Sh. Radha Mohan Seva Shiksha Samiti, Mathura v. The C.I.T.-1, Agra

ITA 362/AGR/2010 | misc
Pronouncement Date: 19-09-2011 | Result: Allowed

Appeal Details

RSA Number 36220314 RSA 2010
Assessee PAN AAEAS2204F
Bench Agra
Appeal Number ITA 362/AGR/2010
Duration Of Justice 1 year(s) 1 month(s) 13 day(s)
Appellant Sh. Radha Mohan Seva Shiksha Samiti, Mathura
Respondent The C.I.T.-1, Agra
Appeal Type Income Tax Appeal
Pronouncement Date 19-09-2011
Appeal Filed By Assessee
Order Result Allowed
Bench Allotted DB
Tribunal Order Date 19-09-2011
Date Of Final Hearing 18-08-2011
Next Hearing Date 18-08-2011
Assessment Year misc
Appeal Filed On 06-08-2010
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL AGRA BENCH AGRA BEFORE SHRI H.S. SIDHU JUDICIAL MEMBER AND SHRI K.G. BANSAL ACCOUNTANT MEMBER ITA NO.362/AGR/2010 SHRI RADHA MOHAN SEVA SHIKSHA SAMITI VS. COMMISSIONER OF INCOME TAX-1 VILLAGE ALABAL POST SONKH AGRA. MATHURA DISTRICT (U.P.) (PAN : AAEAS 2204 F). (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI M.M. AGARWAL C.A. RESPONDENT BY : SHRI A.K. SHARMA JR. D.R. DATE OF HEARING : 18.08.2011 DATE OF PRONOUNCEMENT : 19.09.2011 ORDER PER BENCH : THE ASSESSEE HAS FILED THE PRESENT APPEAL AGAINST T HE IMPUGNED ORDER DATED 28.06.2010 PASSED BY THE LD. CIT-I AGRA ON THE FOL LOWING GROUNDS OF APPEAL :- 1. BECAUSE LEARNED CIT HAS ERRED IN LAW AS WELL AS IN THE FACTS AND CIRCUMSTANCES OF THE CASE IN REJECTING THE APPL ICATION FILED BY THE APPELLANT FOR REGISTRATION UNDER SECTION 12AA OF TH E ACT. 2. BECAUSE LEARNED CIT ERRED IN LAW IN REJECTING TH E APPLICATION OF THE APPELLANT FOR REGISTRATION UNDER SECTION 12A A OF THE ACT ON WHOLLY NON EXISTENT AND IRRELEVANT CONSIDERATION. 3. BECAUSE ON A DUE CONSIDERATION OF THE FACTS AND CIRCUMSTANCES OF THE CASE MATERIAL PLACED BEFORE HER LEARNED CI T HAS ERRED IN 2 HOLDING THAT THE APPELLANT SOCIETY WAS NOT (I) FOR CHARITABLE PURPOSES (II) HAD NOT CARRIED ANY CHARITABLE ACTIVITY AND (I II) ITS ACTIVITIES OF GENERATING FUNDS WERE NOT GENUINE. THE APPELLANT CRAVES AND LEAVES TO HIS RIGHT TO ADD DELETE ALTER SUBSTITUTE OR MODIFY ANY OR ALL THE GROUNDS OF APPEAL AT ANY SUITABLE TIME. 2. THE ASSESSEE SOCIETY HAS MOVED AN APPLICATION DA TED 17.12.2009 IN FORM NO.10A FOR GRANT OF REGISTRATION UNDER SECTION 12AA OF THE INCOME TAX ACT 1961 (THE ACT HEREINAFTER). THE ASSESSEE SOCIETY HAS ALSO ATTACHED CERTIFIED COPY OF SOCIETYS REGISTRATION DEED COPY OF INCOME AND EXP ENDITURE ACCOUNT AND BALANCE SHEET FOR THE YEARS 2006-07 TO 2008-09 AND BRIEF PA RTICULARS OF THE ACTIVITIES OF THE SOCIETY ALONGWITH THE SAID APPLICATION AND REQUESTE D THE LD. CIT-I AGRA TO GRANT REGISTRATION UNDER SECTION 12AA OF THE ACT. THE LD . CIT-I ISSUED A NOTICE DATED 07.05.2010 TO THE ASSESSEE SOCIETY REQUIRING HIM TO PRESENT ITS CASE ON 14.05.2010. IN RESPONSE TO THE SAME THE LD. AUTHORISED REPRESE NTATIVE OF THE ASSESSEE APPEARED AND REQUESTED FOR ADJOURNMENT AND THE LD. CIT-I ADJOURNED THE CASE FOR 25.05.2010. ON 25.05.2010 THE LD. AUTHORISED REPR ESENTATIVE OF THE ASSESSEE APPEARED AND FILED A WRITTEN SUBMISSION. THE LD CI T-I AGRA POINTED OUT TO THE LD. AUTHORISED REPRESENTATIVE OF THE ASSESSEE THAT THE SOCIETY IS RUNNING I.T.I. WHICH IS TO PROVIDE VOCATIONAL EDUCATION TO THE TRAINEES. S INCE THE WORD CHARITABLE DOES NOT INCLUDE VOCATIONAL EDUCATION THE ASSESSEE SOCI ETY WAS REQUIRED TO SHOW CAUSE AS TO WHY ITS APPLICATION FOR GRANT OF REGISTRATION UNDER SECTION 12AA OF THE ACT BE NOT REJECTED AND THE CASE WAS ADJOURNED FOR 02.06.2 010. THE ASSESSEE SOCIETY 3 AGAIN FURNISHED A WRITTEN SUBMISSION BY WAY OF REPL Y TO THE QUERY RAISED BY THE LD. CIT-I AND PLEADED THAT THE OBJECTS OF THE SOCIETY A RE CHARITABLE AND GENUINE IN NATURE BECAUSE ACCORDING TO SECTION 2(15) OF THE AC T CHARITABLE PURPOSE INCLUDES RELIEF TO THE POOR EDUCATION MEDICAL RELIEF AND A DVANCEMENT OF ANY OTHER OBJECTS OF GENERAL PUBLIC UTILITY. THE ASSESSEE FURTHER PL EADED BEFORE THE LD. CIT-I THAT THE SOCIETY IS ESTABLISHED FOR GIVING I.T.I. TRAINING T O VILLAGE STUDENTS AND REQUESTED FOR GRANT OF REGISTRATION TO THE SOCIETY UNDER SECTION 12AA OF THE ACT. 3. AFTER PERUSING THE MEMORANDUM OF ASSOCIATION TH E LD. CIT-I NOTICED THAT THE MAIN OBJECT OF THE SOCIETY IS TO PROVIDE VOCATI ONAL EDUCATION TO THE TRAINEES WHICH SHOWS THAT THE SOCIETY IS NOT FORMED FOR CARR YING OUT THE EDUCATION THEREFORE IS NOT FOR CHARITABLE PURPOSE AS DEFINED UNDER SECTION 2(15) OF THE ACT. SECONDLY THE LD. CIT-I ALSO NOTICED THAT THE ASSES SEE SOCIETY HAS RECEIVED DONATION FROM A NUMBER OF PERSONS WHO ARE NOT ASSESSED TO TA X AND THEY HAVE SHOWN THEIR SOURCE OF INCOME FROM AGRICULTURAL INCOME IN THEIR CONFIRMATION LETTERS WHICH IS UNEXPLAINED INCOME. THEREFORE THE ACTIVITIES OF T HE SOCIETY REGARDING GENERATION OF FUNDS ARE ALSO NOT GENUINE. THE LD. CIT-I AGRA VIDE THE IMPUGNED ORDER HAS REJECTED THE APPLICATION FILED BY THE ASSESSEE SOCI ETY DATED 17.12.2009 AND DENIED TO GRANT REGISTRATION TO THE ASSESSEE SOCIETY. AGG RIEVED BY THE SAME THE ASSESSEE FILED THE PRESENT APPEAL. 4 4. THE LD. COUNSEL FOR THE ASSESSEE CONTENDED THAT THE ASSESSEE SOCIETY IS REGISTERED UNDER SOCIETIES ACT WHICH HAS BEEN ESTAB LISHED ON 23.11.206 FOR GIVING I.T.I. TRAINING TO THE VILLAGES STUDENTS AND IS ALS O APPROVED BY THE D.G.E.T. HE FURTHER STATED THAT THE COURSES RUN BY THE SOCIETY ARE AS PER CENTRAL GOVERNMENT PROGRAMME. THE ASSESSEE SOCIETY HAS FILED A VALID APPLICATION BEFORE THE LD. CIT-I AGRA WHICH IS SUPPORTED BY A VALID TRUST DEED AND O THER DOCUMENTARY EVIDENCES ESTABLISHING THAT THE ASSESSEE TRUST IS IMPARTING E DUCATION THROUGH THE COLLEGE RUN BY THE ASSESSEE SOCIETY. HE FURTHER STATED THAT TH E LD. CIT-I HAS REJECTED THE APPLICATION OF THE ASSESSEE SOCIETY FOR REGISTRATIO N WITHOUT ANY BASIS OR EVIDENCE CONTRARY TO THE EVIDENCES PRODUCED BY THE ASSESSEE THEREFORE THE IMPUGNED ORDER DESERVES TO BE CANCELLED. HE ALSO FILED A PAPER BO OK TO SUPPORT HIS ARGUMENT. THE LD. COUNSEL FOR THE ASSESSEE ALSO FILED A PAPER BOO K CONTAINING PAGES NOS.1 TO 267 IN WHICH HE HAS ATTACHED VARIOUS DOCUMENTARY EVIDEN CES SUPPORTING THE CLAIM OF THE ASSESSEE AND ESTABLISHING THE CHARITABLE ACTIVI TIES DONE BY THE SOCIETY AND UTILISED THEIR FUNDS FOR THE GENUINE AND CHARITABLE ACTIVITIES. THE LD. COUNSEL FOR THE ASSESSEE ALSO FILED COPIES OF VARIOUS DECISIONS RENDERED BY THE HONBLE HIGH COURTS AND TRIBUNAL FROM PAGE NOS.228 TO 267 WHICH INCLUDE CIT VS. SORABJI NUSSERWANJI PAREKH 201 ITR 939 (GUJ) GUJARAT STAT E CO-OPERATIVE UNION VS. CIT 195 ITR 279 (GUJ.) BIHAR INSTITUTE OF MINING & MINE SURVEYING VS. CIT 208 ITR 608 (PAT.) SAURASHTRA EDUCATION FOUNDATION VS. CIT 273 ITR 139 (GUJ.) SELF 5 EMPLOYERS SERVICE SOCIETY VS. CIT 247 ITR 18 (KER. ) FIFTH GENERATION EDUCATION SOCIETY VS. CIT 185 ITR 634 (ALL.) & SWAMI BRAHM D ASS TRUST VS. CIT (ORDER DATED 17.04.2009 IN ITA NO.710/AGR/2008). LASTLY HE REQUESTED THAT THE IMPUGNED ORDER MAY BE CANCELLED AND DIRECTION BE IS SUED TO THE LD. CIT-I AGRA TO GRANT REGISTRATION TO THE ASSESSEE SOCIETY AS PRAYE D FOR BY THE ASSESSEE. 5. ON THE CONTRARY THE LD. DEPARTMENTAL REPRESENTA TIVE RELIED UPON THE IMPUGNED ORDER PASSED BY THE LD. CIT-I AGRA. HE S TATED THAT THE ASSESSEE SOCIETY IS NOT FORMED FOR IMPARTING EDUCATION. IT IS ONLY PROVIDING I.T.I. TRAINING TO THE STUDENTS WHICH ARE NOT COVERED BY EDUCATION. THEOR EM THE LD. CIT-I HAS RIGHTLY REJECTED THE APPLICATION OF THE ASSESSEE FOR REGIST RATION BECAUSE THE ASSESSEE SOCIETY HAS NOT CARRIED OUT ANY CHARITABLE ACTIVITIES AND T HE FUNDS GENERATED BY THE SOCIETY IS ALSO NOT GENUINE. 6. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE R ELEVANT RECORDS AVAILABLE WITH US. AS A MATTER OF RECORD THE ASSESSEE SOCIE TY FILED AN APPLICATION FOR ITS REGISTRATION UNDER SECTION 12AA OF THE ACT ON PRESC RIBED FORM NO.10A IN TRIPLICATE CERTIFIED COPY OF THE SOCIETYS REGISTR ATION DEED COPY OF INCOME AND EXPENDITURE ACCOUNT AND BALANCE SHEET FOR THE YEARS 2006-07 TO 2008-09. THE ASSESSEE SOCIETY HAS ALSO FILED BRIEF PARTICULARS O F THE ACTIVITIES OF THE SOCIETY ALONGWITH REGISTRATION CERTIFICATE ISSUED BY THE RE GISTRAR OF SOCIETY DATED 23 RD 6 NOVEMBER 2006. THE ASSESSEE HAS ALSO FILED ALL DO CUMENTARY EVIDENCES WHICH HAVE BEEN FILED BEFORE THE LD. CIT-I AGRA AT THE T IME OF HEARING IN THE SHAPE OF PAPER BOOK BEFORE US. WE HAVE THOROUGHLY PERUSED T HE SAME AND FOUND THAT THE ASSESSEE SOCIETY HAS BEEN CREATED ON 23 RD NOVEMBER 2006 AND IS REGISTERED WITH THE REGISTRAR OF SOCIETIES. WE HAVE PERUSED THE MEMORA NDUM OF SOCIETY WHICH IS AT PAGE NOS. 6 TO 8 OF THE ASSESSEES PAPER BOOK. WE HAVE THOROUGHLY GONE THROUGH THE SAME AND FOUND THAT THE SOCIETY NAMED SHRI RADH A MOHAN SEVA SHIKSHA SAMITI HAS BEEN ESTABLISHED IN A VILLAGE ALABAL P.O. SONK H DISTRICT MATHURA (U.P.). THE MAIN MOTIVE OF THE ASSESSEE SOCIETY IS TO RUN PRIMA RY SCHOOL HIGHER SECONDARY SCHOOL DEGREE COLLEGES TECHNICAL AND AGRICULTURAL INSTITUTION FOR EDUCATIONAL DEVELOPMENT AND FREE EDUCATION FOR MEN AND WOMEN. ALTHOUGH IN THE MEMORANDUM THE ASSESSEE SOCIETY HAS 24 OBJECTS FOR ITS ESTABLISHMENT BUT ACCORDING TO THE ARGUMENT ADVANCED BY BOTH THE PART IES WE HAVE TO SEE WHETHER THE ASSESSEE SOCIETY HAS BEEN ESTABLISHED FOR CHARITABL E PURPOSE AND HAS ALSO CARRIED OUT SUCH ACTIVITIES. IT IS A MATER OF RECORD THAT THE ASSESSEE SOCIETY HAS FILED A VALID APPLICATION IN FORM NO.10A IN TRIPLICATE ALONGWITH CERTIFIED COPY OF THE SOCIETYS REGISTRATION DEED COPY OF INCOME AND EXPENDITURE A CCOUNT AND BALANCE SHEET FOR THE YEARS 2006-07 TO 2008-09. THE ASSESSEE SOCIETY HAS ALSO FILED BRIEF PARTICULARS OF ITS ACTIVITIES BEFORE THE LD. CIT-I AGRA. ACCO RDING TO SECTION 12AA OF THE ACT THE LD. CIT ON RECEIPT OF AN APPLICATION FOR REGIST RATION OF A TRUST OR INSTITUTION SHALL CALL FOR SUCH DOCUMENT OR INFORMATION FROM THE TRUS T OR INSTITUTION AS HE THINKS 7 NECESSARY IN ORDER TO SATISFY HIMSELF ABOUT THE GEN UINENESS OF ACTIVITIES OF THE TRUST OR INSTITUTION. THE LD. CIT CAN ALSO MAKE ENQUIRIE S AS HE MAY DEEM NECESSARY IN THIS BEHALF. AFTER SATISFYING HIMSELF ABOUT THE OB JECTS OF THE TRUST OR INSTITUTION AND THE GENUINENESS OF ITS ACTIVITIES THE LD. CIT SHAL L PASS AN ORDER FOR REGISTERING THE TRUST OR INSTITUTION OR REFUSE TO REGISTER THE SAME AND INFORM THE TRUST OR INSTITUTION ACCORDINGLY. IN THE PRESENT CASE THE LD. CIT-I IS OF THE OPINION THAT THE ASSESSEE SOCIETY HAS NOT BEEN ESTABLISHED FOR CHARITABLE PUR POSES AND IS ALSO NOT CARRYING OUT ANY CHARITABLE ACTIVITIES. THE LD. CIT-I IS ALSO OF THE OPINION THAT THE ACTIVITIES OF GENERATING FUNDS ARE ALSO NOT GENUINE. AFTER HEARI NG THE LD. COUNSEL FOR THE ASSESSEE AND THOROUGHLY PERUSING THE DOCUMENTARY EV IDENCES FILED BY HIM IN THE SHAPE OF PAPER BOOK WE ARE OF THE CONSIDERED OPINI ON THAT AS PER THE MEMORANDUM OF THE ASSESSEES TRUST THE MAIN OBJECT OF THE ASSESSEE TRUST IS TO RUN EDUCATIONAL INSTITUTIONS ESPECIALLY TECHNICAL AND AGRICULTURAL INSTITUTION FOR EDUCATIONAL DEVELOPMENT AND FREE EDUCATION FOR MEN AND WOMEN IN THE RURAL AREA IN DISTRICT MATHURA UTTAR PRADESH. THE ASSESSEE T RUST RECEIVING VOLUNTARY DONATION FROM THE PERSONS OF SURROUNDING AREA AS PER CONFIRM ATION LETTERS FILED BY THE ASSESSEE TRUST IN THE ASSESSEES PAPER BOOK FROM PA GE NOS.37 TO 140. WE HAVE SEEN THAT MOST OF THE PEOPLE WHO DONATED THE MONEY ARE A GRICULTURISTS AND ARE RETIRED PERSON. THE ASSESSEE HAS DISCHARGED ITS ONUS BY FI LING THEIR CONFIRMATION LETTERS. WE HAVE ALSO SEEN THE INCOME AND EXPENDITURE ACCOUN T AND BALANCE SHEET FOR THE YEARS 2006-07 TO 2008-09 WHICH IS RELEVANT FOR THE PERIOD UNDER CONSIDERATION AND 8 FOUND THAT THE ASSESSEE TRUSTS ACCOUNTS HAVE BEEN AUDITED BY CHARTERED ACCOUNTANT AS PER LAW. NO DEFECT HAS BEEN POINTED OUT IN THE ACCOUNTING SYSTEM MAINTAINED BY THE ASSESSEE SOCIETY. THEREFORE THE FINDING OF TH E LD. CIT-I REGARDING THE ACTIVITIES OF GENERATING FUNDS OF THE ASSESSEE TRUST ARE NOT G ENUINE IS WITHOUT ANY BASIS. AS FAR AS THE PURPOSE OF ESTABLISHMENT OF THE ASSESSEE TRUST AND ITS ACTIVITIES ARE CONCERNED WE FOUND THAT THE ASSESSEE TRUST HAS FIL ED ITS MEMORANDUM BEFORE THE LD. CIT-I WHICH CLEARLY SHOWS THAT THE ASSESSEE TRUST H AS BEEN ESTABLISHED FOR RUNNING EDUCATIONAL INSTITUTIONS ESPECIALLY THE TECHNICAL EDUCATION PROVIDING FREE EDUCATION FOR MEN AND WOMEN. THE LD. CIT-I HAS NOT ICED THAT THE MAIN AIM OF THE SOCIETY IS TO PROVIDE VOCATIONAL EDUCATION TO THE T RAINEES WHICH SHOWS THAT THE SOCIETY IS NOT FORMED FOR IMPARTING EDUCATION. LD. CIT-I WAS OF THE OPINION THAT PROVIDING VOCATIONAL EDUCATION TO THE TRAINEES IS N OT FORMED FOR IMPARTING EDUCATION AND IS NOT FOR CHARITABLE PURPOSE AS DEFI NED UNDER SECTION 2(15) OF THE ACT. WE ARE OF THE CONSIDERED OPINION THAT AS PER THE WRITTEN REPLY BY THE ASSESSEE DATED 11.06.2010 FILED BEFORE THE LD CIT-I AGRA TH E ASSESSEE SOCIETY HAS FILED VARIOUS DOCUMENTARY EVIDENCES ESTABLISHING THAT THE ASSESSEE SOCIETY IS PROVIDING EDUCATION BY GIVING I.T.I. TRAINING TO THE VILLAGE STUDENTS WHICH IS APPROVED BY THE DIRECTOR TRAINING AND EMPLOYMENT D.G.E.T. NEW DE LHI AND THE COURSES RUN BY THE SOCIETY ARE AS PER THE CENTRAL GOVERNMENT PROGR AMME. 9 7. AFTER GOING THROUGH THE WRITTEN REPLY DATED 11.0 6.2010 FILED BY THE ASSESSEE BEFORE THE LD. CIT-I AS WELL AS THE MEMORANDUM OF A SSESSEES SOCIETY ALONGWITH BOOKS OF ACCOUNTS BILLS AND VOUCHERS FOR THE PERIO D UNDER CONSIDERATION WE ARE OF THE CONSIDERED OPINION THAT THE LD. CIT-I HAS NOT A PPRECIATED THE EVIDENCES FILED BY THE ASSESSEE SOCIETY WHILE REJECTING THE APPLICATIO N DATED 17.12.2009 FOR REGISTRATION OF THE ASSESSEE SOCIETY UNDER SECTION 12AA OF THE ACT. KEEPING IN VIEW OF THE OBJECTS AND THE ACTIVITIES OF RUNNING I NSTITUTION BY THE ASSESSEE SOCIETY IN A VERY SMALL VILLAGE NAMELY ALABAL WHICH IS RECO GNISED BY THE DIRECTOR GENERAL DIRECTORATE OF TRAINING & EMPLOYMENT D.G.E.T. NEW DELHI AND PROVIDING EDUCATION TO THE PEOPLE OF SMALL VILLAGES WHICH IS SITUATED IN REMOTE AREA FROM MATHURA (U.P.) WE ARE OF THE CONSIDERED OPINION TH AT THE ASSESSEE SOCIETY IS GENUINE AND ALSO DOING GENUINE AND CHARITABLE ACTIV ITIES WITHOUT THE AIM OF ANY PROFIT. 8. THE ASSESSEE SOCIETY HAS ESTABLISHED EDUCATION I NSTITUTION FOR PROVIDING TECHNICAL EDUCATION TO ALL THE RURAL AND URBAN PEOP LE IN SMALL VILLAGE OF ALABAL FOR CHARITABLE PURPOSE AND NOT FOR ANY TRADE COMMISSIO N OR BUSINESS. THEREFORE THE ASSESSEE TRUST IS IMPARTING EDUCATION BY PROVIDING VOCATIONAL EDUCATION TO THE POOR PEOPLE ESPECIALLY VILLAGERS. THUS WE HOLD THAT TH E ASSESSEE SOCIETY HAS BEEN ESTABLISHED FOR CHARITABLE PURPOSES AND HAS BEEN CA RRIED OUT CHARTABLE ACTIVITIES AND ENTITLED FOR REGISTRATION UNDER SECTION 12AA OF THE ACT. THE LD. CIT-I AGRA HAS 10 PASSED THE IMPUGNED ORDER ON THE BASIS OF DECISIONS MENTIONED IN THE IMPUGNED ORDER WHICH ARE ENTIRELY DIFFERENT FROM THE FACTS O F THE PRESENT CASE AND THEREFORE THE SAME ARE NOT APPLICABLE. SIMILARLY THE DECISI ONS CITED BY THE LD. COUNSEL FOR THE ASSESSEE ARE ALSO NOT HELPFUL TO THE ASSESSEE S OCIETY AND THEREFORE WE ARE NOT COMMENTING UPON THE SAME. 9. KEEPING IN VIEW OF THE AFORESAID DISCUSSIONS AND THE FACTS AND CIRCUMSTANCES EXPLAINED ABOVE WE ARE OF THE CONSIDERED OPINION T HAT THE IMPUGNED ORDER PASSED BY THE LD. CIT-1 DESERVES TO BE CANCELLED. WE CANC EL THE SAME WITH DIRECTION TO THE LD. CIT-I TO GRANT REGISTRATION TO THE ASSESSEE SOCIETY W.E.F. 01.04.2009. 10. IN THE RESULT APPEAL FILED BY THE ASSESSEE IS ALLOWED. SD/- SD/- (K.G. BANSAL) (H.S. SIDHU) ACCOUNTANT MEMBER JUDICIAL MEMBER PLACE: AGRA DATE: 19 TH SEPTEMBER 2011 PBN/* COPY OF THE ORDER FORWARDED TO: APPELLANT/RESPONDENT/CIT CONCERNED/CIT(APPEALS) CO NCERNED/D.R. ITAT AGRA BENCH AGRA/GUARD FILE. BY ORDER ASSISTANT REGISTRAR INCOME-TAX APPELLATE TRIBUNAL AGRA TRUE COPY