NEWSLETTER. Rajkot Branch of WIRC of The Institute of Chartered Accountants of India JUNE. Web :

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1 JUNE Rajkot Branch of WIRC of The Institute of Chartered Accountants of India Web : rajkot@icai.org

2 CHAIRMAN S MESSAGE INSIDE THIS ISSUE Dear Members! Let me first of all wish you a very happy monsoon and pleasant rainy days. The month of Junealways makes beginning for hectic work journey and festive session also which almost continues till the month of October and this vary year the same has arrived with an additional compliance of GST while finalization of books of accounts and audits. GST has been very courageous and important move of the Indian government which is indeed a need of these days and much beneficial for economy and businesses. Keeping aside some technical glitches and implementation issues, it has been an appreciable reform. Managing & Sub Committees Forthcoming events Provisions of Reassessment Under Income tax Act, 1961 Oral Hygiene Techniques Glimpse of Past events The number of programs, seminars and workshop have been organized by our branch during last few months on GST issue which shall help the members to provide a quality output in the process of finalization and it is very promising to share that the response from the members of profession a, industry and students have been so active that we really felt inspired and motivated to organize such seminars on more frequent basis. I am pleased to inform that the Rajkot Branch has been successfully organizing useful and effective programs on Direct Taxes as National Conference, Seminars on ICDS, Tax audit and GST audit, Direct Taxes Refresher Course, RRC at Sasan in the upcoming days. In addition, the month of June and July shall be full of social and recreational activities. In the upcoming days the branch has planned various seminar on auditing aspects, a batch of ISA PT course and a women conference. The members are requested to take maximum benefits of all events. Point to Ponder: The Only way you survive is you continuously transform into something else APPEAL TO CONTRIBUTE KNOWLEDGE SHARING : We wholeheartedly invite articles, professional news and updates and other useful miscellanea. Please send/write to us on Rajkot Branch at rajkot@icai.org.com or to any of the committee members. Regards, CA. Ankit Chotaliya Chairman, Rajkot Branch of WIRC of ICAI...1

3 JUNE MANAGING COMMITTEE CHAIRMAN VICE CHAIRMAN & WICASA CHAIRMAN SECRETARY & TREASURER IMMEDIATE PAST CHAIRMAN: CA. Ankit Chotaliya CA. Bhavin Mehta CA. Hardik Vyas CA. Kalpesh Parekh SUBCOMMITTEE MEMBERS CA. Amar Unadakat CA. Sandip Katba CA. Tanmay Shah CA. Nayan Shah CA. Deepti Savjani CA. Alpesh Trivedi CA. Ravi Bhatti BRANCH NOMINEE WIRC CA. Purushottam Khandelwal CA. Jignesh Rathod CA. Paresh Davda MANAGING COMMITTEE MEMBERS: CA. Chandresh Dholakia CA. Maulik Bagdai CA. Sumit Shingala CA. Vinay Sakariya CA. Khushboo Ganatra

4 FORTHCOMING EVENTS ICDS on Saturday, 2 nd & 9 th June nd June Time Sessions Speakers 04:00 pm to 06:00 pm 06:00 pm to 08:00 pm 9 th June ICDS 1 & 2 ICDS 3, 4 & 8 CA. Palak Pavagadhi, Ahmedabad CA. Divyang Shah, Ahmedabad 04:00 pm to 06:00 pm 06:00 pm to 08:00 pm ICDS 5 & 9 ICDS 6, 7 & 10 CA. Jignesh Parikh, Ahmedabad CA. Divyang Shah, Ahmedabad CPE: Venue : 8 hours (For Both days) 4 hours (For Single day) ICAI Bhawan, Giriraj Nagar Main Road, Near Raiya Circle, Off 150ft Ring Road, Rajkot Fees: ` 600/- (plus 18%) For Both Days ` 400/- (plus 18%) For any of day Offline Registration at Branch...3

5 FORTHCOMING EVENTS Rajkot Branch has organized Half-day seminar on Tax Audit and GST Audit on Saturday, 16th June 2018 Time Sessions Faculties 04:00 pm to 06:00 pm 06:00 pm to 08:00 pm GST - Documentation, Pre Audit Precautions & Important circulars Documentation in practice Tax Audit CA. Nitesh Jai n, Ahmedabad CA. Mukesh Khandwala, Ahmedabad CPE: Venue : 4 hours ICAI Bhawan, Giriraj Nagar Main Road, Near Raiya Circle, Off 150ft Ring Road, Rajkot Fees: ` 300/- (plus 18%) ` 400/- (Spot Registration, plus 18%) For CA Students ` 200/- (Inclusive of GST) Offline Registration at Branch...4

6 FORTHCOMING EVENTS National Conference on Direct Taxes on Saturday on 23 rd & 24 th June 2018 Time Sessions Faculties 23rd June 08:00 am to 09:30 am Registrations and Fellowship 09:30 am to 10:30 am Inaugural address by Chief Guest CA. Pramod Kumar, Hon ble Member, ITAT 10:30 am to 11:30 am 11:30 am to 01:00 pm 01:00 pm to 01:45 pm 01:45 pm to 02:45 pm 02:45 pm to 03:45 pm 03:45 pm to 05:00 pm Special address on recent developments in tax litigations Keynote Address on E Systems and E Compliances in Income tax law including w.r.t. new income tax forms, CPC and other e systems related issues and Guidance Lunch Break Recent Developments in MAT, ICDS, Deemed Dividend Dealing with re-openments and reassessments, rectifications u/s.154, 254 Taxation of real estate transactions including joint developments, sections 50C, 43CA, 56(2), 54EC CA. Manoj Aggarwal, Hon ble Member, ITAT, Mumbai Bench Shri Ramesh Krishnamurthi, IRS, Addl. DGIT, Systems, CBDT CA. Yogesh Thar Shri Rajendra, Hon ble ITAT Member CA. Tarun Ghia, Chairman, Direct Taxes Committee of ICAI...5

7 JUNE FORTHCOMING EVENTS National Conference on Direct Taxes on Saturday on 23 rd & 24 th June 2018 Time Sessions Faculties 24th June 10:00 am to 11:30 am 11:30 am to 11:45 am 11:45 am to 01:15 pm 01:15 pm to 02:00 pm 02:00 pm to 03:30 pm 03:00 pm to 05:00 pm Inbound and outbound investments by NRIs and related FEMA and other issues including w.r.t. real estate investments Tea Break Recent amendments in taxation of LTCG in securities transactions, Impact of Recent SC decision w.r.t. Section 14A, Trends in taxation of alleged penny stock transactions Lunch Break Benami Transactions Prohibition Act vis a vis its interplay with income tax Act Recent developments in respect of Survey, Search, Penalty, Prosecution CA. Mayur Nayak CA. Kishor Karia CA. Gautam Nayak Shri Rajnish Vohra, Retd. Additional CIT Venue : ICAI Bhawan, Giriraj Nagar Main Road, Near Raiya Circle, Off 150ft Ring Road, Rajkot Fees: For Members - ` 1800/- Plus GST upto 16th June 18 ` 2200/- Plus GST from 17th June 18 For Non-Members - ` 2200/- Plus GST For CA Students ` 1200/- Inclusive of GST upto 16th June 18 ` 1500/- Inclusive of GST from 17th June 18 Online Payment Link -

8 FORTHCOMING EVENTS Direct Tax Refresher Series on 25 th to 30 th June 2018 Time Topics Speakers 25th June :00 am to 10:00 am 26th June :00 am to 10:00 am 27th June :00 am to 10:00 am 28th June :00 am to 10:00 am 29th June :00 am to 10:00 am 30th June :00 am to 10:00 am Computation of Business Income and related deductions under Chapter VIA-C Income from Salaries, House Property and Other Sources (including sec. 56 in particular) Income from Capital Gains and deductions (including real estate) Liability of Tax Deduction at Source as well as Provisions of Penalties (with focus on Sec. 270A) Assessment, Re-assessment, Revision and Appeals Basic provisions and practice aspects of special situations such as survey, search, unexplained credits, business restructuring etc. CA. Brijen Sampat CA. Sumit Shingala CA. Rajiv Doshi CA. Darkshak Thakkar CA. Kalpesh Doshi CA. Deepak Rindani CPE Venue : 12 Hours (2 hours per day) ICAI Bhawan, Giriraj Nagar Main Road, Near Raiya Circle, Off 150ft Ring Road, Rajkot Fees: ` 800/- Plus GST for whole series (` 200/- plus GST for any of day) For CA Students ` 500/- Inclusive of GST for whole series (` 100/- Inclusive of GST for any of day) Online Payment Link -

9 1. Preamble The proceedings under Section 147 are for the benefit of the revenue and not an assessee and are aimed at gathering the escaped income of an assessee. The same cannot be allowed to be converted as revisional or review proceedings at the instance of the assessee, thereby making the machinery unworkable. Section 147 and 148 of Income Tax Act is a well designed weapon for the Income Tax Department empowering it to assess, re-assess or re-compute income, turnover etc, which has escaped assessment. CA Jignesh Parikh The objective of carrying out Income Escaping Assessment u/s 147 is to bring any income which has escaped assessment in the original assessment under the tax net.. Sec. 147 and Section 148 of the Act contain the per-requisite conditions to be fulfilled for invoking the jurisdiction to reopen the assessment. Section 149 and 150 deals with the time limit within which the notice is required to be issued to the assesee and Section 151 deals with the competent authority to be satisfied that it is a fit case for the issue of such notice. the same are as under No of Years from Sr No Particular the end of Assessment years within which notice Required authority to be satisfied that it is a fit case for the issue of such notice. can be issued. 1 If the escaped income is less than Rs. 1,00,000. Up to 4 Years Joint Commissioner If the income which is Principal Chief Commissioner or Chief 2 escaped is equal to or more Up to 6 Years Commissioner or Principal Commissioner or than Rs. 1, 00,000 Commissioner If escaped income is Principal Chief Commissioner or Chief 3 associated with any assets Up to 16 Years Commissioner or Principal Commissioner or located outside India Commissioner Section 153 deals with time limit for completion of assessment, reassessment and re-computation. This document covers an extensive analysis on the reassessment provisions in light of landmarks judgements....8

10 2. Issues Relating to Issue of Notice 2.1 Assessing Officer - Smt. Maya Rastogi v. CIT [2011] 196 Taxman 283 (All.) Section 151 does not provide for notice to be issued by Joint Commissioner, rather it only provides that Joint Commissioner should be satisfied on reasons recorded by Assessing Officer and, therefore, if Joint Commissioner is satisfied on reasons recorded by Assessing Officer, then notice can be issued by Assessing Officer Similar is view is taken by CIT v. Restima Arif [2012] 251 CTR (All.) Govinda Choudhury & Sons v. ITO [1977] 109 ITR 370 (Ori.) Where in the proposals for reassessment sent by the ITO, the Commissioner did not write 'yes' in his own handwriting but the word was affixed by means of a rubber stamp, the sanction would not be valid under section 151(2) Similar View is taken by Raj Kishore Prasad v. ITO [1990] 88 CTR (All.) 152. However honourable Andhra Pradesh hagh court in the case of P. Munirathnam Chetty and P. Satyanarayana Chetty v. ITO [1975] 101 ITR 385 (AP) has held that while the Act requires that the Commissioner should be satisfied, it does not require that he should record his reasons for the satisfaction. Where the ITO has given elaborate reasons for reopening the assessment in his report to the Commissioner, mere 'yes' endorsement by the Commissioner would not amount to a mechanical act so as to invalidate the sanction. 2.3 Anil Jaggi v Assistant Commissioner of Income Tax, Circle 30(1), Mumbai*[2018] 89 taxmann.com 266 (Mumbai - Trib.) The failure on the part of the A.O to take the sanction of the appropriate authority contemplated under Sec. 151(1) would go to the very root of the validity of assumption of jurisdiction by the A.O. Issuing of notice under Sec. 148 by the A.O after taking approval from the wrong authority would in no way be better then a case where no approval had been sought, as in either case the obtaining of the sanction of the appropriate authority is found to be missing. Similar view is also taken by a. Ghanshyam K. Khabrani v. Asstt. CIT [2012] 20 taxmann.com 716/210 Taxman 75 (Mag.) (Bom.) b. CIT v. SPL's Siddhartha Ltd. [2012] 204 Taxman 115 (Mag.)/17 taxmann.com 138 (Delhi). c. DSJ Communication Ltd. v. Dy. CIT [2014] 41 taxmann.com 151/222 Taxman 129 (Bom.). However honourable Ahmedabad Tribunal in the case of Mayurbhai Mangaldas Patel v Income-tax Officer, Ward-2, Mehsana[2017] 88 taxmann.com 289 (Ahmedabad - Trib.) has held that reassess-...9

11 ment proceedings couldn't be quashed just because AO had obtained prior approval from higher authority. 2.4 Y. Narayana Chetty v. ITO [1959] 35 ITR 388 (SC) The notice prescribed by section 148 cannot be regarded as a mere procedural requirement. It is only if the said notice is served on the assessee that the ITO would be justified in taking proceedings against the assessee. If no notice is issued or if the notice issued is shown to be invalid, then the proceedings taken by the ITO would be illegal and void. Similar View is taken by a. CIT v. Thayaballi Mulla Jeevaji Kapasi [1967] 66 ITR 147 (SC) b. CIT v. Kurban Hussain Ibrahimji Mithiborwala [1971] 82 ITR 821 (SC) 2.5 Gokul Chand v. ITO [1994] 77 Taxman 320 (All.). When a person has a dual capacity, as an individual as well as karta of HUF, and notice under section 148 is intended to be addressed to HUF, it is necessary to specifically mention that notice was/is being addressed to him in his capacity as karta of HUF. Even if the two tax entities have the same name, it is imperative for the Assessing Officer to specify in the notice that it was addressed to the HUF and not to individual, particularly when the petitioner was the existing assessee and the alleged HUF was not. 2.6 Ranchi Club Ltd. v. CIT [1995] 214 ITR 643 (Pat.). In view of Explanation 2(b)before section 147, there cannot be any doubt that even if assessment has not been made in terms of section 143(1)(a) and section 143(3), and only intimation has been sent to the assessee, notice can be issued under section Comunidado of Chicalim v. ITO [2000] 113 Taxman 331 (SC). If the appellant had already been served with a notice under section 148 and had complied therewith by filing a return, it was entitled to contend that no second notice lay and also to submit that in any event, the second notice was barred by time. 2.8 CIT v. Eshaan Holding (P.) Ltd. [2012] 25 taxmann.com 99 (Delhi) Service of notice issued under section 148 at old address of assessee, though return of income filed before issue of notice showed new address, was not valid. ment proceedings couldn't be quashed just because AO had obtained prior approval from higher authority....10

12 2.9 Atulbhai Hiralal Shah v. Dy. CIT [2016] 73 taxmann.com 320 (Guj.) It had come on record that the Income Tax Department had sent the notice for service to the assessee through postal department on , which was duly returned by the postal department with a remark 'left'. In fact, the assessee contends that at that very address, he has received multiple communications and, therefore, the endorsement 'left' was totally wrong. For multiple reasons, the stand of the assessee cannot be accepted. Firstly, the postal dispatch has nothing to do with attempted personal service by the Income Tax Department. Secondly, the assessee does not dispute that the notice was, in fact, dispatched through the postal department on or around Thirdly, the assessee does not at least now dispute the correctness of the address. Lastly, the assessee has not joined the postal department to question why and under what circumstances, the remark 'left' was made. So far as the Income Tax Department is concerned, it was entitled to proceed on the basis of official remark of the Government of India Department that the service could not be effected, since the addressee had left the place B.K. Gooyee v. CIT [1966] 62 ITR 109 (Cal.) A notice not containing the signature of the ITO is invalid Nyalchand Malukchand Dagli v. CIT [1966] 62 ITR 102 (Guj. Notice not specifying assessment year is invalid CIT v. Kurban Hussain Ibrahimji Mithiborwala [1971] 82 ITR 821 (SC). Where notice is issued in relation to one assessment year while the assessment of another year is reopened, the notice is not valid Mohd. Ayub v. ITO [2012] 27 taxmann.com 114 (All.). Assessing Officer is obliged to issue separate notice under section 148 for each assessment year CIT v. Greenworld Corpn. [2009] 181 Taxman 111 (SC) The provision of section 150, although appears to be of a very wide amplitude, but would not mean that recourse to reopening of the proceedings in terms of sections 147 and 148 can be initiated at any point of time whatsoever. Such a proceeding can be initiated only within the period of limitation prescribed therefor as contained in section 149. Section 150(1) is an exception to the aforementioned provision. It brings within its ambit only such cases where reopening of the proceedings may be necessary to comply with an order of the higher authority. For the said purpose, the records of the proceedings must be before the appropriate authority. It must examine the records of the proceedings. If there is no proceeding before it or if the assessment year in question is also not a matter which would fall for consideration before higher authority, section 150 will have no application. It is, thus, evident that jurisdiction to issue directions is limited....11

13 3. Writ 3.1 Orient Beverages Ltd. v. ITO [1994] 208 ITR 509 (Cal.) The assessee can move the High Court and challenge the jurisdiction of the ITO in issuing notice under section 148 in a case where the condition precedent has not been fulfilled; the question of pursuing the alternative remedy does not arise at all 4. Fresh Assessment 4.1 V. Jaganmohan Rao v. CIT/CEPT [1970] 75 ITR 373 (SC) Once an assessment is reopened by issuing a notice, the previous under-assessment is set aside and the whole assessment proceedings start afresh. Once the reassessment proceedings are validly initiated, the jurisdiction of the ITO is not restricted to the portion of the income that escaped assessment. Once valid proceedings are started under section 147, the ITO not only has the jurisdiction but it is his duty to levy tax on the entire income that has escaped assessment during that year. 4.2 CIT v. Sun Engineering Works (P.) Ltd. [1992] 198 ITR 297 (SC). Keeping in view the object and purpose of the proceedings under section 147 which are for the benefit of the revenue and not an assessee, an assessee cannot be permitted to convert the reassessment proceedings on his appeal or revision, in disguise, and seek relief in respect of items earlier rejected or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to 'escaped income', and reagitate the concluded matters. Even in cases where the claims of the assessee during the course of reassessment proceedings relating to the escaped assessment are accepted, still the allowance of such claims has to be limited to the extent to which they reduce the income to that originally assessed. The income for purposes of 'reassessment' cannot be reduced beyond the income originally assessed. 4.3 Metal Import (P.) Ltd. v. CIT [1994] 72 Taxman 375 (Cal.). The implication of the decision in V. Jaganmohan Rao's case (supra ) has been lately gone into by the Supreme Court, in a recent case in CIT v. Sun Engg. Works (P.) Ltd. [1992] 198 ITR 297 wherein it has been observed that to read the judgment in V. Jaganmohan Rao's case (supra) as laying down that reassessment wipes out the original assessment and that reassessment is not only confined to 'escaped assessment' or 'under-assessment' but to the entire assessment for the year and starts the assessment proceedings de novo giving the right to an assessee to reagitate matters which he had lost during the original assessment proceedings, which had acquired finality, is not only erroneous but also against the phraseology of section 147 and the object of reassessment proceedings. Such an interpretation would be reading that judgment totally out of context in which the questions arose for decision in that case. Thus, from this judgment it will be clear that the assessee's grievance arising from the original assessment order has to be agitated by the assessee in the appellate forum against the said original assessment, because the assessee is precluded from agitating such grievances in the course of reassessment proceeding. That being so, the entire appellate remedy shall be denied to the assessee if the ratio in V. Jaganmohan Rao's case (supra) is blown up out of all propotion. Therefore, the only pragmatic reading of that judgment can be that the reassessment proceeding would confine itself to the points of under-assessment. It cannot embrace the entire assessment....12

14 5. Reason to believe 5.1 CIT v. Atul Jain [2008] 299 ITR 383 (Delhi). There must be reason to believe warranting the issuance of a notice by the Assessing Officer. If there are no reasons, then the entire foundation for initiating the proceedings is bad and the notice initiating proceedings must be quashed. A mere statement of facts in the form of a report is not a substitute for reasons that are required to be recorded before issuing a notice under section 148 of the Act. Mere satisfaction of the Assessing Officer for the issuance of a notice is not enough - there must be reasons on record which have led him to believe that a notice should be issued. After a foundation based on information is set up, there must still be some reasons which warrant the holding of a belief so as to necessitate the issuance of a notice under section 148. The assessees had purchased certain shares through stock and share broker. Subsequently, these shares were sold at a much higher value through another broker. The assessee had disclosed long-term capital gain arising from the transaction. Some intra-departmental information was received by the Assessing Officer to the effect that the assessees had taken a bogus entry of long-term capital gain after paying the equivalent amount in cash together with premium for the accommodation entry to the second broker. This information was received from the Deputy Director of Income-tax (Investigation). Based on the information received, the Assessing Officer took action to issue a notice under section 148. The concerned files were then put up before the Commissioner of Income-tax and in response to the question whether the Commissioner was satisfied that income had escaped assessment, he wrote 'Yes'. The question for consideration was whether the reopening of assessment was justified. Held that the only information was that the assessees had taken a bogus entry of capital gains by paying cash along with some premium for taking a cheque of that amount. The information did not indicate the source of the capital gains (which in this case are shares). One did not know which shares had been transacted and with whom had the transaction taken place. There were absolutely no details available and the information supplied was extremely scanty and vague. Insofar as the basis for the reasons was concerned, even that was absent. The Assessing Officer did not verify the correctness of the information received by him, but merely accepted the truth of the vague information in a mechanical manner. The Assessing Officer had not even recorded his satisfaction about the correctness or otherwise of the information or his satisfaction that a case had been made out for issuing a notice under section 148. Read in this light, what had been recorded by the Assessing Officer as his 'reasons to believe' was nothing more than a report given by him to the Commissioner. Thus, the reopening of assessment was not justified. 6. Approval must not be mechanical 6.1 Sunil Agarwal vs. ITO (ITAT Delhi) itatonline.org Section 151 of the Act clearly stipulates that the CIT(a), who is the competent authority to authorize the reassessment notice, has to apply his mind and form an opinion. The mere appending of the expression approved says nothing. It is not as if the CIT(A) has to record elaborate reasons for agree-...13

15 ing with the noting put up. At the same time, satisfaction has to be recorded of the given case which can be reflected in the briefest possible manner. In the present case, the exercise appears to have been ritualistic and formal rather than meaningful, which is the rationale for the safeguard of an approval by a higher ranking officer. 6.2 ITO vs. Virat Credit & Holdings Pvt.Ltd (ITAT Delhi) itatonline.org The grant of approval by the CIT with the words Yes. I am satisfied proves that the sanction is merely mechanical and he has not applied independent mind while according sanction as there is not an iota of material on record as to what documents he had perused and what were the reasons for his being satisfied to accord the sanction to initiate the reopening of assessment u/s 148 of the Act. 6.3 Kalpana Shantilal Haria vs. ACIT (Bombay High Court)itatonline.org There can be no dispute with regard to the application of Section 292B of the Act to sustain a notice from being declared invalid merely on the ground of mistake in the notice. However, the issue here is not with regard to the mistake / error committed by the Assessing Officer while taking a sanction from the Joint Commissioner of Income Tax but whether there was due application of mind by the Joint Commissioner of Income Tax while giving the necessary sanction for issuing the impugned notice. It is a settled principle of law that sanction granted by the higher Authority for issuing of a reopening notice has to be on due application of mind. It cannot be mechanical approval without examining the proposal sent by the Assessing Officer. Prima facie, it appears to us that if the Joint Commissioner of Income Tax would have applied his mind to the application made by the Assessing Officer, then the very first thing which would arise is the basis of the notice, as the provision of law on which it is based is no longer in the statute 7. Recording of Reasons 7.1 Rajoo Engineers Ltd. v. Dy. CIT [2008] 218 CTR (Guj.) 53. On a plain reading of section 148(2) the legislative mandate which one discerns is that before issuing any notice under section 148, the Assessing Officer is bound to record reasons for issuance of such notice. The language of section 148(2) does not permit recording of reasons between the date of issuance of notice and service of notice. The words used by the provision in no uncertain terms require recording of reasons before issuing any notice. 7.2 Meta Plast Engineering P. Ltd. vs. ITO (ITAT Delhi) itatonline.org Passing the reassessment order before the expiry of 4 weeks of passing the order of objections renders the reassessment order void. Also, if the reasons state bogus accommodation entries were provided/taken and it is not clear whether the assessee has received or provided accommodation entries, it means there is no application of mind by the AO while recording reasons...14

16 8. Reasons Recorded for One Income and Assessment of Other income 8.1 Travancore Cements Ltd. v. ACIT [2009] 179 Taxtman 117 (Ker.) Section 148 deals with the issue of notice where income has escaped assessment. Section 148(2) states that the Assessing Officer shall, before doing so, record his reasons for issuing such notice. Recording of reasons before issuing notice is a mandatory requirement. The Assessing Officer is also empowered under section 147 to assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under section 147. Therefore, the Assessing Officer gets jurisdiction under section 147 to assess or reassess the income which has escaped assessment only after sub-section (2) of section 148 has been complied with. The question is whether when proceedings under section 147 are already on in respect of one item of the income for which the Assessing Officer had already recorded reasons, it is necessary that the Assessing Officer should record reasons for assessing or reassessing any other items of income which are totally unconnected with the proceedings already initiated. The answer is that when under two heads, income has escaped assessment and those two heads are interlinked and connected, the proceedings initiated or notice already issued under sub-section (2) of section 148 would be sufficient if the escaped income on the second head comes to the knowledge of the Assessing Officer in the course of the proceedings. However, if both the items are unconnected and totally alien, then the Assessing Officer has to follow sub-section (2) of section 148 with regard to the escaped income, which comes to his knowledge during the course of the proceedings. The expression 'subject to the provisions of sections 148 to 153' in section 147 lends support to the above view. [Para 9] 8.2 Commissioner of Income-tax- II vs Mohmed Juned Dadani [2013] 30 taxmann.com 1 (Gujarat) It is not dispute that once an assessment is reopened by a valid exercise of jurisdiction under section 147, it is open for the Assessing Officer to assess or reassess any income which had escaped assessment which comes to his light during the course of his assessment proceedings which was not mentioned in the reason for issuing notice under section 148. In a notice for reassessment which has been issued beyond a period of four years from the end of relevant assessment year, the condition that income chargeable to tax has escaped assessment for the reason of the failure on the part of the assessee to disclose truly and fully all material facts for the purpose of assessment must also be established unless of course some other ground viz., non-filing of the return at all etc. is available to the Assessing Officer. If such non-disclosure of material facts is established with respect to the reason recorded for issuing notice for reopening the assessment, it would be open for the Assessing Officer to thereafter even assess other income which might have escaped assessment but which may not necessarily satisfy the requirement of non-disclosure of true and full material facts. If in such a situation, the stand of the revenue is accepted, a very incongruent situation would come about if ultimately the Assessing Officer were to drop the ground on which notice for reopening had been issued but to chase some other grounds not so mentioned for issuance of the notice...15

17 In such a situation, even if a case where notice for reopening has been issued beyond a period of four years, the assessment would continue even though on all the grounds on which the additions are being made, there was no failure on the part of the assessee to disclose true and full material facts. In such a situation an important requirement of failure on part of the assessee to disclose truly and fully all material facts would be totally circumvented. [Para 30] Thus, it is apparent that Explanation 3 to section 147 does not change the situation insofar as the present controversy is concerned. [Para 31] In the result, it is held that the Tribunal was right in law in coming to the conclusion that when on ground on which the reopening of assessment was based, no addition were made by Assessing Officer in the order of assessment, he could not make additions on some other grounds which did not form part of reasons recorded by him. [Para 33] 8.3 Gujarat Paguthan Energy Corporation (P.) Ltd v Deputy Commissioner of Income-tax, Circle- 4*[2014] 45 taxmann.com 564 (Gujarat) A valid reopening of previously closed assessment is a must for assuming jurisdiction under section 147. When the very foundation of such reassessment are both the reasons recorded and by virtue of binding decisions, neither of the grounds is sustainable, permitting such notice to be pursued would be an exercise in futility and this Court cannot disregard such vital aspects while addressing the challenge to the notice of reopening. 9. Reasons for Reopening the Assessment must be given to the assessee. 9.1 Manjula AthurvsIncome Tax Officer, Non Corporate Ward 13(5), Chennai[2018] 91 taxmann.com 438 (Madras) It is held that the Assessing Officer is bound to furnish the reasons for reopening the assessment to the assessee when the assessee seeks reasons for the reopening. [Para 8]. Therefore, on this ground, following the dictum laid down by the Supreme Court in the judgment [2002] 125 Taxman 963/259 ITR 19/[2003] 259 ITR 19 [GKN Driveshafts (India) Ltd. v. ITO] the impugned assessment order is liable to be set aside. Accordingly, the same is set aside. [Para 10] The respondent is directed to consider the request of the assessee for furnishing the reasons recorded for reopening the assessment for the year within a period of fifteen (15) days from the date of receipt of a copy of this order. On furnishing of such reasons for reopening, the assessee is directed to file her objections/reply within thirty (30) days thereafter, after which, the respondent shall consider and redo the assessment by following the mandate laid down in [GKM Driver shafts (India) Ltd. (supra)], as expeditiously as possible. [Para 11] 9.2 Bharatmaiya Memorial Foundation v Deputy Commissioner of Income-tax (Exemption)-2, Ahmedabad [2018] 91 taxmann.com 25 (Gujarat) Even if objections against reasons recorded for reopening of assessment were received belatedly, but prior to framing of assessment, Assessing Officer was duty bound to consider them....16

18 9.3 Surya Restaurant v. Union of India [1994] 120 CTR (MP) 515. It is obligatory on the part of the authority concerned to disclose and communicate reasons for appreciation and proper defence, at least on demand after submission of return in compliance of the notice. At that stage, refusal is unwarranted in law and citation of absence of provisions in the Act tantamounts to closure of the eyes to realities. Law in fact permits no privilege in that behalf. The assessee is entitled to contest the issue effectively. This is possible only on obtaining reasons. It cannot be gainsaid that the satisfaction of conditions, being a sine qua non can be judged only on the basis of reasons. Refusal in such a case is arbitrary and prejudicial. 9.4 Agarwal Metals & Alloys v. Asstt. CIT [2012] 27 taxmann.com 139 (Bom.). Reopening of assessment without communication of reasons for reopening and without furnishing to assessee an opportunity of filing its objections is not valid. 9.5 Mitilesh Kumar Tripathi v. CIT [2006] 280 ITR 16 (All.). Section 148(2) neither expressly nor impliedly provides for 'reasons' to be communicated to the assessee. It is only by virtue of 'judicial pronouncements' that the Apex Court and other High Courts had laid down that 'reasons' ought to be communicated to avoid 'arbitrary' action or to avoid 'abuse' of the power/office by the tax authorities with an object to save the 'assessee' from harassment. If reasons are supplied along with the notice under section 148(2), it shall obviate unnecessary harassment to the assessee as well as to the revenue by avoiding unnecessary litigation which will save courts also from being involved in unproductive litigation. Above all, it shall be in consonance with the principles of natural justice. 10. No Reassessment when No Impact on Chargeable Income 10.1 AccuraPolytech (P.) Ltd. V Principal Commissioner of Income Tax-1 [2018] 89 taxmann.com 12 (Gujarat) For relevant year, assessment in case of assessee was completed under section 143(3) - Subsequently, Assessing Officer reopened assessment taking a view that assessee wrongly carried forward unabsorbed depreciation pertaining to assessment year on ground that it had lapsed in view of prospective amendment in section 32(2) - Tribunal held that assessment year in question was merely a transient year where carry forward of earlier year had been brought forward to that year and again carried forward to next year for set off in appropriate assessment year - It was further opined that disclosure of unabsorbed depreciation had no impact on 'chargeable income' for relevant year which was alleged to have escaped assessment - Tribunal thus set aside reassessment proceedings - Whether, on facts, impugned order passed by Tribunal did not give rise to any substantial question of law. 11. Reason to Believe vs Reason to Suspect 11.1 Scan Holding (P.) Ltd v Assistant Commissioner of Income-tax[2018] 90 taxmann.com 396 (Delhi) On the issue of initiation of proceedings under sections 147/148, distinction is drawn between 'reasons to believe' and 'reasons to suspect' as the statute permits re-opening in the former case and not in the latter case. [Para 8]...17

19 At the stage of issue of notice what is required and necessary is that the information must be 'definite', i.e., it should not be mere guess, gossip or rumour. In the context of the two sections 'definite' does not mean conclusion of certainty at the stage of notice for there is clear distinction between receipt of information as a consequence of which the Assessing Officer forms an honest belief and notice is issued, and the final determination, which takes place when the assessment order is passed. Once the Assessing Officer has formed a bona fide and honest belief upon materials, which reasonably support such belief, issue of notice would be valid. [Para 10] The aforesaid discussion means that a complaint or information from a third party before the Assessing Officer, when it is 'definite' information and not mere gossip or guess or rumour, can certainly be a ground for issue of notice under section 147/148 albeit the Assessing Officer must form an honest belief upon some material, and basis, which supports such belief. [Para 11] The assessee has pointed out that similar complaints were made by the statutory auditors for assessment years , and for subsequent assessment years, i.e., onwards. Complaints were also made against the individual directors of assessee-company. The individual directors had filed writ petitions which have been allowed. Similarly, for the assessment year , the assessee had participated in the assessment proceedings under section 147/148 and some additions in the scrutiny assessment were made, but these additions have been deleted in the first appeal. [Para 12] This is a case wherein there was no assessment and in case Assessing Officer felt that there was nexus between the grounds and the facts stated and available which have basis and foundation to form the 'reasons to believe' that income has escaped assessment, it is open to him to say so and thereafter continue with the proceedings under section 147/148. However, the findings of the Assessing Officer must be honest and cogent, based upon some material available on record, to support the prima facie finding and not predicated on mere assumption and guess work. A complaint or information may merit examination and consideration, but every complaint does not merit reopening or proceeding under section 147/148. The Assessing Officer must examine and ascertain whether or not allegation made are mere guess work, surmise and rumour, or has some basis to make it the basis for detailed final determination. [Para 13] 11.2 Mrs.Sejal J. Panchal v Income-tax Officer, Ward-10(4), Ahmedabad[2018] 90 taxmann.com 305 (Ahmedabad - Trib.) A bare glance of the reasons recorded gives unmistakable impression that the action under s.147 of the Act was taken for detailed verification of the various aspects of the reference made to the AO in consequence of search in case of a third party. Thus, it is evident that no definite formation of belief towards escapement of income was made at the time of issuance of notice. The AO has not even come to a prima-facie conclusion towards escapement of income. What the AO intended is to make objective enquiry into the correctness of the information received from other wing of the department and find out if there is any escapement of income. The AO merely seeks to conclude that there is a case for investigation towards truth of the alleged transactions. This is not the same thing as saying that there are 'reasons to belief' that some chargeable income has escaped assessment. Ostensibly, the AO at best has made out a case of 'probable' escapement in distinction to a definite conclusion of escapement of income. Thus, the requirement of section 147 is clearly not fulfilled....18

20 Needless to say, provisions of section 147 which gives power to reopen a completed assessment can be invoked only when the conditions precedent for exercising the jurisdiction exists. Exercise of power under s.147 of the Act cannot be made on the basis of mere ipsi dixit of revenue. It is well settled by plethora of judicial precedents that reopening is not permissible merely seeking to investigate the facts collected without holding atleast prima-facie belief based on relevant material towards escapement of income. The conditions have not been met. Hence, the notice issued under s.147 of the Act is not backed by authority of law and consequently bad in law. The assessment as a sequel to such illegal notice is therefore null and void and requires to be quashed. 12. Reopening in absence of any tangible material is not allowed PCIT vs. Manzil Dineshkumar Shah (Gujarat High Court) itatonline.org It is equally well settled that the notice of reopening can be supported on the basis of reasons recorded by the Assessing Officer. He cannot supplement such reasons. The third principle of law which is equally well settled and which would apply in the present case is that reopening of the assessment would not be permitted for a fishing or a roving inquiry. This can as well be seen as part of the first requirement of the Assessing Officer having reason to believe that income chargeable to tax has escaped assessment. In other words, notice of reopening which is issued barely for making fishing inquiry, would not satisfy this requirement 12.2 Income Tax officer v ChintanJadavbhai Patel [2018] 91 taxmann.com 426 (SC) Re-opening notice was issued against assessee on basis of one 'saudachitthi' seized during search of premises of one RV - As per saudachitthi, assessee had sold land for sale consideration of higher amount - However, sale consideration in sale deed executed by assessee in favour of one PK was for sale consideration of much lesser amount - Therefore, Assessing Officer held that difference of two sale amounts had escaped assessment by way of long-term capital gain - However, it was to be noted that assessee was not signatory to saudachitthi - Even concerned persons who signed said saudachitthi were not owners of land sold - Saudachitthi was not acted upon - Person who purchased land from assessee was also not signatory to saudachitthi - High Court by impugned order held that since there was no tangible material available to prima facie show that assessee had received additional sale consideration in cash, formation of opinion that assessee had sold land for higher amount was only on surmises and, therefore, re-opening notice was unjustified - Whether Special Leave Petition against said impugned order was to be dismissed - Held, yes [Para 2] 13. No Reassessment on the Basis of Change of Opinion Income Tax Officer, ward No. 16(2)vsTechSpan India (P.) Ltd.[2018] 92 taxmann.com 361 (SC) The language of section 147 makes it clear that the Assessing Officer certainly has the power to re-assess any income which has escaped assessment for any assessment year subject to the provisions of sections 148 to 153. However, the use of this power is conditional upon the fact that the Assessing Officer has some reason to believe that the income has escaped assessment. The use of the words 'reason to believe' in section 147 has to be interpreted schematically as the liberal interpretation of the word would have the consequence of conferring arbitrary powers on the Assessing Officer who may even initiate such re-assessment proceedings merely on his change of opinion on the basis of same facts and circumstances which have already been considered by him during the...19

21 original assessment proceedings. Such could not be the intention of the legislature. The said provision was incorporated in the scheme of the IT Act so as to empower the Assessing Authorities to re-assess any income on the ground which was not brought on record during the original proceedings and escaped his knowledge; and the said fact would have material bearing on the outcome of the relevant assessment order. [Para 8] Section 147 does not allow the re-assessment of an income merely because of the fact that the Assessing Officer has a change of opinion with regard to the interpretation of law differently on the facts that were well within his knowledge even at the time of assessment. Doing so would have the effect of giving the Assessing Officer the power of review and section 147 confers the power to re-assess and not the power to review. [Para 9] To check whether it is a case of change of opinion or not one has to see its meaning in literal as well as legal terms. The word change of opinion implies formulation of opinion and then a change thereof. In terms of assessment proceedings, it means formulation of belief by an Assessing Officer resulting from what he thinks on a particular question. It is a result of understanding, experience and reflection. [Para 10] Before interfering with the proposed re-opening of the assessment on the ground that the same is based only on a change in opinion, the Court ought to verify whether the assessment earlier made has either expressly or by necessary implication expressed an opinion on a matter which is the basis of the alleged escapement of income that was taxable. If the assessment order is non-speaking, cryptic or perfunctory in nature, it may be difficult to attribute to the Assessing Officer any opinion on the questions that are raised in the proposed re-assessment proceedings. Every attempt to bring to tax, income that has escaped assessment, cannot be absorbed by judicial intervention on an assumed change of opinion even in cases where the order of assessment does not address itself to a given aspect sought to be examined in the re-assessment proceedings. [Para 12] The fact in controversy in this case is with regard to the deduction under section 10A which was allegedly allowed in excess. The show cause notice dated reflects the ground for re-assessment in the present case, that is, the deduction allowed in excess under section 10A and, therefore, the income has escaped assessment to the tune of Rs. 57,36,811. In the order in question dated , the reason purportedly given for rejecting the objections was that the assessee was not maintaining any separate books of account for the two categories, i.e., software development and human resource development, on which it has declared income separately. However, a bare perusal of notice dated which was issued in the original assessment proceedings under section 143 makes it clear that the point on which the re-assessment proceedings were initiated, was well considered in the original proceedings. In fact, the very basis of issuing the show cause notice dated was that the assessee was not maintaining any separate books of account for the said two categories and the details filed do not reveal proportional allocation of common expenses be made to these categories. Even the said show cause notice suggested how proportional allocation should be done. All these things leads to an unavoidable conclusion that the question as to how and to what extent deduction should be allowed under section 10A was well considered in the original assessment proceedings itself. Hence, initiation of the re-assessment proceedings under section 147 by issuing a notice under section 148 merely because of the fact that now the Assessing Officer is of...20

22 the view that the deduction under section 10A was allowed in excess, was based on nothing but a change of opinion on the same facts and circumstances which were already in his knowledge even during the original assessment proceedings. [Para 13] In light of the forgoing discussion, the impugned judgment and order of the High Court dated does not call for any interference. [Para 14] Shahrukh Khan v Deputy Commissioner of Income-tax, Central Circle-4(2) [2018] 90 taxmann.com 284 (Bombay) Where as per rule 11UA, value of shares was less than Rs. 5, but assessee purchased same at Rs. 10 per share and disclosed all facts in return, reassessment notice for valuing these shares at Rs. 35 as per valuation by Government valuer was not justified In the circumstances, we are, prima facie, of the view that the impugned notice indicates a change of opinion, as this very issue namely - valuation of share was a subject matter of consideration during the regular assessment proceedings. Besides, on the application of method of valuation as mandated by the Explanation to Section 56(2)(vii) of the Act, prima facie, the Assessing Officer could not have had reason to believe that income chargeable to tax has escaped assessment. 14. Penny Stock The CBDT has issued a letter dated in which it has noted that an investigation has been conducted by Kolkata Investigation Directorate in respect of large number of penny stock companies, whose share prices were artificially raised on the Stock Exchanges in order to book bogus claims of Long Term Capital Gains or Short Term Capital Loss by various beneficiaries. It is stated that extensive investigation, including search and seizure/survey action on entry providers, riggers, beneficiaries etc. was conducted by the Investigation Directorate in such cases. Based upon outcome of such investigation and analysis of the data, the Systems Directorate has now uploaded details of such information in respect of individual assessees who have made transactions in such penny stocks. The CBDT has directed that the information relating to the Penny Stock should be considered by AO s for making assessments u/s 143(3) and reopening assessments u/s 148 of the Act Pr CIT vs. Paradise Inland Shipping Pvt. Ltd (Bombay High Court)itatonline.org This Court in the Judgments relied upon by the learned Counsel appearing for the Respondents, have come to the conclusion that once the Assessee has produced documentary evidence to establish the existence of such Companies, the burden would shift on the Revenue-Appellants herein to establish their case. In the present case, the Appellants are seeking to rely upon the statements recorded of two persons who have admittedly not been subjected to cross examination. In such circumstances, the question of remanding the matter for re-examination of such persons, would not at all be justified. The Assessing Officer, if he so desired, ought to have allowed the Assessee to cross examine such persons in case the statements were to be relied upon in such proceedings. Apart from that, the voluminous documents produced by the Respondents cannot be discarded merely on the basis of two individuals who have given their statements contrary to such public documents. Other Supporting Judgments on Penny Stock...21

23 a. Pr. CIT v. Prem Pal Gandhi in ITA (O&M) dt (Punjab & Haryana HC) b. ITO v. Arvind Kumar Jain HUF ITA No. 4862/MUM/2014 dt (Mum.)(ITAT) c. ITO v. M/s. Indravadan Jain (HUF) ITA No. 4861/Mum./2014 dt d. CIT v. Shyam R. Pawar [2015] 229 Taxman 256 (Bombay) e. CIT v. SmtJamna Dev Agarwal 328 ITR 656 (Bombay) f. CIT v. Vivek Mehta 204 Taxmann 177 (Punjab & Haryana) g. CIT v. Mahesh chandra G. Vakil 220 Taxman 166 (Gujarat)(HC) h. Ms. Farrah Marker v. ITO (Mumbai) ITA No. 3801/Mum/2011 i. CIT v. Smt. Sumitra Devi 49 taxmann.com 37 (Rajasthan) j. Arvind Mehta v. ITO ITA No. 2799/Mum/2015 pronounced on k. Commissioner of Income-tax-I v. Himani M. Vakil [2013]10 taxmann.com 326 (Guj.) l. ITO v. Aarti Mittal 41 taxmann.com 118 (Hyderabad Trib.) m. DCIT v. Anil Kaniya ITA No. 4077/Mum/2013 (Mumbai) n. Sudhanshu Suresh Pandhare v. ITO I.T.A. No. 5185/Mum/2012 (Mumbai) o. Surya Prakash Toshniwal HUF v. ITO ITA No.1213/Kol/2016 (Kol. ITAT) 15. No Reassessment after four years if no failure on part of assessee to disclose all material facts necessary for assessment Dipak Kumar Dasbhowmik v Income Tax Officer, Ward 38(1), Midnapore[2018] 92 taxmann.com 75 (Kolkata - Trib.) 19. Reassessment is permissible when original assessment is quashed for technical reasons Krishna Developers & Company v Deputy Commissioner of Income-tax, Circle-7(2) [2018] 91 taxmann.com 306 (SC) Nothing contained in the language of section 147 would permit to hold that even if all the parameters to enable the Assessing Officer to assess or reassess the income by reopening the assessment...22

24 are present, same may not be permitted in cases where the original assessment framed by the Assessing Officer has failed on any technical ground, such as in the present case i.e. want of service of notice under section 143(2). Once the original assessment is declared as invalid as having been completed without the service of notice on the assessee within the statutory period, there would be thereafter no assessment in the eye of law. The situation therefore, be akin to where return of the assessee has been accepted without a scrutiny. Reopening of the assessment, if the Assessing Officer has the reason to believe that income chargeable to tax has escaped assessment, would be entirely permissible under section 147. Merely on the ground that the reasons recorded by the Assessing Officer proceeded on the same basis on which the Assessing Officer initially desired to make additions but which failed on account of setting aside the order of assessment, would not preclude the Assessing Officer from carrying out the exercise of reopening of the assessment. In the present case, facts are peculiar. It is not as if the Assessing Officer after noticing certain discrepancies in the return of the assessee, slept over his right to undertake the scrutiny assessment. The scrutiny assessment was initiated by issuance of notice under section 143(2) on It was also dispatched for service to the assessee on by Speed Post on the last known address. The Commissioner (Appeals) however, held that there was no proof of service of notice and since section 143(2) requires service of notice, the assessment was framed without complying with the mandatory requirements. [Para 20] 20. Recording Of Satisfaction U/s 147 SOP By CBDT In order to sustain his action u/s 147. Accordingly, to bring uniformity in the action of the department in the matters of income escaping assessments, CBDT has issued standard operating procedure [SOP] for recording satisfaction u/s 147 of the Act vide its internal directive No. 247/140/2017-A&PC-1 dated There are sample templates annexed to the SOP for recording reasons of reopening of assessment under each of the above eventualities. A standard eight paragraph template is recommended covering almost all the necessary ingredients of section 147 and other relevant machinery provisions of the Act which are necessary to sustain the action of the AO u/s 147. The attempt of CBDT to standardise the procedure of recording the satisfaction/ reasons to believe by AO u/s 147 is praiseworthy. While drafting the said standard procedure, CBDT has indirectly recognised various judicial precedents declaring reopening of assessment invalid due to lapses on the part of the AO while recording reasons u/s 147 of the Act. If the aforesaid directives are followed strictly and as elaborately as suggested by CBDT, it will not only prevent the illegal/casual reopening but also reduce litigation to great extent. On the other hand, the reasons recorded in casual or routine manner by ignoring the above stepwise procedure, may be liable to be quashed by the judiciary on that ground alone. 21. Disclaimer: The contents of this document are solely for informational purpose. It does not constitute professional advice or a formal recommendation. While due care has been taken in preparing this document, the existence of mistakes and omissions herein is not ruled out. Neither the compiler nor editor nor publisher and its affiliates accepts any liabilities for any loss or damage of any kind arising out of any inaccurate or incomplete information in this document nor for any actions taken in reliance thereon....23

25 Oral Hygiene Techniques Tooth Brushing Technique A dry multitufted brush with a short head is choosen. The brush is directed at an angle of 45º towards the gingiva and rolled towards tooth surface. Small vibrations of the brush loosen the plaque. Brushing should covered lingual (inner), buccal (outer), occlusal (upper) surfaces of the teeth. Innovative brushes with oblique longer bristles should make it possible to improve interdental cleaning. Dr. Keyur Patel (Dentist) Interdental hygiene: Interdental areas are usually not adequately reached by normal or electric tooth brushes. Therefore additional special aids are required for interdental cleaning. Dental Floss Dental Floss Dental Floss with holders Dental Floss consists of 3 parts 1. Stiff end to thread. 2. Spongy intermediate part to clean the gingival side. 3. Longer part made of normal dental floss. Interdental Brushes These are cone shaped brushes made of bristles. It is used for cleaning large irregular tooth surface adjacent to wide interdental space. Toothpicks These are used with or without handle made up of wood. Removing soft deposit for the teeth and repeatedly move in and out of the embrasures. Golden tips for better dental health: 1. A person should brush twice a day, and do not eat/drink immediately after brushing. 2. Avoid maximum intake of sweets in snacks and gargle your mouth with water or mouthwash after sweets 3. Use interdental brush or dental floss to clear debris between two teeth and gums 4. Maximum usage of citrus fruits (containing vit-c) and fibrous fruits like apple are recommended for better health of gums. 5. Kindly consult your dentist every 6 Months to keep your dental health updated.. 6. Kindly consult your dentist immediately, if you have symptoms like, cold water sensitivity, bleeding gums, bad smelling and cavities in teeth

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30 JUNE Glimpses of Past Event Seminar on Recent changes in Income Tax on 28th May 2018 Monday HELP US TO SERVE YOU BETTER To Start Receiving SMS & s From Branch Please Send Your Details At DISCLAIMER: The views nd opinions expressed or implied" & material in the publication may not be reproduced. Unsolicited articles and transparaencies are sent in at the owners risk and publishers accepts no liability of loss or damage. Material in the publication may no be reproduced, whether in part or in whole, without the consent of Branch/ICAI. It is For Private Circulation only. RAJKOT BRANCH OF WIRC OF INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA ICAI BHAVAN, Giriraj Nagar Main Road, Nr. Raiya Circle, Off 150 Feet Ring Road, Rajkot Tel. : Web: rajkot@icai.org...29