Madras High Court
The Commissioner Of Income vs Midas Golden Distelleries P on 25 August, 2021
TCA.No.97 of 2015
In the High Court of Judicature at Madras
Dated : 25.8.2021
Coram
The Honourable Mr.Justice T.S.SIVAGNANAM
and
The Honourable Mr.Justice SATHI KUMAR SUKUMARA KURUP
Tax Case Appeal No.97 of 2015
The Commissioner of Income
Tax, Central II, Chennai ...Appellant
Vs
Midas Golden Distelleries P.
Ltd., Kancheepuram District ...Respondent
APPEAL under Section 260A of the Income Tax Act, 1961 against
the order dated 30.6.2009 passed in ITA.No.1801/Mds/2008 on the file
of the Income Tax Appellate Tribunal, Chennai 'C' Bench for the
assessment year 2003-04.
For Appellant: Mr.T.R.Senthilkumar, SSC
assisted by Ms.K.G.Usharani, JSC
For Respondent : Served and No appearance
Judgment was delivered by T.S.SIVAGNANAM,J
We have elaborately heard Mr.T.R.Senthilkumar, learned Senior
Standing Counsel appearing for the appellant – Revenue. None
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appears for the respondent though the respondent is served and their
name is printed in the cause list.
2. This appeal by the Revenue under Section 260A of the Income
Tax Act, 1961 (for short, the Act) is directed against the order dated
30.6.2009 passed in ITA.No.1801/Mds/2008 on the file of the Income
Tax Appellate Tribunal, Chennai 'C' Bench (for brevity, the Tribunal) for
the assessment year 2003-04.
3. The appeal was admitted on 16.3.2015 on the following
substantial questions of law :
“1. Whether the ITAT is right in law in
reversing the order of the CIT(A) which
confirmed the addition under Section 68?
2. Whether, in view of the facts and
circumstances, the ITAT has correctly applied
the judgment of the Hon'ble Supreme Court in
the case of CIT Vs. Lovely Exports P. Ltd. [216
CTR 195] and
3. Whether the ITAT has erred in law in
its finding that the Assessing Authority had not
brought any evidence or positive material to
indicate that the share application money as
such represented assessee's own undisclosed
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money brought back in the garb of share
capital and thereby the ITAT failed to apply the
settled position of law that the onus is only on
the assessee to establish the genuineness of
the credits ?”
4. The respondent - assessee is a private limited company
engaged in the business of manufacture of Indian Made Foreign Liquor
(IMFL). A search was conducted under Section 132 of the Act in the
business premises and the factory and the residential premises of the
directors of the assessee. Consequent upon the search operations,
proceedings under Section 153A of the Act were initiated by issuing a
notice on 19.6.2006. The assessee filed their return of income for the
assessment years from 2003-04 to 2005-06. In the letter
accompanying the return of income for the assessment year 2003-04,
the assessee stated that the assessee company came into existence
during the period relevant to the assessment year 2003-04. The
assessee admitted the same income, which was returned in the regular
return filed by them.
5. The Assessing Officer issued the notice under Section 143(2)
of the Act on various dates and the case was discussed with the
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authorized representative of the assessee for 21 hearings. During the
course of assessment proceedings, the company's directors, the
promoter – director, the former managing director and the vice
president were summoned under Section 131 of the Act and
statements were recorded from them. Apart from these persons, the
employees of the assessee company also appeared during the hearing
and the authorized representative of the assessee was permitted to
inspect the seized documents.
6. After considering the statements, which were recorded, the
seized documents and the submissions made on behalf of the
assessee, the assessment was completed by the Assessing Officer by
order dated 27.12.2007.
7. The Assessing Officer held that the enquiry with the past and
the present directors would show that there was no transparency in
the control and administration and even about the ownership of the
company; that the share capital has been introduced in the company
through two intermediary companies, which operated with the same
pseudonymous address and there was no business activity in those
companies; that the directors of the intermediary companies pleaded
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ignorance about the decision regarding the investment in the assessee
company; that the sources of the shareholders, who made their
investment in the assessee company through the intermediary
companies were not properly explained; that the affairs of the two
intermediary companies established the fact that those were only
paper companies created with the sole intention to act as a conduit for
facilitating transfer of funds; that the signatories to the agreement
were between the assessee and another company, as per which, the
shares of the assessee were to be allotted to the other company or its
nominees in lieu of the alleged advance of Rs.5.35 Crores, totally
denied by stating that he did not have knowledge of such transaction
and that transaction was not reflected by the erstwhile partnership firm
M/s.Golden Distilleries; that the addresses of the share applicants
namely M/s.D.Kumar Trading and Co., and M/s.Pooja Equitex and
M/s.Pentium were not furnished.
8. Thus, the Assessing Officer concluded that the share
application money was not property explained to his satisfaction and
that the same had to be assessed in the hands of the assessee
company. The Assessing Officer appeared to have come to the above
provisional conclusion and afforded an opportunity to the assessee to
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make their submissions as to what, according to them, was the
provisional conclusion.
9. The authorized representative of the assessee argued that the
amounts were received by the assessee only through cheques and the
names and addresses of the shareholders had been furnished.
Therefore, they contended that they discharged the onus cast upon
them. A written submission to the said effect was filed on 03.12.2007
by the authorized representative of the assessee company.
10. The assessee company further contended that they received
share capital of Rs.13.95 crores from various persons through cheques
or demand drafts and that the list of persons, from whom, the share
application money was received, was furnished to the Assessing
Officer. It was also contended that that the assessee allotted shares to
the applicants and filed necessary documents with the Registrar of
Companies in proof of such allotment. Further, the allotment had been
made on the basis of a valuation made by independent and reputed
professional.
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11. Placing reliance on the decision of the Hon'ble Supreme
Court in the case of CIT Vs. Stellar Investments Ltd. [reported in
(1991) 192 ITR 287], it was contended by the assessee that on
account of the factual situation, the amount of share application
money could not be regarded as undisclosed income in the hands of
the assessee.
12. This argument of the assessee was considered by the
Assessing Officer and it was pointed out that merely filing the identity
of the shareholders or the share applicants and the mode of receipt of
amounts would not amount to discharging onus cast upon the
assessee. It was further pointed out that when a doubt arose as to the
genuineness of the share capital introduced by the assessee, it would
be necessary to examine the facts and circumstances of the entire
issue to find out as to whether the amounts shown as representing the
share application were genuine and also to ascertain the capacity of
the share applicants.
13. Thus, the Assessing Officer held that if, on the facts and
circumstances, the Assessing Officer came to the conclusion that the
share capital of a company was in question, the Assessing Officer was
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at liberty to make an enquiry and if the enquiry proved that the
transactions were not genuine, he could treat the amount as income of
the assessee.
14. With regard the argument of the assessee that the share
application money had been received by cheque/demand draft, the
Assessing Officer relied upon the decision of the Gauhati High Court in
the case of Nemi Chand Kothari Vs. CIT [reported in (2003) 264
ITR 254] and held that merely because the amounts were received by
cheques, it could not make the transaction sacrosanct and that the
assessee was bound to prove the identity of the creditors, the
genuineness of the transactions, which they had with the creditors and
the creditworthiness of their creditors vis-a-vis the transactions, which
they had with the creditors and only then, the burden stood
discharged.
15. With regard to the decision of the Hon'ble Supreme Court
relied upon by the assessee in the case of Stellar Investments Ltd.,
the Assessing Officer held that no ratio decidendi was laid down in that
decision and it could not be applied to the facts of the assessee's case.
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16. With regard to the power of the Assessing Officer to make
enquiry about the nature and source of amounts credited under share
application money, the Assessing Officer relied upon the decision of the
Delhi High Court in the case of CIT Vs. Sophia Finance Ltd.
[reported in (1994) 205 ITR 98] and observed that the Assessing
Officer was not precluded from making any enquiry with regard to the
share capital. To the same effect, reliance was placed on the decisions
of the Calcutta High Court in the case of Hindustan Tea Trading Co.
Ltd. Vs. CIT [reported in (2003) 263 ITR 289] and in the case of
CIT Vs. Ruby Traders and Exporters Ltd. [reported in (2003)
263 ITR 300].
17. Further, by placing reliance on the decision of the Hon'ble
Supreme Court in the case of Juggilal Kamalapet Vs. CIT [reported
in (1969) 73 ITR 702], the Assessing Officer held that he was
entitled to pierce the veil of a corporated entity and look at the reality
of the transaction. To the same effect, reliance was placed on the
decision of the Hon'ble Supreme Court in the case of CIT Vs. Sri
Meenakshi Mills Ltd. [reported in (1967) 63 ITR 609] and the
decision of the Kerala High Court in the case of CIT Vs. Paulose and
Mathen Pvt. Ltd [reported in (1999) 236 ITR 416].
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18. Further, the Assessing Officer held that a tax payer could not
be allowed to get away with any colourable device or artificial sham
transaction and to that effect, placed reliance on the decision of the
Hon'ble Supreme Court in the case of McDowell & Co. Vs. CTO
[reported in (1985) 154 ITR 148].
19. Reverting to the facts, the Assessing Officer observed that
the share capital had been routed through two companies, the
existence and operation of which remained only on paper and that the
enquiries, which were conducted, were not only to lift the corporate
veil of the assessee company, but also that of the intermediary
companies, which acted as conduits. Further, based on the enquiry, the
Assessing Officer recorded that it revealed that huge amounts were
brought in the assessee's books as share application money through
the intermediary companies by the shareholders, who could not
properly explain their source.
20. Therefore, the Assessing Officer held that the provisions of
Section 68 of the Act got attracted and that the share application
money, which was not explained, had to be assessed in the hands of
the assessee company. Reliance was placed on the decision of the
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Hon'ble Supreme Court in the case of Sumati Dayal Vs. CIT
[reported in (1995) 214 ITR 801] wherein it was held that
apparent could not be considered as real and that when there was no
reason to believe that the apparent was not real, the Taxing Authorities
were entitled to look into the surrounding circumstances to find out the
reality and the matter had to be considered as per such a finding.
Accordingly, the entire share application money amounting to
Rs.13,94,15,000/- was brought to tax by the assessment order dated
27.12.2007.
21. Aggrieved by such an order, the assessee filed an appeal
before the Commissioner of Income Tax (Appeals)-I, Chennai-34 [for
brevity, the CIT(A)], who, by a very detailed and reasoned order dated
21.7.2008, dismissed the appeal by confirming the assessment order.
22. As against the same, the assessee preferred further appeal
to the Tribunal, which was allowed by the impugned order dated
30.6.2009. Thus, the Revenue is before us by way of this appeal.
23. Though the impugned order passed by the Tribunal, at the
first blush, appears to be a very elaborate and detailed order, we find
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that the discussion is only in paragraph 30. From paragraphs 31 to 40,
the Tribunal referred to various decisions of the Hon'ble Supreme Court
not on the subject issue, but on the issue as to when an order passed
by the Hon'ble Supreme Court is a law declared by the Court under
Article 141 of The Constitution of India. To say the least, we find that
the order passed by the Tribunal to be utterly perverse and devoid of
reasons and there was no discussion as to how the Assessing Officer
was factually incorrect and as to how the CIT(A) was not right in
confirming the order passed by the Assessing Officer.
24. The CIT(A), while confirming the order passed by the
Assessing Officer, reexamined the entire facts and the discussions
commenced from paragraph 4.1.3 in the order dated 21.7.2008. After
noting the submissions, which were recorded by the Assessing Officer
during the course of assessment proceedings, the CIT(A) held that the
so-called directors basically discharged their functions in the honorary
capacity during their tenure and they used to look after the routine
matters pertaining to the assessee and that they categorically denied
having every actively participated in the crucial decision making
process of the assessee company. As former managing director of the
assessee company, he was stated to be in charge of civil work,
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erection of plant and machinery, purchases, etc., and expressed
ignorance about the shareholding pattern of the assessee company
and other financial transaction entered into by the initial promoter –
directors and the present directors. All of them appeared to have
stated that the important decisions used to be taken by only one
person, who was the main person behind the promotion of the
assessee company and its business operations. But, the main person
pleaded that he and his family members had no role to play in the
assessee's business activities apart from holding shares therein.
25. After noting the statements recorded by the Assessing
Officer, the CIT(A) observed that the Assessing Officer was within his
right to probe the genuineness and source of the share application
money received by the assessee during the year. The statements
recorded from the persons had clearly established that the needle of
suspicion inevitably and inexorably pointed to one particular person
and since the suspicion was so overwhelming, the Assessing Officer
had no other option except to trace the origin of funds, which got
channelized into the assessee company through the corporate entities.
Further, the CIT(A) pointed out that the Assessing Officer, while
embarking upon such an enquiry, found that the share application
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money was primarily contributed by two companies and an aggregate
sum of Rs.3 Crores was found to be contributed by three Mumbai
based companies.
26. During the course of enquiry, the Assessing Officer was able
to establish that two persons, who were common directors in the two
companies and who were alleged to have contributed, had no social
standing or any financial capacity to bring in such amount of monies as
share application monies. The statements revealed that those two
persons acted as puppets under the instructions of a single person. It
was also found that the two companies had, in turn, collected funds
from other parties and the family members of the said single person
and they were subsequently transferred to the assessee company by
way of share application money.
27. Thus, the CIT(A) agreed with the conclusion arrived at by the
Assessing Officer and held that there was no other option left except to
treat the source of the aggregate funds brought in by the companies
as unexplained. Likewise, the genuineness of other transactions were
also examined and the CIT(A) agreed with the Assessing Officer that
the alleged investments remained unexplained and the
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creditworthiness of two ladies, who were stated to have invested a
sum of Rs.30 lakhs was not established. Therefore, the CIT(A) agreed
with the findings rendered by the Assessing Officer that the source of
entire share application money remained unexplained thereby
attracting the provisions of Section 68 of the Act.
28. Before the CIT(A), the assessee placed reliance on the
decision of the Hon'ble Supreme Court in the case of Stellar
Investments Ltd., and distinguished that decision on facts and
contended that the special leave petition filed before the Hon'ble
Supreme Court was summarily dismissed and it was not by a speaking
order. Thereafter, the CIT(A) proceeded to refer to several decisions
including the decision of the Delhi High Court in the case of CIT Vs.
M/s.Lovely Exports Pvt. Ltd. [reported in (2008) 299 ITR 268],
which was referred to by the Tribunal and which, according to the
Tribunal, stood confirmed before the special leave petition was
dismissed. After noting the decisions, the CIT(A) held that the
Assessing Officer was entitled to conduct a full-fledged enquiry for
ascertaining the true nature and source of any credit appearing in the
books of accounts of the assessee and also brought out on facts as to
how the creditworthiness of the persons, who were said have brought
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in the share application money was not established and accordingly
confirmed the assessment order.
29. As mentioned above, the Tribunal reversed the order passed
by the Assessing Officer as confirmed by the CIT(A) by observing that
despite all material being available with the Assessing Officer and
discreet enquiries were made as within the scope of his powers, the
Assessing Officer has not brought in positive material or evidence to
indicate that the share application money as such represented
assessee's own undisclosed money brought back in the garb of share
capital.
30. Unfortunately, the Tribunal did not take note of the elaborate
exercise done by the Assessing Officer and the various statements,
which have been recorded in a well reasoned order running to 44
pages. The Tribunal, in a single line, held that the Assessing Officer
had not brought in any positive material or evidence. This finding is
wholly erroneous and contrary to the facts, as the Assessing Officer
clearly brought out as to how the so-called investors were either shell
companies or without any financial capacity to bring in such monies for
the purpose of investment and all fingers pointed to one individual.
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These facts were re-appreciated by the CIT(A), who had concurred
with the Assessing Officer.
31. Section 68 of the Act states that where any sum is found
credited in the books of an assessee maintained for any previous year,
and the assessee offers no explanation about the nature and source
thereof or the explanation offered by him is not, in the opinion of the
Assessing Officer, satisfactory, the sum so credited may be charged to
income-tax as the income of theassessee of that previous year.
32. In terms of Section 68 of the Act, the assessee is bound to
explain as to how the nature and source of the amounts found credited
in their books. If the assessee offers an explanation, which, in the
opinion of the Assessing Officer, is not satisfactory, the said sums
found credited in the books of accounts of the assessee may be
charged to income tax as the income of the assessee.
33. Therefore, the onus is on the assessee to establish the
creditworthiness of various persons and as to how the share
application money was brought in. Therefore, furnishing the list of
names or stating that the monies were paid by cheques will not, by
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itself, establish the creditworthiness and genuineness of the
transaction. The initial onus is on the assessee to discharge the burden
cast upon them to prove the creditworthiness and genuineness of the
transaction.
34. On going through the factual position as recorded by the
Assessing Officer and re-appreciated by the CIT(A), we have no
hesitation to hold that the assessee has not established the
creditworthiness and genuineness of the transaction to the satisfaction
of the Assessing Officer. In fact, the Tribunal agreed that the Assessing
Officer made an in-depth enquiry, which was well within his powers.
Yet, by a cryptic order, the Tribunal reversed the well considered order
passed by both the Assessing Officer as well as the CIT(A).
35. The decision in the case of M/s.Lovely Exports Pvt. Ltd.,
can hardly help the case of the assessee because, on facts, in the said
case, it was found that the assessee furnished full information thereby
discharging the onus cast upon them and once the onus is discharged,
it was for the Assessing Officer, who has to prove the contrary.
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36. In the case on hand, the assessee miserably failed to
discharge the primary onus cast upon them. In fact, the Assessing
Officer conducted a detailed enquiry, issued summons, recorded
statements, permitted the authorized representative of the assessee to
peruse the seized records and in fact, came to a provisional conclusion
as to how he intends to proceed and gave further opportunity to the
authorized representative of the assessee, who had filed a written
submission on 03.12.2007 raising certain factual issues and relying
upon certain decisions. Those factual issues were considered and held
to be not sustainable and the decisions, which were relied upon by the
assessee, were also distinguished and in our considered view, are
rightly so.
37. The case of the Revenue stands substantiated and supported
by the decision of the Delhi High Court in the case of PCIT Vs. NDR
Promoters P. Ltd. [reported in (2019) 102 Taxmann.com 182]
wherein it has been held that when the Assessing Officer made
additions to the assessee's income under Section 68 of the Act in
respect of the amounts received as share capital from several
companies, which was, in fact, maintained by one person, the
additions were held to be justified. The special leave petition filed
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against this decision was dismissed by the Hon'ble Supreme Court in
the decision reported in NDR Promoters P. Ltd. Vs. PCIT [reported
in (2019) 109 Taxmann.com 53].
38. In the decision of this Court in the case of B.R.Petrochem
P. Ltd. Vs. ITO, Ward I(1), Chennai [reported in (2017) 81
Taxmann.com 424], it was held that where assessee received share
capital from various contributors, in view of fact that those contributors
were persons of insignificant means and their creditworthiness to have
made contributions had not been established, impugned addition made
by authorities below in respect of amount in question under Section 68
was to be confirmed.
39. In the decision of a Division Bench of this Court, to which,
one of us (TSSJ) was a party, in the case of PCIT Vs. M/s.SRM
Systems and Software P. Ltd. [TCA.No.875 of 2018 dated
17.2.2021], more or less an identical issue was considered and after
taking note of the provisions of Section 68 of the Act, it was held as
follows :
“8. In terms of the above provision, if
the assessee offers no explanation about the
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nature and source of the amounts found
credited in their books or the explanation
offered by the assessee is not in the opinion of
the Assessing Officer, satisfactory, the same so
credited, may be charged to income tax, as the
income of the assessee of that previous year.
Therefore, to establish, the assessee was
required to produce the creditworthiness of
various persons, who are said to have made
the share capital advance. Therefore, what is
required to be established is the identity of the
person, who has made the share capital
advance, his creditworthiness and genuineness
of the transaction. The onus is on the assessee
to establish these factors and mere furnishing
of the list of persons, who have claimed to
have advanced towards share capital, will not
constitute sufficient compliance of the onus
placed on the assessee.
9.The CIT(A) has brushed aside the
remand report submitted by the Assessing
Officer, which would clearly indicate that the
assessee failed to establish the genuineness of
the amounts received as advance towards
share capital. The CIT(A) has made an
observation that the assessee has produced
Form No.2, which is under under the
provisions of the Companies Act and as rightly
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submitted by the learned Senior Standing
Counsel, the same will not contain the PAN
numbers of the persons, who are said to have
advanced monies.
10.In Principal Commissioner of
Income Tax, Central I vs. NRA Iron &
Steel Pvt. Ltd., [(2019) 103 taxmann.com
48 (SC)], the issue, which fell for
consideration, was whether the share
capital/premium credited in the books of
accounts of the assessee-company, the onus
of proof is on the assessee to establish by
cogent and reliable evidence of the identity of
the investor companies, the creditworthiness
of the investors and genuineness of the
transaction to the satisfaction of the Assessing
Officer. While answering the said issue, the
Hon'ble Supreme Court held that it is for the
assessee to prove by cogent and credible
evidence that the investments made in share
capital are genuine borrowings, since the facts
are exclusively within the assessee's
knowledge. After referring to several
decisions, the principles, which emerged there
from, were summed up in paragraph 11 of the
judgment on the following terms:-
“11. The principles which emerge where
sums of money are credited as Share
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Capital/Premium are :
i. The assessee is under a legal
obligation to prove the genuineness of the
transaction, the identity of the creditors, and
credit-worthiness of the investors who should
have the financial capacity to make the
investment in question, to the satisfaction of
the AO, so as to discharge the primary onus.
ii. The Assessing Officer is duty bound to
investigate the credit-worthiness of the
creditor/ subscriber, verify the identity of the
subscribers, and ascertain whether the
transaction is genuine, or these are bogus
entries of name-lenders.
iii. If the enquiries and investigations
reveal that the identity of the creditors to be
dubious or doubtful, or lack credit-worthiness,
then the genuineness of the transaction would
not be established. In such a case, the
assessee would not have discharged the
primary onus contemplated by Section 68 of
the Act.
11.The Review application filed against
the above decision was dismissed by a
speaking order as reported in (2020) 117
taxmann.com 752 (SC). 12.From the facts
of the case, which we have set out in the
preceding paragraphs, it is clear that the
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assessee has not discharged the legal
obligation cast upon them to prove the
genuineness of the transaction, the identity of
the creditors and creditworthiness of the
investors, who should have the financial
capacity to make the investment in question to
the satisfaction of the Assessing Officer so as
to discharge the primary onus. Since the
assessee did not discharge the primary onus
cast upon them, the question of the Assessing
Officer to investigate the creditworthiness of
the creditors/subscribers would not arise in the
case on hand. Therefore, the above decision is
a clear answer to the assessee's case, which
would necessitate us to decide the same in
favour of the Revenue.
13.We may also refer to the decision of
the High Court of Calcutta in
J.J.Development Private Ltd., vs. CIT,
Calcutta IV [(2018) 100 taxmann.com
101 (Cal.)] wherein, it was held that when
there was no plausible explanation that was
furnished by the assessee to discharge the
onus cast upon them and the identities of the
alleged share applicants having not been
established and the documents of the alleged
share applicants carried by the assessee
before the Assessing Officer did not reveal the
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investments that the assessee claimed such
alleged applicants had made in the assessee,
there was no reason to interfere with the order
of the Assessing Officer. The Special Leave
Petition filed by the assessee therein was
dismissed by the Hon'ble Supreme Court in the
taxmann.com 102.
14.In the decisions referred to by
Ms.G.Baskar in the case of CIT vs. Gopi
Textiles Ltd., [(2007) 294 ITR 663
(Madras)] and the decision of the Hon'ble
Supreme Court in CIT vs. Lovely Exports
(P.) Ltd., [(2008) 216 CTR 195 (SC)], the
stand taken by the assessee was accepted as
the Court found that the assessee had
furnished full information thereby discharging
the onus cast upon him and once the onus is
discharged by the assessee, it is for the
Assessing Officer, who has to prove the
contrary. In the case on hand, we find that
the initial onus, which has been cast on the
assessee has not be discharged by them.
Reference to a statutory form prescribed under
the Companies Act is of little avail, as it does
not reveal the PAN numbers of the alleged
investors.
15.In the light of the above facts, we
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have no hesitation to conclude that the
Tribunal erred in confirming the order passed
by the CIT(A) by observing that merely
because the share applicants are from Andhra
Pradesh that cannot be a reason to disallow
the claim of the assessee. The factual position
being, the Assessing Officer did not do so, but
disallowed the same on the ground that the
assessee has not furnished any details, viz.,
the names and addresses of the persons, who
paid the share capital advances, the cheque
numbers, the name of the bank, PAN numbers
etc. Thus, the order passed by the Tribunal
calls for interference.”
40. For the above reasons, we have no hesitation to hold that
the impugned order passed by the Tribunal calls for interference.
41. In the result, the above tax case appeal is allowed, the
impugned order passed by the Tribunal is set aside and the order
passed by the Assessing Officer dated 27.12.2007 as confirmed by the
CIT(A) is restored. The substantial questions of law framed are
answered in favour of the Revenue.
RS 25.8.2021
https://www.mhc.tn.gov.in/judis/
TCA.No.97 of 2015
T.S.SIVAGNANAM,J
AND
SATHI KUMAR SUKUMARA KURUP,J
RS
To
The Income Tax Appellate Tribunal, Chennai 'C' Bench
TCA.No.97 of 2015
25.8.2021
https://www.mhc.tn.gov.in/judis/
