TMI Blog2015 (6) TMI 605X X X X Extracts X X X X X X X X Extracts X X X X ..... investment or trade. In the said circular of CBDT it has stated the principle laid down in the case of Associated Industrial Development Company (P) Ltd. [1971 (9) TMI 3 - SUPREME Court ] and in the case of H. Hoick Larsen (1986 (5) TMI 30 - SUPREME Court ) which afforded adequate guidance to the Assessing Officer while determining whether a transaction is in the nature of investment or trade. When the ratio of these decisions when applied to the facts of the present case, then it would be found that assessee satisfied the requirements because as a rule, the assessee had taken delivery at the time of purchase and given delivery at the time of sale in respect of all the shares in its investment portfolio and the assessee had also kept separate records to record the transactions of each category, i.e., delivery based and non-delivery based (F&O). Also, by treating the delivery based transaction as an investment, the assessee clearly established that it did not take the first step as a trader, hence, the result of the delivery based transaction it was treated as short term capital gain or long term capital gain depending upon the period of holding of such shares. The tests of badges ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce sheet were in the nature of trading asset(s) and not capital asset(s), as claimed by the appellant. 2.2 That the CIT(A) erred, on facts and in law, in holding that the intention of the appellant in purchasing shares of so-called insignificant companies revealed that the intention of the appellant was to resell the shares, rather than to hold them or retain them as capital asset. 2.3 That the CIT(A) erred, on facts and in law, in affirming the action of the assessing officer in assessing capital gains as business of levelling various false/baseless allegations, without judiciously appreciating the submission of the appellant. 3. That the AO/CIT(A) erred on facts and in law in charging interest under section 2348 and 234C of the Act. 2. Ground No.1 is general in nature and so is not adjudicated. Apropos ground No.2 is against the confirmation of the order of the AO in assessing the gains of ₹ 2,77,73,257/- arising on sale from long-term capital assets‟ and gain of ₹ 4,06,124/- arising on sale of short term capital assets‟, being investment in equity shares, as business income instead of capital gains as declared by the assessee. 3. Bri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s from business or profession which was set off against income from other sources. 6. The claim of the long term capital gains as above became the bone of contention. Therefore a show cause notice was issued to the appellant by the AO vide letter dated 27.02.2013 asking the assessee to explain as to why the income arising from the sale of M/s Balrarnpur Chini, M/s GMR and M/s Pacelep amounting to ₹ 2,77,73,257/- should not be treated as income from business of share transaction. The above referred show cause notice is reproduced for reference as under: As per Column 8(a) of 3 CD of the audit report, nature of business or profession has been written as share transaction, then why purchase of share of ₹ 3,87,78,265.27 has been shown as investment, in share in the asset side of the balance sheet of the year under consideration and not shown as closing stock of the business. As per Column 8(a) of from 3CD of the audit report, nature of business or profession has been written as share transaction, then why the income arising from the sale of share of Balrampur Chini, GMR and Pacelep amounting to ₹ 2,77,73,257/- has been shown as Long Term Capital Gain and /no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s in the case of M/s Shubhkaran Dass Chiranjilal (Agency) with PAN AAAPC3276C which shows that M/s Subhkaranadass Chiranjilal Agencies is a sole proprietary firm in the name of Sh. Vinod Chaudhary (PAN AAAPC3276C). When the status of the above is a firm then how the assessee has stated that he is a Director in the above company. Moreover assessee has declared only ₹ 24000/- salary income as a director from the so called company in his computation of income for AY 2010-11. Keeping in view of the above facts, I arrived at the conclusion that the assessee spent most of his time in no other work except share trading. The assessee is running his business of share trading by making a sole proprietary firm named M/s. Ashish Choudhary stock Investment whose business premises address is 4410, Ganesh Bazar, Cloth Market, Delhi-110006 as declared by the assessee. The assessee filed a profit loss account balance sheet and tax Audit report of his firm. Keeping in view the above facts, I also arrived at conclusion that the assessee has well developed infrastructure in the form of office equipments and only indulged in the business of share trading. Undoubtedly the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7.02.2008 05.03.2009 08.06.2009 11.06.2009 13.06.2009 13.06.2009 29.07.2009 31.07.2009 06.08.2009 17.09.2009 79200 21160 440 30000 10000 75000 5000 20800 10000 10000 10000 10000 79200 100360 100800 25800 20800 0 30000 20000 10000 20000 10000 0 2. SVC Resources 31.08.2007 14.07.2009 14.07.2009 17.07.2009 04.08.2009 11.08.2009 12.08.2009 21.08.2009 26.08.2009 03.09.2009 07.09.2009 08.09.2009 11.09.2009 15.09.2009 15.09.2009 16.09.2009 22.09.2009 23.09.2009 400000 30000 20000 25000 5000 30000 20000 25000 25000 50000 10000 15000 25000 25000 15500 3000 6500 25000 400000 370000 350000 325000 275000 245000 225000 200000 175000 125000 115000 100000 75000 50000 34500 31500 25000 0 3. Spentex Industries Limited 31.05.2007 31.05.2007 28.06.2007 03.07.2007 05.07.2007 18.07.2007 19.07.2007 27.07.2007 27.07.2007 24.01.2008 18.07.2008 14.10.2008 17.10.2008 24 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sujana Universal Industries Limited 09.07.2007 30.10.2007 18.02.2008 13.03.2008 24.10.2008 24.10.2008 19.01.2009 20.01.2009 22.01.2009 23.01.2009 23.01.2009 27.01.2009 27.01.2009 28.01.2009 28.01.2009 29.01.2009 29.01.2009 30.01.2009 30.01.2009 02.02.2009 02.02.2009 03.02.2009 03.02.2009 04.02.2009 01.12.2009 02.12.2009 08.12.2009 400000 200000 25000 25000 10000 338 2109 108776 3565 19075 3038 124203 30000 30100 7900 1962 38 7000 53963 17908 2592 4024 95077 18670 173579 26421 139662 400000 600000 625000 650000 660000 660338 662447 771223 774788 793863 796901 921104 951104 981204 989104 991066 991104 998104 1052067 1069975 1072567 1076591 1141668 1160338 133917 1360338 1500000 7. Valeccha Engineering Limited 16.05.2007 16.05:2007 21.05.2007 26.06.2001 26.06.2007 10.07.2007 12.07.2007 13.07.2007 I 2.11.2007 13.1l.2007 05.01.2008 15.01.2008 2I.10.2008 09.04.2010 7000 7969 31 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thing but intention of trade. It was pointed out by the AO that the assessee earned only a meagre amount of dividend of ₹ 1, 09,444/- from the share he had with him in the year under consideration. 10. According to AO the facts and circumstances of the case indicate that the voluminous share transaction were in the nature of the business and purchase of share by the assessee was not for the purpose of earning dividend, but with the dominant intention of resale in order to earn profit. According to AO, the huge volume of share transaction, the repetition and continuity of the transaction, give them a flavour of 'trade'. The magnitude, frequency and the ratio of sales and purchase on the total holding is evidence that the assessee had not purchased the share as an investment, but with the intention to trade in such scripts. So according to AO, during the year the assessee traded in purchase and sale of share through brokers and declared huge profit earned from this activity. The assessee has shown this income as long term capital gain and short term capital gain on the plea that the shares were held as investment. However, while going through the share account on dem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee. 14. AO relied on ITAT Delhi Bench 'E' in the case of ACIT, Cirle-31(I), New Delhi Vs. Manoj Kumar Samdaria (2012) 27 Taxmann.com 102 (Delhi) and on CBDT instruction No. 1872 dated Accordingly, relying upon the CBDT instruction No.1827 dated 31.08.1989, circular No.4/2007 dated 15.06.2007 and order of ITAT Delhi Bench 'E' in the case ACIT, Circle-31(1), New Delhi Vs Manoj Kumar Samdaria (20l2)27 Taxmann.com 102 (Delhi), the AO was of the view that the assessee traded in share with the motive of profit. He, therefore, assessed the gain resulting from the sale of share of ₹ 2,81,79,381/- as business income. 15. Aggrieved the assessee preferred an appeal before the ld CIT(A) who was pleased to dismiss the same. 16. Aggrieved the assessee is before us. 17. The Ld. Counsel Shri Rohit Jain submitted that the appellant is a resident individual and was engaged in the trading of derivatives (Futures and Options), investment in shares and looking after textile trading business as director of M/s Shubh Karan Das Chiranji Lal Agencies Private Limited. The appellant during the year under consideration realized long term capital gains of ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... added to the capital of the appellant in the balance sheet and duly shown in his return of income. And it is only for the second set of transactions that the tax audit was required. But for extra and abundant caution Tax-Audit has been done. The Ld. AR pointed out that the AO only referred clause 8(b) of the audit report and did not mention clause 12(a) of the same audit report, which mentioned that there is no closing stock of shares. 20. The ld counsel for the assessee brought to our attention the details of the long term capital investment made in shares for the year under appeal and contended that the AO has brought in transaction which is not relevant for the A.Y. under consideration and submitted that only three scrip has been sold in this year to claim long-term capital gain and 3 scrip for short term capital gain. 21. The long-term capital of the assessee is as under:- 22. And the short-term capital gain is as under:- 23. The Ld. AR pointed out the following factors which would further corroborate the claim of the appellant showing the shares as investments: i) The shares were bought from appellant's own funds and there were no borrowings. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cts of the appellant and in view of the other factors as detailed above, there is no reason why the accepted position of appellant being a share investor should be disturbed. (Refer P-18-19 in paperbook) 24. Countering the next objection of the assessing officer that M/s Shubh Karan Das Chiranji Lal Agencies Private Limited, with whom the appellant is stated to be a director, the AO observed that this is no company which is existing and it is only an Agency; and that the appellant spends most of his time in no other work except share trading, the ld AR submitted that the assessing officer has reached this conclusion without fully appreciating the true facts. According to the ld AR M/s Shubh Karan Das Chiranji Lal Agencies Private Limited is indeed in existence and its company master data record from ROC is placed at P-17 of the paper book and the appellant is stated to be a director in this company since 01.03.1995. Further, it was submitted that there is also a proprietorship firm by the name of Shubh Karan Das Chiranji Lal Agencies, whose proprietor is Sh. Vinod Choudhary, appellant's father. The appellant devotes almost all his time looking after the family business in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... orizon. 27. The Ld. AR relied on the decision of jurisdictional Delhi High Court in the matter of CIT v. Vinay Mittal: 208 Taxman 106 dated 27.04.2012 and attention was also invited to the decision of the Hon'ble Bombay High Court in the case of CIT v. Gopal Purohit: 336 ITR 287, dated 06.01.2010 wherein it was held that Capital gains on sale of shares treated as investment income in earlier years cannot be treated as business income in subsequent years. Further, the Hon'ble Court also upheld that the assessee can keep two portfolios one for jobbing (without delivery) to be classified as business portfolio and other as investment to be classified as capital gains. 28. It was pointed out by the ld AR that the said decision of the Hon‟ble Bombay High Court has now been affirmed by the Supreme Court vide judgment dated 15th November, 2010 in CC 16802 / 2010, 334 ITR 308 (St.) and emphasised consistency in tax treatment. Similarly, on the similar issue in the case of Jindal Photo Investment Ltd., the Hon‟ble Supreme Court dismissed the department's SLP on 13.09.2010 reported in 334 ITR (St.) 307. The appellant's case according to the ld AR is squarely ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hin 2-3 days of purchase and frequent churning of securities. In the light of the aforesaid submission the ld. AR prayed that the impugned confirmation of the addition made by the AO by treating the capital gains on shares as business income be deleted. 32. On the other hand the ld DR supported the decision of the ld CIT(A) and argued on the same lines as reasoned by the AO and does not want us to interfere in the impugned order of the ld CIT(A) and cited the following decisions Dalhousie Investment Trust Company Limited Vs. CIT. (1968) 68 ITR 486(SC) Raja Bahadur Visheshwara Singh v. CIT [1961] 41 ITR 685; Kkaran R Bahl Vs. ITO (60 SOT 63 (Mumbai) Commissioner of Income Tax, U.P v. Madan Gopal Radhey Lal, [1969] 73 ITR 652 (SC); DCIT v Mukeshbhai Babulal Shah (2013) 57 SOT 45 (Rajkot) (Trib.) N.K. Leasing Construction Ltd. Vs. CIT (2006) 285 ITR 330(AP) Manoj Kumar Samdari Vs. Commssion of Income Tax, ITA No.97 of 2014 (Del) 33. The ld DR pointed out the frequency of transaction made by the assessee in the relevant Assessment Year from the D-MAT Account which has been filed by the revenue from the paper book is reproduced as under:- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Such examplers abound in assesses case throughout 07-08 to 11-12. 36. In the light of the decisions relied upon by her, the ld DR vehemently supported the decision of the ld CIT(A) and urged us not to disturb the well reasoned order of the ld CIT(A). 37. We have heard the rival submission and perused the relevant material on record. Before proceeding further, we want to make it clear that any decision to hold shares as Investment‟ or Stock-in-trade‟ depends on a host of factors. There can be no single criteria to decide the nature of shares purchased. In fact, it is the cumulative effect of all the relevant factors, which is taken into consideration for reaching a conclusion as regards the nature of shares and the resultant income arising from their transfer. There may be some factors indicating the purchase of shares as investment, while others may point towards stock-in-trade. It is the holistic consideration of all such factors which is kept in view while deciding as to whether the shares purchased by the assessee constituted stock-in-trade or investment. 38. Since the AO and the ld CIT(A) has held that the profit assessee earned is business income and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vailable on record. For the purpose of finding out the nature of transaction as to whether it is an investment or adventure in the nature of trade, one has to see the intention of the assessee at the time of purchase of the shares. The assessee is only an employee having salary income. In the return of income as seen from the assessment order, the assessee has claimed ₹ 83,712 from share trading and another sum of ₹ 53,84,239 as exempt income on sale of certain sales. This ₹ 53,84,239 was treated by the Assessing Officer as business income on sale of shares. We find that the CBDT in its circular No. A12007. dated 15-06-2007 examined this issue and after referring to the judgment of the apex court, instructed all its officers that it is possible for the taxpayer to have two portfolios, i.e., investment portfolio. When the assessee has two portfolios, the income has to. be assessed both under' the head. capital gains as well as business income . In this case, the assessee is a salaried employee.' Therefore, the question of maintaining two portfolio does not arise for consideration. The assessee invested his funds as investment and whenever it was convenie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rade. In the case of CIT Vs. Associated Industrial Development Co. (P) Ltd., 82 ITR 586, the Hon‟ble Supreme Court had observed that whether a particular holding of shares is by way of investment or forms part of the stock-in-trade is a matter which is within the knowledge of the assessee who holds the shares and it should, in normal circumstances, be in a position to produce evidence from its records as to whether it has maintained any distinction between those shares which are its stock-in-trade and those which are held by way of investment. Ld. Counsel of the assessee has submitted that the assessee is an individual who have invested his funds in various shares. During the year, the assessee has invested his own fund (not borrowed fund) in various shares and earned a long term capital gain of ₹ 2,77,73,257/- and short term capital gain of ₹ 4,06,124/-. The assessee also earned an amount of ₹ 1,09,444/- and ₹ 1,49,314/- from HDFC short term plan on account of dividend and ₹ 22,64,917/- from as interest income. The assessee filed its return of income for the assessment year on 28.09.2010 declaring an income of ₹ 14,10,350/-. 45. We have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the DMAT account of the assessee firm and all the transactions were done by investment in shares through Dynamic Equities Pvt. Ltd., a member of Bombay Stock Exchange. 47. Further it was submitted by the ld. AR‟s that as and when the opportunity arose, the assessee sold the shares in the open market. According to him, the said gain was in the nature of short term capital gain which was duly offered for taxation in the return of income filed by the assessee firm for the year under consideration as well as earned long term capital gain on shares which were sold after one year. Further, it was brought to our notice that assessee has not borrowed funds for the purpose of making investments so as to call its activities as business. 48. The CBDT Circular No. 4/2007, dated 15.06.2007, which has specifically spelled out the conditions to determine the nature of transaction which is in question of being whether it is in the nature of investment or trade. In the said circular of CBDT it has stated the principle laid down in the case of Associated Industrial Development Company (P) Ltd. as reported in 82 ITR 586 and in the case of H. Hoick Larsen as reported in 160 ITR 67 (SC) w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld by an assessee as a capital investment or as stock in trade depending upon a large number of factors chiefly the intention of the assessee. However once the nature of shareholding is accepted or known no further test is required to be applied for determining the nature of dividend income. If the holding of shares is business (Stock in trade) then the dividend earned is business income, although required to be taken under the head Other Source for computing of income. If shares are held as a capital investment the dividend cannot be taken as business income. 52. The Hon‟ble Madras High Court in CIT Vs. Ramaamirtham reported in 306 ITR 239 has observed that there is nothing in law which prohibits a trader in shares to invest in shares. It further held as under: Held, dismissing the appeal, that on the facts it was found that the assessee had been maintaining separate books of account for trading in shares and investment in shares. The assessee was carrying on the business only in the name of the company and the surplus earned from the company had been shown as business income. The payment for the shares had been done by the assessee in his personal account. Further, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of investment or forms part of the stock-in-trade is a matter which is within the knowledge of the assessee who holds the shares and it should, in normal circumstances, be in a position to produce evidence from its records as to whether it has maintained any distinction between those shares which are in stock-in-trade and those which are held by way of investment. 54. The Mumbai ITAT (having identical facts as in the case of the appellant), in the case of Gopal Purohit vs. CIT (2009) 122 DJ 87 (Mumbai) wherein it has been specifically held: The assessee was engaged in sale and purchase of shares. The delivery based transactions were to be treated as of nature of investment and profits there from were to be treated as short term or long term capital gains depending on period of holding. Such profits could not be treated as business income. 55. The said judgment has further been upheld by the Hon'ble Bombay High Court reported at 228 CTR 582 (2010). In the present case, all the transactions are delivery based transactions only. The assessee also earned dividend of ₹ 1,09,444/- thereon. It is also noted that the appellant had not claimed the amount of SIT pai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the financial statements for the year ended 31st March, 2008 and 31st March, 2009. The said shares were not acquired/ held as stock-in-trade . 60. The ld DR pointed to the return from assessment year 2011-12 filed by PB letter dated 17.12.2014, wherein she took our attention to Page 2 of the ITR wherein investment column is shown as Nil‟ and she contended that if the assessee was investing in shares, he could have duly reflected it in the column specified for it in the ITR form. So the ld DR‟s contention was that assessee was in business of shares and has not so reflected about shares in the investment column. There is a flaw in the aforesaid contention of the ld DR, for the simple reason that a perusal of Page 1 of ITR form reveals Part A-Balance sheet where the particulars are required to be furnished of the proprietary business as is evident from a perusal of the same. When the assessee is not doing trading/ business in shares then he has rightly not reflected the same in Page 2 of the ITR form, whereas if he was doing business of shares he should have reflected it. However we find that, the assessee had filed along with the ITR form, the balance sheets i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d and held for substantial period of time prior to transfer, are of capital account. In identical circumstances, the Courts and various benches of the Tribunal in the following decisions have held that assessee has rightly declared non-delivery based transactions as business income and delivery based transactions as resulting in capital gain: CIT v. Gopal Purohit: 336 lTR 287 (80m.) [affirming Gopal Purohit: 122 TTJ 87 (Mum] The Supreme Court has dismissed departmental appeal: 334 ITR 308 (st.) (SC). (refer pages 1-3 of assessee paper book of case law) CIT v. M.G. Share Stock (P.) Ltd.: ITA No. 177 of2014 (Del) CIT v. Vinay Mittal: 208 Taxmann 106 (Del.) [refer pages 11-14 of assessee paper book of case law] CIT v. M/s Devasan Investment Pvt. Ltd: ITA No. 1102 1103/ 20 II (Del.) [refer pages 15-33@27 of assessee paper book of case law] CIT v. Jubilant Securities (P.) Ltd.: 333 ITR 445 (Del) CIT v. CNB Finwiz LTd.: 228 Taxman 175 (Del) 64. As regards the contention of the DR that dividend was received in respect of shares held as investment as well as trading, it is common knowledge that shares would result in dividend, irrespective of the f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e earlier assessment year, then the same cannot be denied in the subsequent year at the time of transfer. The following cases say that: CIT v. Gopal Purohit: 336 ITR 287 (Bom.) [affirming GopalPurohit: 122 TTJ 87 (Mum.) The Supreme Court has dismissed departmental appeal: 334 ITR 308 (st.) (SC). [refer pages 1-3 of assessee paper book of case law] CIT vs. Devasan Investment P. Ltd: [T As 1102 110312011 (Del HC) [refer pages 15-33 @ 27 of assessee paper book of case law] CIT v. Avinash Jain (2013) 214 Taxman 260/362 ITR 441 (Del) [refer pages 38- 39 40-47 @ 46 of assessee paper book of case law] CIT vs. Gulmohar Finance Limited: 170 Taxman 483 (Del) [refer pages 34-37 @ 36 of assessee paper book of case law] Sunil Kumar Ganeriwal V. DCIT: 134 ITD 179 (Mum.) [refer pages 48-53@ 51 of assessee paper book of case law] ]DCIT vs. SMK Shares Stock Broking : ITA No. 799/Mum.l2009 (Mum) [refer pages 91-98 @. 91 of assessee paper book of case law) 70. The contention of the ld DR against sale of shares of M/s Balrampur Chini is not understandable. The fact is that shares in M/s Balrampur Chini were acquired in January, 2008 and sold after holding the same fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... every acquisition by a dealer in a particular commodity is acquisition for the purpose of his business; in each case the question is one of intention to he gathered from the evidence of conduct by the acquirer and his dealings with the commodity. The aforesaid observations clearly support the case of the appellant rather than supporting the case of the Revenue. d) In Karan R. Bahl vs. ITO: 60 SOT 63, the Tribunal simply reiterated the settled legal position that the primary onus is on the assessee that the shares were held as investment. In the present case, the assessee has clearly discharged the aforesaid onus by pointing out that shares were held as investment and non as stock-in-trade as reflected in the financial statements, which has been held by the Supreme Court in the case of Karam Chand Thapar And Bros (P) Limited vs. CIT: 82 ITR 899 to be material factor. Further, all the transactions of purchase/ sale of shares were delivery based and there was substantial holding period prior to transfer of shares. e) Sanjay Kumar Jhabak vs. DClT: 63 SOT 66(Bom): In that case holding period of assessee was few days only and there was substantial frequency and regularity ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nder the head Capital gains‟. This treatment of profit from sale of shares held as investment has not been disputed by the AO in the assessments made u/s 143(3) of the Act. The assessee has placed on record a copy of the assessment orders for immediately preceding assessment year ( page 22-26 of paper book) in which there was Short-term capital gain‟ which has been accepted by the AO vide his order dated 22.12.2011. It is pertinent here to add that the AO has confirmed the genuineness of the short term capital gain for the said Assessment Year 2009-10 by making an office note which is annexed at Pg. 3 of Departmental Paper Book, Volume-IV which is as under:- Name: Sh. Ashish Choudhary PAN:AAAPC2274L A.Y.:2009-10 Office Note As per AIR information and reason for selection the undersigned has examined the genuineness of STCG u/s 11A. The AR of the assessee submitted the details of STT payments. Necessary details were produced and filed which were examined and no adverse inference was drawn. (AASTHA LAKSHMI) Asstt. Commissioner of Income Tax Circle-29(1), New Delhi 76. Similarly orders passed u/s 143 (1) for assessment year 2008-09 (Departme ..... X X X X Extracts X X X X X X X X Extracts X X X X
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