A G M Properties Private Limited vs ITO, Ward 1 (1)

“1.

On facts and circumstances of the case, the authorities below have erred in upholding the assessment proceedings ignoring the fact that assessment is invalid and without jurisdiction as thesaid assessment is completed without complyingwith legal requirements of the provisions of section 153A of the Income Tax Act therefore such assessment is void ab initio and liable to be quashed.

2.

On the facts and circumstances of the case, the authorities have erred in law in upholding the assessment being invalid in law as the same has been passed after taking approval u/s 153D of the Act granted without application of mind by the Joint Commissioner of Income Tax through a common communication dated vide F No. JCITICR-4/Approva1/153D/2017-18/1132 dated 29.12.2017 in the appellants case.

3.

On the facts and circumstances of the case, the authorities have erred in law in upholding the addition of Rs.27,07,90,000/-u/s 68 of IT Act on protective basis without having anycorroborative evidence allegedly treating the appellant as conduit company.

4.

On the facts and circumstances of the case, the authorities have erred in law in upholding the addition of Rs.27,07,90,000/-u/s 68 of IT Act on protective basis without providing any evidence whether substantive addition has been made in hands of beneficiary.

5.

On the facts and circumstances of the case, the authorities have erred in law in upholding the addition ofRs.l,02,23,800/- on protective basis treating the alleged commission received in providing entries to beneficiaries without bringing any corroborative evidence on record and without providing any evidence whether substantive addition has been made in hands of beneficiary.”

“Ground No 1 On the validity of the assessment u/s 153A and the addition made thereby without bringing on record any incriminating material found in the course of the search.

The search in the present case was on 16.09.2015 and therefore the assessment was unabatedin accordance with the second proviso to section 153A of the Act. It is a settled proposition of law that in case of unabated assessment u/s 153A of the Act, addition cannot be made dehors any incriminatingmaterial found in the search on the assessee.

Coming to the facts of the case, apanchnama was drawn by the search team at the conclusion of the search in the presence of the witnesses. The perusal of the panchnama will reveal that no cash, valuables and books of account or documents were seized in the course of the search in question. Bethat as it may question o nay material sized does not arise what to speak of any incriminating material found in the said search. The Ld CIT(A) has taken note of the above contention of the appellant in para 8 of the appellate order and in para 8.02 of the above order where he does not dispute that fact that thepanchnama does not evidence seizure of books of account or documents. The Ld CIT(A) relying on the remand report of the LdAO inpara 10.1 of the appellate order too the view that the statement of Sh Nem Chand Gupta recorded on 26.11.2015 (post completion of search was the incriminating material considered to the material found in the course of search to justify addition based on that statement.

Your Honor’s kind attention is invited to the appellant’s own case for AY 2013-14 in ITA No 305/Del/19 dated 19.07.2022, the relevance of the statement of the above-named person was highlighted to justify addition u/s 153A inpara 6.2 page 6 of the said order. The Hon’ble Bench held in the identical facts and circumstances vide finding in para 7.1 (page 7), that, taking into account the observation of Ld CIT(A) in para 6 of his order that the panchnama does not depict any seizures, and in the absence of any incriminating material unearthed during search, no addition u/s 153A could be made to the income already assessed.

The appellant, supporting the above proposition of law, seeks to place reliance on the following authorities:

1.

CIT Vs M/s Abhisar Buildwell PLtd 454 ITR 212(SC);

2.

CIT Vs Kabul Chawla 380 ITR 573(Del);

3.

PCIT Vs SaumyaConstruction Pvt Ltd 387 ITR 529(Guj);

4.

PCIT Vs Meeta Gutgutia 395 ITR 526(Del);

On identical facts which exist in present case, the Hon’ble ITAT in the case of ACIT vs Nirmal KumarSarda2026 (7) TMI 684-ITAT Delhi has quashed the assessment order relying on CIT Vs M/s Abhisar Buildwell P Ltd (supra).

Coming to the utility of the statement recorded u/e 132(4) of the Act,it is a settled law in view of the decisions of PCIT Vs Anand Kumar Jain (HUF)432 ITR 384 (Del) where reliance is placed on CIT Vs Best Infrastructure (India) P Ltd 397 ITR 82 and CIT Vs Harjeev Aggarwal 290CTR 263(Del), that it is not incriminating material on a stand-alone basis unless such statement is with reference to any other material discovered during search and seizure operation. The statement sought to be relied upon by the Department is the one recorded during the post-search enquiry, as the above deponent was not available at the time of the search and his statement was recorded late on. Kindly refer to para 3, page 5 of the assessment order. Therefore, without prejudice, it is not the case of the Department that the statement in question, u/s 132(4), was recorded during the search tocharacterize the same as the material fund during the search action.

Ground No.2: Mechanical approval u/s 153D of the Act

The respondent has raised this additional ground of cross objection supporting the order of Ld CIT(A) on the ground that the approval u/s 153D was mechanical and without application of mind. From the assessment orders for AY 2011-12to AY 2016-17, it can be noticed that the approval has been granted by the JCIT through common communication i.e. F No. JCIT/CR-4/Approval/153D/2017-18/1132 dated 29.12.2017. The approval provided through communication has been found to be mechanical and without application of mind by the jurisdictional Hon’ble Allahabad High Court in the case of PCIT vsSapna Gupta2022 SCC Online ALL 1294. The above decision has been duly considered in the latest decision of Hon’ble Delhi High Court in the case of Pr CIT vs Shiv Kumar Nayyar ITA No.285/2024 dated 15.05.2024 in which various decision on this issue including Pr CIT vs Anuj Bansal ITA 368/2023 (Del) dated 13.07.2023, Sapna Gupta (Supra) and ACIT vs Serajuddin& Co 223 SCC Online Ori 992 have been cited/followed. Incidentally, it needs be appreciated that decision in the case of Serajuddin (supra) has been approved by Hon’ble Apex Court in the order dated 28.11.2023 whereby the department appeal was dismissed.

Ground Nos.3 and 4:Applicability of section 68 of the Act on addition of Rs.27,07,90,000/-

The facts on record show that the authorities below have dealt with the addition u/s 68 of the Act on a protective basis treating as unexplained cash credits the investments of Rs 26,40,20,250/- in the form of share capital of Rs 72,69,750/- with share premium to over 48 parties. The above investments are shown by the appellant on the assets side of the balance sheet. The above amounts appearing as assets in the balance sheet of the appellant company are the outcome of debits of these amounts as per the books of account of the appellant company. In the absence of any credit entries of these amounts not appearing in the books of account of the appellant company, the authorities below are not justified in invoking section 68 of the Act. Section 68 can only be invoked when there are credit entries in the books of account the nature and source of which the assessee fails to explain to the satisfaction of the assessing authority. In the present case no credits in the books of account of the above amounts have been found by the Ld AO or by the Ld CIT(A) in the present case. Since n no credits in the books of account were found by the authorities below, the jurisdictional requirement for invoking section 68 is not satisfied, and accordingly the addition under the above section does not survive. Reliance is placed on the decision of the Hon’ble Delhi High Court in the case of CIT Vs Usha Stud Agricultural Farm Ltd.301 ITR 384 (Del).

Justification of protective addition in the hands of the appellant company.

For making protective additions in the hands of the appellant company, the Department has also taken a view that the appellant is treated as a conduit company for channeling funds to beneficiary companies. In view of these facts, the substantive addition is to be made in the hands of the beneficiary companies numbering 48, only 3 or 4 of them identified, but the composition of the substantive income to be added in the hands of each entity wasstill not identified, which shows that part of the action is pending. Having regard to the above facts theld CIT(A) has erred in confirming the protective assessment framed by the AO although no corresponding substantive assessment with respect to the impugned issue was made and existed in the case of so called beneficiary companies It was submitted that the said action is against the judicially established principle that there cannot be a protective assessment/addition without there being a substantive assessment/addition.

In this regard, reference is drawn to the decision of the Coordinate Mumbai Benches in the case of Suresh K. Jajoo Vs. ACIT 39 SOT 514, wherein, while dismissing the protective addition made in the hands of appellant, it was held that where there is no substantive assessment already made , there can be no protective assessment.

The aforesaid proposition has been followed in another Mumbai Benches decision in case of Pegasus Properties (P.) Ltd. Vs. DCIT reported in 193 ITD 514 (Mumbai - Trib.), wherein it was held as under:

"9.3

In the instant case before us, admittedly, no substantive addition of Rs. 13,86,600/-was made by the revenue either in the hands of M/s. Fisher Health Resorts (P.) Ltd or in the hands of any other person. In respectfully following the aforesaid decision, since no substantive addition was made, the protective addition made in the hands of the assessee company does not survive. "

The above two decisions have been followed in favour of the appellant by the Chandigarh Bench of Hon’ble ITAT in the case of M/s Vision Steel Ltd vs DCIT ITA No.685 to 687/Chd/2019 dated 16.02.2023.

Having regard to the foregoing facts, the action of AO in making a protective addition prior to making a substantive addition in any case, is arbitrary and bad in law. Thus, the impugned additions should be deleted on this ground alone.

Ground No.5 Merits of addition ofRs.1,02,23,800/- on protective basis

From the facts discussed on page 18, the Ld AO has made the addition on account of commission @ 2% of Rs.51,11,90,000/-consisting of the share capital and premium of Rs.27,07,90,000/-plus the so-called accommodation entry provided by the appellant Rs.24,04,00,000/-. The above protective addition is contested on the ground that the above addition like the other addition of Rs.27,07,90,000/- is dehors the incriminating material found in the search in support of which the submission has already been made and same are relied upon to contest the above addition also.

“7.

We have given our careful thought to the rival submissions and perused the material available on record. To recapitulate the facts, it is an admitted position that for AY 2013-14 the assessee had originally filed its return of income under section 139(1) of the Act on 15.11.2014 and assessment under section 143(1) of the Act was completed on 15.11.2013. The time limit for issuance of notice under section 143(2) of the Act was upto 30.09.2014 but not notice under section 143(2) of the Act was issued upto 30.09.2014. On expiry of the aforesaid period for issue of notice under section 143(2) of the Act, the assessment for AY 2013-14 is deemed to have been concluded. The search was conducted on 17.09.2015. On the date of search i.e. 17.09.2015 the assessment for the AY 2013-14 was not pending. Therefore, the acceptance of the return of income amounts to an assessment and such assessment did not abate in terms of the second proviso to section 153A( 1) of the Act. During the course of search no incriminating material whatsoever was found and seized. The Ld. CIT(A) himself observes in para 6 of appellate order that it is a fact that the punchnama does not depict any seizures.

7.1

In the background of the above factual matrix, the decision of Hon'ble Delhi High Court in CIT vs. Kabul Chawala 380 ITR 573 (Delhi) squarely applies to the facts of the assessee's case wherein their Lordships held that assessment under section 153A can be carried out only on the basis of seized material. Where no incriminating material was unearthed during the search, no additions could be made to the income already assessed. The Hon'ble Delhi High Court in Kabul Chawala's case (supra) recorded in para 37 summary of the legal position as under :-

"37.

On a conspectus of Section 153A{1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under:

i.

Once a search takes place under Section 132 of the Act, notice under Section 153 A (1) will have to be mandatorily issued to the person searched requiring him to file returns for six A Ys immediately preceding the previous year relevant to the A Y in which the search takes place.

ii.

Assessments and reassessments pending on the date of the search shall abate. The total income for such A Ys will have to be computed by the AOs as a fresh exercise.

iii.

The AO will exercise normal assessment powers in respect of the six years previous to the relevant A Y in which the search takes place. The AO has the power to assess and reassess the 'total income' of the aforementioned six years in separate assessment orders for each of the six years. In other words there will be only one assessment order in respect of each of the six A Ys "in which both the disclosed and the undisclosed income would be brought to tax".

iv.

Although Section 153 A does not say that additions should be strictly made on the basis of evidence found in the course of the search, or other post-search material or information available with the AO which can be related to the evidence found, it does not mean that the assessment "can be arbitrary or made without any relevance or nexus with the seized material. Obviously an assessment has to be made under this Section only on the basis of seized material."

v.

In absence of any incriminating material, the completed assessment can be reiterated and the abated assessment or reassessment can be made. The word 'assess' in Section 153 A is relatable to abated proceedings (i.e. those pending on the date of search) and the word 'reassess' to completed assessment proceedings.

vi.

Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 15A merges into one. Only one assessment shall be made separately for each A Yon the basis of the findings of the search and any other material existing or brought on the record of the AO.

vii.

Completed assessments can be interfered with by the AO while making the assessment under Section 153 A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment"

7.2

In their later decision in the case of Pro CIT and ors. vs. Meeta Gutgutia Prop. Ferns 'N' Patels and Ors. (2017) 395 ITR 526 (Delhi) the Hon'ble Delhi High Court reiterated with approval their observations in Kabul Chawala's case (supra) that completed assessments could be interfered with by AO while making assessment under section 153A only on basis of some incriminating material unearthed during course of search. If in relation to any assessment year, no incriminating material was found, no addition or disallowance could be made in relation to that assessment year in exercise of powers under section 153A and earlier assessment should have to be reiterated. This decision has been affirmed by the Hon’ble Supreme Court by dismissing the Revenue's SLP in PCIT vs. Meeta Gutgutia (2018) 96 taxmann.Com 468 (SC).

7.3

Accordingly, we hold that the assessment for AY 2013-14 was already completed prior to the date of search and having not abated, the scope of proceedings under section 153A of the Act had to be confined only to material found in the course of search. Since no material on the basis of which the impugned addition has been made was found in the course of search, the addition made by the Ld. AO in the order of the assessment could not have been subject matter of proceedings under section 153A of the Act. Consequently, impugned addition could not be made. The assessment order is held to be bad in law and is quashed.”

“Ground Nos.1 to 4 Invalid Assumption of reassessment proceedings u/s 147/148 of IT Act From the reasons reproduced in para 2 at page 2-3 of the assessment order,the Ld AO had information in his possession that the appellant company has madeinvestment of Rs.23,60,77,927/- in M/s Hare Krishna Garments P Ltd(“HKG”). As per the reason, the investment was in share capital of Rs.42,58,400/-, share premium of Rs.12,05,93,600/- and investment and deposits of Rs.11,12,25,927/-. If the above information compared with the balance sheet for relevant AY 2012-13 of above-named company i.e. HKG which is available on MCA portal, public domain, the information contained in said balance sheet as on 31.03.2012 show clear non-application of mind which fact is evident from following particulars emerging therefrom:

I. There is no increase in share capital/share premium in above named company from 01.04.2011 to 31.03.2012(Kindly refer note no.2.1 & 2.2).

II. The entire share capital/share premium which is carried over from preceding assessment year is attributed to be coming from appellant company mobilized during the relevant financial year whereas from list of share holders of more than 5% shares shows that the appellant company has brought forward shareholding of 28167 shares consisting of 6.61% shareholding meaning that the remaining 93.39% is held by other entities and those shareholding including appellant shareholding is coming from preceding assessment year.

III. In the asset side of above balance sheet, in item No.(i)(b), the net current assetsare shown to be at Rs.11,12,25,927/- as on 31.03.2012 (closing balance) as compared to Rs.11,11,50,000/- as on 31.03.2011 (opening balance). These balances represents investment in equity instruments by the said company namely HKG. But Ld AO while reopening the assessment has taken the investment in equities by said company to different other companies as investments made by the appellant company in the said HKG.

IV. From the information available in balance sheet of HKG, there is no investment received by the said company neither in the share capital nor in the share premium nor by any other means which fact is evident from liability side of balance sheet. The Ld AO has misapplied himself by assuming incorrectly that all the investments in share capital/share premium is during the year under consideration only and same is made by appellant company only.

V. Further, the Ld AO in sub-para 5 of reasons say that there is non-current investment of Rs.16,99,80,000/- of appellant company in other companies. The Ld AO says that since, details of such investment is not available, his unable to verify whether or not the investment by appellant in HKG is recorded therein. From the above material, it is evident that there is not only non-application of mind but is a case of misapplication/ miscarriage of facts arising from non-verification of facts, including those which were available in the public domain at the reopening. It is a case where Ld AO has taken cognizance of the information received from ITO, Ward 1(1), Delhi through email and has jumped upon in taking action of reopening without verifying the authenticity of information by referring to the records available at his end. It is a case where the prior assessment has been completed u/s 153A on 29.12.2017 and 148 on 28.12.2018. Since, that is the case, the entire evidences in form of bank statement/other details like books of account showing the transactions of appellant were available with him wherefrom the above information could have been cross checked by him.

Since, as per Ld AO was not able to verify the investment in the balance sheet shown under non-current investment of Rs.16,99,80,000/- there was all the more reason for him to verify either from the bank account of the appellant company which was available with as per assessment records or verify the same from the concern bank from where such investment was made.

It is therefore a case where reassessment proceedings has been initiated based on vague and self-contradictory information in that case, the Ld AO was required to conduct further enquiry to garner information to make information actionable to bring the supporting material which is not done in present case.

The Ld AO has not verified the facts to verify the correctness of information before triggering action u/s 147 of IT Act. The Hon’ble Delhi High Court in the case of Well Trans Logistics India Pvt. Ltd. Versus Addl. Commissioner of Income Tax & Ors 474 ITR 131 (Del) places emphasis on the duty of the AO to take further steps, make further enquiries and garner further material and if such material indicate that the income of the assessee has escaped assessment and then form a belief that the income of the assessee has escaped assessment. Reliance is also placed inSh Rajiv Agarwal vs ACIT395 ITR 0255 (Del) held that “even in cases where the AO comes across certain unverified information, it is necessary for him to take further steps, make inquiries and garner further material and if such material indicates that income of an Assessee has escaped assessment, form a belief that income of the Assessee has escaped assessment. There is non-application of mind by the AO could not be said to have reason to believe as to justify reopening of assessment.”

Further, as discussed, the reason, therefore, are vague, opaque and non-communicative leaving the noticee clueless of the background of satisfaction in the reason. In the case of Pr. CIT vs. Meenakshi Overseas Pvt. Ltd. 395 ITR 677 (Del), it was held that reproduction of information without showing how the material referred in therein does not show application of mind by the AO in absence of any specific discussion on the material on the basis of which independent prima facie belief is reached that income has escaped assessment. To support the above proposition of law regarding non-application of mind by the AO on the reasons recorded, the reliance is placed on following decisions:  Pr. CIT v. G & G Pharma India Ltd 384 ITR 147 (Del.);  CIT vs Independent Media Pvt Ltd in ITA 108/2015 (Del);  Signature Hotels P. Ltd. Vs. ITO – [2011] 338 ITR 0051 (Del);  CIT Vs. SFIL Stock Broking Ltd. 325 ITR 285 (Del);  Sarthak Securities Co. P. Ltd. Vs. ITO 329 ITR 110 (Del);  CIT Vs. Supreme Polypropolene (P) Ltd.ITA No.266/2011 (Del);  CIT vs. Multiplex Trading & Industrial Co. Ltd 378 ITR 351 (Del.);  Hindustan Lever Ltd. Reported in [2004] 137 TAXMAN 479 (BOM.);  CIT vs.Greenworld Corporation 314 ITR 81 (SC); From above discussion, it is evident that reopening has been made on incorrect facts, leading to the invalidation of the consequent reassessment framed on the ground of non-application of mind in view of the decisions cited below:  Shamshad Khan vs ACIT 395 ITR 265 (Del);  Pr CIT vs M/S SNG Developers Ltd 404 ITR 312 (Del) revenue’s SLP dismissed in SLP © 42379/2017 Dt: 09.02.2018;  M/s SynfoniaTradelinks P Ltd vs ITO435 ITR 642 (Del);  CIT vs Suren International Pvt Ltd 357 ITR 24 (Del);  Pr. CIT vs. RMG Polyvinyl (I) Ltd (2017) 396 ITR 5 (Del),  CIT vs. Atlas Cycle industries (1989) 180 ITR 319 (P&H);  Siemens Information System Ltd., vs. ACIT & Ors 293 ITR 548 (Bom.);  Ankita A. Choksey vs. ITO & Others (2019) 411 ITR 207 (Bom); Ground No.5 Merits of addition of Rs.23,60,77,927/-The addition has been made by the Ld AO by treating the above amount as unexplained investment although the charging section was not invoked. It is a settled law that when an assessment order lacks clear references to the specific sections under which the addition is made, it raises doubts about the intention and rationale behind the additions. Such an order can no longer be considered a "speaking order and provides room to surmises. Such an order cannot be held to be valid in the eyes of law. In this regard, reliance is placed in the decision of Smt. Sudha Loyalka vs ITO [2018 (7) TMI 1892] which has been relied in the case of Neeraj Paliwal vs ITO [2021 (12) TMI 584] and Shree Ramareddy Ramesh vs.ITO ITA No. 2027/Bang/2016.

It is apparent that the Ld AO has invoked sec 69 for making the above addition. The ingredient of sec 69 presupposes the investment made by the appellant which is not recorded in books of account by an assessee and source of which is not explained to the satisfaction of Ld AO. The precondition of an investment need be satisfied by the department and such onus needs be discharged squarely that there was actual investment made by an assessee. In the present case, the Ld AO is unable to prove the fact that the investment has been made by the appellant company during the year under consideration which fact is evident from the lack of enquiry conducted by the Ld AO both at the time of reopening of assessment or during assessment proceedings. No bank account is identified for which the alleged investment was made, and such account is proved to belong to the appellant. No enquiry was conducted with the company with whom so called investment was made. The balance sheet of the so-called investee company is available from MCA portal in public domain; the perusal of such balance sheet rule out any investment whatsoever by the appellant company.

The primary burden of proof to prove the underinvestment/unaccounted investment understatement/ concealment/ escapement of income by invoking deeming provisions of sec 69/69A/69B is on the revenue and it is only when such burden is discharged thereafter that the assessee had to provide all the answers in view of decisions of CIT Vs. Pradeep Kumar Gupta207 CTR Del 115 (Del), Sargam Cinema vs. CIT (2010) 328 ITR 513 (SC), CIT vs. Pratap Singh Amro Singh Rajendera Singh (1993) 200 ITR 788 (Raj),CIT vs. Sadhna Gupta (2013) 352 ITR 595 (Guj.),Dove Buildcon vs ITO ITA No.353/Mum/2026 dated 13.05.2026 and ACIT vs M/s Mayfair Resorts India Ltd.2023 (8) TMI 917 - ITAT DELHI.In the present case, no such compliance of deeming provision has been made by the Ld AO and therefore, addition in question needs deleted.”

HARE KRISHNA GARMENTS PRIVATE LIMITED

BALANCE SHEET AS AT 31ST MARCH 2012

(Amount in ₹)

Particulars	Note No.	Figures for the current reporting period as at 31/03/2012	Figures for the previous reporting period as at 31/03/2011
I EQUITY AND LIABILITIES
(i) Shareholder's Fund
(a) Share Capital	2.1	4,258,400.00	4,258,400.00
(b) Reserves and Surplus	2.2	120,623,104.00	120,639,090.00
(c) Money received against Share Warrants
(ii) Share Application Money Pending Attainment	2.3
(iii) Non Current Liabilities
(a) Long Term Borrowings	2.4
(b) Deferred Tax Liabilities (Net)	2.5	15,642.00	10,141.00
(c) Other Long Term Liabilities	2.6
(d) Long Term Provisions	2.7
(iv) Current Liabilities
(a) Short Term Borrowings	2.8
(b) Trade Payables	2.9
(c) Other Current Liabilities	2.10	23,000.00	22,000.00
(d) Short Term Provisions	2.11		1,695.00
TOTAL		124,918,146.00	124,932,134.00
II ASSETS
(i) Non Current Assets
(a) Fixed Assets	2.12
Tangible Assets		68,734.00	107,617.00
Intangible Assets
Capital Work in Progress
Intangible Assets Under Development
(b) Non Current Investments	2.13	111,225,927.00	111,150,000.00
(c) Deferred Tax Assets (Net)	2.14
(d) Long Term Loans and Advances	2.15	12,450,000.00	12,500,000.00
(e) Other Non Current Assets	2.16	93,832.00	129,181.00
(ii) Current Assets
(a) Current Investments	2.17
(b) Inventories	2.18
(c) Trade Receivables	2.19
(d) Cash and Cash Equivalents	2.20	79,653.00	1,050,336.00
(e) Short Term Loans and Advances	2.21
(f) Other Current Assets	2.22
TOTAL		124,918,146.00	124,932,134.00

Significant Accounting Policies and Notes to Accounts 1 to 7

As per our report of even date, For VIRENDER ARJUN & ASSOCIATES Chartered Accountants

For Hare Krishna Garments Private Limited For Hare Krishna Garments Pvt. Ltd.

Director

VIRENDER KUMAR Proprietor

Membership No. 093571

Place: Delhi Date: 03/09/2012

ITA No.416/Del/2026 (AY 2013-14)