Income Tax Appellate Tribunal - Jaipur
Prateek Kothari, Jaipur vs Assessee on 15 June, 2016
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IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR
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BEFORE: SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM
vk;dj vihy la-@ITA No. 312/JP/2015
fu/kZkj.k o"kZ@Assessment Year : 2007-08
Prateek Kothari, cuke Assistant Commissioner of
H-12, Sukhi Jeewan Vs. Income Tax,
Complex, Jacob Road, Central Circle-2, Jaipur.
Jaipur.
LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: ABIPK 8090 R
vihykFkhZ@Appellant izR;FkhZ@Respondent
fu/kZkfjrh dh vksj ls@ Assessee by : Shri Vijay Goyal (CA)
jktLo dh vksj ls@ Revenue by : Shri M.S. Meena (CIT)
lquokbZ dh rkjh[k@ Date of Hearing : 26/05/2016
mn?kks"k.kk dh rkjh[k@ Date of Pronouncement : 15/06/2016
vkns'k@ ORDER
PER: T.R. MEENA, AM This is an appeal filed by the assessee against the order dated 25/02/2015 passed by the learned CIT(A)-4, Jaipur, for A.Y. 2007-08. The respective grounds of appeal raised by the appellant are as under:-
"1 On the facts and in the circumstances of the case and in law the ld CIT(A) erred in confirming the addition of Rs. 24,80,911/- made on account of advance received by the assessee from M/s Nakshatra Real Estates Private Limited.
2 ITA 312/JP/2015_ Prateek Kothari Vs ACIT
2 On the facts and in the circumstances of the case and in law the ld CIT(A) erred in holding that the advance received by the assessee from M/s Nakshatra Real Estates Private Limited amounting to Rs. 24,80,911/- represents loan and provisions of section 2(22)(e) of Income Tax Act, 1961 were attracted.
3. That the order of the ld CIT(A), confirming the addition made by the ld Assessing Officer on account of deemed dividend by applying the provisions of Section 2(22)(e) of Income Tax Act is arbitrary, whimsical, capricious, perverse and against the law and facts of the case. The order of ld CIT(A) in this regard deserves to be set aside and addition made by the ld Assessing Officer deserves to be deleted." The assessee has also taken additional ground, which is reproduced as under:-
"The assessment order passed U/s 153A read with Section 143(3) of the Income Tax Act for assessment year 2007-08 is bad in law, void ab-initio, and also the addition made therein deserves to be deleted as no addition can be made in the assessment made U/s 153A read with Sec. 143(3) consequent to the search unless some incriminating material in support of the addition is found as a result of search.
2. The assessee has income from salary, capital gain and other sources. A search and seizure operation was carried out by the department U/s 132 of the Income Tax Act, 1961 (in short the Act) and survey U/s 133 of the Act was carried out by the department on the members of KGK 3 ITA 312/JP/2015_ Prateek Kothari Vs ACIT Group on 06/5/2010. Assessee is a member of Prateek Kothari sub-group. The ld Assessing Officer observed that during the course of search, cash jewellery, stock in trade, valuables, documents, books of account and loose papers were found and seized from the premises of the members of KGK Group of which one such member happens to be the assessee. Notice U/s 153A of the Act was issued on 16/9/2001 to file return as per Rule 12 of the Income Tax Rules, 1962 (in short the Rules). The assessee had filed return declaring total income of Rs. 6,21,000/- and speculation business loss of Rs. 3,90,430/-, unabsorbed depreciation for current year of Rs. 2,51,106/- with brought forward long term capital loss of A.Y. 2005-06 at Rs. 5,65,025/- was filed on 25/10/2011. The original return filed by the assessee U/s 139(1) of the Act on 26/10/2007 and identical income had been disclosed in the return. In response to notice U/s 153A, no undisclosed income pertaining to the relevant year had been declared by the assessee. The ld Assessing Officer further observed that during the course of scrutiny proceedings, it was noticed that the assessee had taken loan of Rs. 31.65 lacs from M/s Nakshatra Real Estates Developers Pvt. Ltd. in which the assessee is shareholder of 50%. As per audited balance sheet of the company, it had reserve and surplus at Rs. 24,80,911/-. The ld Assessing Officer gave reasonable opportunity of being heard on 4 ITA 312/JP/2015_ Prateek Kothari Vs ACIT deemed dividend. The assessee submitted before the ld Assessing Officer that there was no reserve and surplus on first day of the year under consideration, therefore, deeming provision cannot be applied. The ld Assessing Officer held that the assessee sold the land to the company, which has been transferred back to the assessee in form of loan. Therefore, he made addition U/s 2(22)(e) of the Act at Rs. 24,80,911/-.
3. Being aggrieved by the order of the Assessing Officer, the assessee carried the matter before the ld CIT(A), who had confirmed the addition by observing that the assessee was not able to give evidence before the Assessing Officer, therefore, he accepted the additional evidence under Rule 46A of the Rules, which was forwarded to the Assessing Officer for his comment. As per Assessing Officer, the agreement to sale was dated 08/11/2006 was simply an afterthought to escape the provisions of Section 2(22)(e) of the Act. There was no evidence that agreement to sale was materialized into actual sale. As per agreement to sale, the consideration was for Rs. 50,01,000/- out of which Rs. 25.00 lacs was paid on 10/11/2006 and further Rs. 12.50 lacs was to be paid within four months i.e. up to 10/3/2007 and the balance of Rs. 12,51 lacs was to be paid after the appellant completed the JDA procedure of conversion and patta. As per Assessing Officer, within such conditions, sum a Rs. 24,80,911/- claimed to 5 ITA 312/JP/2015_ Prateek Kothari Vs ACIT have been received as advance, had not been provided inasmuch as only Rs. 12.51 lacs was remaining to be paid as on 10/3/2007 whereas the appellant received total sum of Rs. 31.65 lacs. It is submitted by the assessee before the ld CIT(A) that the appellant had received Rs. 21,80,911/- from the company namely M/s Nakshatra Real Estates Developers Pvt. Ltd. in which the appellant is director and having shareholding of 50% was not the loan amount but it represented advance received on account of sale agreement of 2 plots which M/s Nakshatra Real Estates Developers Pvt. Ltd. has to purchase from the assessee and this being a business transaction, therefore, it was not to be covered U/s 2(22)(e) of the Act. The ld CIT(A) also considered the various other documents including the copy of the letter received from JDA, Jaipur dated 07/6/2006 addressed to appellant. It is noted that the appellant had paid and received amount from M/s Nakshatra Real Estates Developers Pvt. Ltd. on regular basis. It is found from the copy of account in the books of the company that initially the assessee paid on 09/10/2006 Rs. 31.75 lacs and Rs. 30.00 lacs to M/s Nakshatra Real Estates Developers Pvt. Ltd. and in subsequent period of financial year 2006-07 from 08/11/2006 to 30/12/2006 the appellant had received total amount of Rs. 93.40 lacs from the company of different dates. On 27/3/2007, again the appellant had 6 ITA 312/JP/2015_ Prateek Kothari Vs ACIT paid Rs. 1,01,000/- to the company, therefore, transaction with the company cannot be said to be wholly related to the sale transactions of the plots. In other words, it is noted that the assessee had advanced loan and also received loans from M/s Nakshatra Real Estates Developers Pvt. Ltd. but the assessee was claiming that the amount received from 8/11/2006 to 30/12/2006 were not loans but were amount of advances received on account of the sale of two plots. However, such contention of the appellant prima facie does not appear to be genuine inasmuch as, as per this agreement the two plots which were to be sold to M/s Nakshatra Real Estates Developers Pvt. Ltd. were never sold and the transaction was never materialized. Moreover, it may also be noted that in the letter dated 07/6/2007 written by the JDA, Jaipur to the assessee there is a reference of their letter dated 20/11/2006 through which the JDA has informed to the assessee that the plot No. C-55 and C-56 cannot be regularized as there was illegal construction on such plots. This fact indicates that these two plots were not of saleable plots as per the JDA norms and even after such letter dated 20/11/2006 the assessee has received substantial amount of Rs. 53.50 lacs from 23/11/2006 to 30/12/2006 from M/s Nakshatra Real Estates Developers Pvt. Ltd.. When both the plots were not saleable why the company would make payment to the assessee. All the 7 ITA 312/JP/2015_ Prateek Kothari Vs ACIT facts of the transaction established that these payments were regular loans. When the assessee noticed this fact that loan taken from the company is a violation of Section 2(22)(e) of the Act then he made attempt to show that these payments were for sale of two plots. Therefore, he confirmed the addition U/s 2(22)(e) of the Act at Rs. 24,80,911/- up to reserve and surplus. However, outstanding loan against the assessee was on closing date at Rs. 30.64 lacs.
4. Now the assessee is in appeal before us. The ld AR of the assessee has submitted that he has raised a technical ground as there was a search and notice U/s 153A was given to the assessee to complete the assessment but finally no addition was made on account of incriminating documents, therefore, other addition made by the assessee is not allowable in case of search U/s 153A of the Act. Being a technical ground is allowable as held by the Hon'ble Supreme Court in the case of National Thermal Power Co. Ltd. Vs CIT (1998) 229 ITR 0383. He further relied on the decision of Hon'ble Jurisdictional High Court in the case of Zakir Hussain Vs. CIT & Anr. (2006) 202 CTR (Raj) 40 wherein the Hon'ble High Court has held that additional ground is to be allowed, which had a bearing on correct determination of tax liability on the ground of limitation.
8 ITA 312/JP/2015_ Prateek Kothari Vs ACIT Various other case laws also referred. After considering both the parties on this issue, we deem fit to allow the additional ground being a technical. 4.1 The ld AR of the assessee has also submitted that the assessee filed return U/s 139(1) on 26/10/2007 and the ld Assessing Officer could have issued notice by 30/09/2008 U/s 143(2) of the Act. In this case, search was conducted on 06/5/2010, therefore, the Assessing Officer issued notice on 2/11/2011 U/s 153A read with Section 143(2) of the Act. During the course of search, no incriminating documents were found, therefore, no notice can be issue U/s 153A read with Section 143(2) of the Act because no proceeding was pending before the Assessing Officer. The ld Assessing Officer made addition on the basis of entries recorded in the audited books of account of the assessee. There was no evidence found during the course of search that the assessee had received loan from M/s Nakshatra Real Estates Developers Pvt. Ltd.. The scope of Section 153A is limited to an assessment made on the basis of incriminating document found and seized during the course of search. The ld Assessing Officer made addition in routine manner without referred any seized material or incriminating documents. The assessment for the year under consideration had attended the finality. The assessment completed in the impugned assessment year will not get abated. He further relied on the decision of 9 ITA 312/JP/2015_ Prateek Kothari Vs ACIT Hon'ble ITAT, Jaipur Bench, Jaipur in the case of M/s Jadau Jewellers & Manufacturers Pvt. Ltd. in ITA No. 686/JP/2014 dated 14/12/2015 wherein identical issue has been considered by the Hon'ble Bench and the order U/s 153A read with Section 143(3) as held void ab-initio. He further relied various decisions on this issue as under:-
a) CIT V/s Smt. Shaila Agarwal, 204 Taxman 276
(Allahabad High Court)
b) Vishal Dembla Vs Deputy Commissioner of Income Tax
ITAT, JODHPUR BENCH ITA Nos. 304 to 308/Jd/2013; 22nd July, 2013 (2013) 93 DTR (Jd)(Trib) 1 (2013) 36 CCH 484 JodhTrib (2014) 61 SOT 10 (Jodhpur)(URO).
c) Marigold Merchandise (P) Ltd Vs Deputy Commissioner
of Income Tax ITAT Delhi ITA Nos. 2666 &
2667/Del/2013 27th December, 2013 (2013) 38 CCH 050 Del Trib.
d) Gurinder Singh Bawa v. DCIT (2012) 28 Taxmann.com 328 (Mum trib)
e) Kusum Gupta v. DCIT, ITA Nos. 4873/Del/2009, (2005-
06) 2510 (A.Y. 2003-04), 3312(A.Y. 2004-05) 2833/Del/2011 (A.Y. 2006-07).
f) MGF Automobiles Ltd. V. ACIT, ITA No's 4212 &
4213/Del/2011 (ITAT Delhi)
g) Tarannum Zafar Khan Vs. ACIT, ITA Nos. 5888 to
5890/Mum/2009 Hon'ble ITAT Mumbai held that:-
h) Vee Gee Industrial Enterprises vs. ACIT, ITA No. 1/Del/2011 & ITA No.2/Del/2011 (ITAT Delhi) 10 ITA 312/JP/2015_ Prateek Kothari Vs ACIT
i) ITA Nos. 1153 to 1159/Hyd/2012 Mir Mazharuddin, 24.1.2013 (ITAT Hyderabad).
j) Asha Kataria, I.T.A. Nos. 3105, 3106 & 3107/Del/2011 20.5.2013 Hon'ble ITAT Delhi Held that:-
k) Natvar Parikh & Co Pvt Ltd Vs Deputy Commissioner of Income Tax (ITAT MUMBAI) ITA No. 2143/Mum./2009, 2144/Mum./2009 & 2145/Mum./2009 22nd January, 2014 (2014) 39 CCH 031 MumTrib.
5. The ld CIT DR has vehemently supported the of the ld CIT(A) and argued that in the assessee's group cases, number of incriminating documents as well as unrecorded assets were found and seized as the Assessing Officer has mentioned in the assessment order itself showed that during the course of search, incriminating documents and unrecorded assets were found. Therefore, the ld Assessing Officer had rightly issued notice U/s 153A of the Act. Further the technical ground had not raised before the ld Assessing Officer. Otherwise the ld Assessing Officer should have referred the incriminating documents with him for this technical ground as such this technical ground has also not been raised before the ld CIT(A). Therefore, the technical ground raised by the assessee is deserved to be dismissed.
6. We have heard the rival contentions of both the parties and perused the material available on the record. It is undisputed fact that the return 11 ITA 312/JP/2015_ Prateek Kothari Vs ACIT U/s 139(1) of the Act was filed on 26/10/2007 by the assessee. As per law, notice U/s 143(2) could be issued on or before 30/09/2008. There was a search and seizure in this group on 06/5/2010. The ld Assessing Officer issued notice U/s 153A read with Section 143(2) of the Act on 02/11/2011. It is evident from the assessment order that no addition was made by the Assessing Officer on the basis of incriminating documents found during the course of search except some regular additions. Technical ground can be raised at any stage before the ITAT even before the Hon'ble High Court if it goes to the root of the matter and to assess the correct income of the assessee. It is a fact that on time for selection of the case for scrutiny had already been elapsed and no proceedings were pending before the Assessing Officer. Therefore, the proceedings for the year under consideration were not abated. This issue has been considered by the various ITATs as well as Hon'ble High Courts. It has been held that assessment U/s 153A read with Section 143(3), the ld Assessing Officer has to assess the income in abated year only where incriminating documents were found and seized and no regular addition can be made under this section as the Coordinate Bench has decided this identical issue in the case of M/s Jadau Jewellers and Manufacturers P. Ltd. (supra) wherein it has been held that technical ground raised by the assessee 12 ITA 312/JP/2015_ Prateek Kothari Vs ACIT succeeds and order passed U/s 153A read with Section 143(3) of the Act has been held void ab-initio. The other case laws referred by the assessee is also squarely applicable. Therefore, we have considered view that assessment made by the Assessing Officer U/s 153A read with Section 143(3) of the Act is out of jurisdiction. Accordingly, we allow the assessee's appeal on this ground.
7. On merit, the ld AR of the assessee has submitted that the assessee as well as the company are in real estate business. During the year under consideration, the company namely M/a Nakashatra Real Estates Developers Pvt. Ltd. sold its land and was planning to investment the sales consideration in some other land/property, therefore the company entered into an agreement dated 08.11.2006 with the assessee to buy plots No. 55 and 56 in the Scheme No. 1C, Lal Kothi, Tonk Road, Jaipur from the assessee. As per terms and conditions of the agreement, both the plots were sold to company for Rs. 50,01,000/- and advance of Rs. 25,00,000/- was paid at the time of signing the agreement, Rs. 12,50,000/- was to be paid within four months from signing the agreement and balance amount of Rs. 12,51,000/- was to be paid after conversion of land for commercial purpose and at the time of execution of registered sales deed. As per terms and conditions of agreement the conversion of land for commercial 13 ITA 312/JP/2015_ Prateek Kothari Vs ACIT purpose was to be completed within six month from signing the agreement and in case the assessee failed to do so, the deal deemed to be cancelled and the assessee had to return all the advances received from company. The assessee did not receive the second installment of Rs. 12,50,000/- in full from the company within four months of the agreement as stipulated in the agreement. Due to some legal technicalities the assessee could not get the conversion of the land in commercial and obtained the JDA patta of this plot, therefore the deal with company stand cancelled and the assessee returned back the advance received from company in the month of May-June, 2007. Thus the amount received by the assessee from the company was against the purchase of plot from the assessee. He has further drawn our attention from the copy of account, which shows that initially the assessee has given amount to the company on 09/10/2006 Rs. 31,75,000/- and on 10/10/2006 Rs.30,00,000/-. Thereafter, the assessee received refund of Rs. 40 lacs from the company out of the earlier advances made to the company. On 09-11-2006, the assessee received Rs. 25,00,000/- against the agreement to sale of two plots to the company. He has further drawn our attention on page No. 80 of the paper book and argued that there was correspondence with JDA for conversion of land for both the plots which were sold to the company. The assessee made full 14 ITA 312/JP/2015_ Prateek Kothari Vs ACIT efforts to convert two plots into commercial but they could not get converted. The assessee made another application for reconstitution of plot on 19/5/2007, which was also rejected on 07/6/2007. The ld CIT(A) held that there was no saleable value of the plot and is also without any basis even disputed property has its saleable value in the market. Therefore, this observation is made by the ld CIT(A) without any basis. The assessee also ppurchased these plots through registered sale deed which has been declared in the closing stock by the assessee, which has been accepted by the department. He further argued that expression used in Section 2(22)(e) is advanced or loan which has been considered by the Hon'ble ITAT, Agra Bench in the case of Shri Krishan Murari Lal Agarwal Vs DCIT 2013 (9) TMI 445 wherein it has been held that in ordinarily means payment of cash or transfer of goods for which accounting must be referred by the recipient at some later date. The transaction of loan involves lending the delivery by one party and receipt by another party of sum money upon express or implied agreement to repay it with or without interest. If such loan or advance is given to such shareholder as a consequence of any further consideration, which is beneficial to the company received from a shareholder, in such case, such advance or loan cannot be said to a deemed dividend within the meaning of the Act. He 15 ITA 312/JP/2015_ Prateek Kothari Vs ACIT further argued that trade advances which are in the nature of money transacted to give effect to a commercial transaction would not fall within the ambit of the provisions of S. 2(22)(e) of the Act. For which he relied on the decision of Hon'ble Delhi High Court in the case of CIT V/s Raj Kumar 318 ITR 462 (Delhi). He further argued that the Hon'ble Delhi High Court in the case of CIT Vs. Creative Dyeing and Printing Pvt. Ltd. (2009) 318 ITR 476 wherein it has been held that advances for commercial purposes i.e. fund received for expansion of production capacity from the company transaction was held as business transaction and not covered U/s 2(22)(e) of the Act. He further relied on the following decisions.
(i) The Hon'ble MP High Court in the case of CIT Vs. Om Prakash Suri (No.2) 359 ITR 41.
(ii) The Hon'ble Chennai Bench of ITAT in the case of ACIT V Smt. G. Sreevidya 138 ITD 427.
(iii) The Hon'ble Calcutta High Court in the case of Pradip Kumar Malhotra V CIT 338 ITR 538.
(iv) Hon'ble Delhi High Court in the case of CIT Vs. Ambassador Travels P. Ltd. [2009] 318 ITR 376 (Delhi)
(v) In the case of CIT V Arvind Kumar Jain 2011-TIOL-790- HC-Del-II
(vi) 2016 (1) TMI 84 Gujarat High Court CIT Vs Schutz Disman Bio Tech Pvt Ltd.
16 ITA 312/JP/2015_ Prateek Kothari Vs ACIT
(vii) 2015 (12) TMI 763 ITAT Delhi ACIT Vs Ashok Kumar Garg.
(viii) 2015 (12) TMI 1371 ITAT Mumbai ACIT Vs Smt Dina Sudhir Shah.
(ix) Jaipur Bench of Hon'ble ITAT in the case of Shri Ashok Kumar Agarwal ITA No 810/JP/2014 order dated 04-03- 2016.
Therefore, the advances made by the company to the assessee were for the purposes of business and not covered U/s 2(22)(e) of the Act. Therefore, order of the ld CIT(A) is deserved to be deleted.
8. At the outset, the ld CIT DR has vehemently supported the order of the ld CIT(A) and argued that the assessee make believe theory not to make provisions of Section 2(22)(e) of the Act applicable. All the facts have been given by the ld CIT(A) in his appeal order clearly indicates that the assessee's agreement to sale with the company is an afterthought, therefore, he prayed to confirm the order of the ld CIT(A).
9. We have heard the rival contentions of both the parties and perused the material available on the record. It is undisputed fact that the assessee as well as the company are in the real estate business. In initially, the assessee had advanced money of Rs. 31,75,000/- on 09/10/2006. Thereafter Rs. 30.00 lacs on 10/10/2006.
17 ITA 312/JP/2015_ Prateek Kothari Vs ACIT Thereafter, he received back amount of Rs. 40.00 lacs on 08/11/2006 on 09/11/2006. The assessee received Rs. 25.00 lacs which includes assessee's outstanding amount of Rs. 21.75 lacs partly against the agreement to sale of two plots i.e. Rs. 3.35 lacs. Thereafter the assessee received Rs. 15.00 lacs on 23/11/2006, Rs. 10.00 lacs on 07/12/2006, Rs. 2.00 lacs on 08/12/2006, Rs. 1.00 lac on 12/12/2006 and Rs. 40,000/- on 30/12/2006. Thus, total amount received from the company against the plots at Rs. 31.65 lacs up to 30/12/2006. Thereafter again the assessee paid Rs. 1,01,000/- to the company on 26/3/2007. The copy of accounts shows that the assessee and company as regular transaction and appears to be current account maintained by both. Finally the assessee has liability against the company at Rs. 30.64 lacs as on 31/3/2007. It is fact that there was an agreement to sale between the assessee and the company dated 08/11/2006, which has been notarized on 08/11/2006, shows that the assessee and company made agreement to sale two plots bearing No. 55 and 56, scheme No. 1C of Lal Kothi, Tonk Road, Jaipur for a consideration of Rs. 50,01,000/-. The assessee has received Rs. 25.00 lacs vide cheque No. 000405 drawn on bank of Punjab at the time of singing of agreement and 25% was to receive within four months from the date of signing of the agreement. Remaining amount of Rs. 12,51,000/- was to receive after 18 ITA 312/JP/2015_ Prateek Kothari Vs ACIT issue of JDA Patta and conversion of land for commercial purposes and at the time of execution of registered sale deed. The ld Assessing Officer as well as the ld CIT(A) has doubted the transaction but it is a fact that in real estate most of the transactions are being made on the basis of agreement to sale and to avoid the stamp duty payment. In real estate business number of transactions of purchase and sale of the plots are being made and stamp duty finally is to be borne by the actual user of the plot at the time of registration. Therefore, generally the transactions made on agreement to sale basis. It is also a fact that this transaction was in between director of the company and company even as per this agreement, the assessee has to make registry of both the plots at the time of final conversion and allotment of Patta. The correspondence between the assessee and the JDA shows that there was efforts to convert the land commercially and get the patta from the JDA, which cannot be doubted. The assessee relied on various decisions on deemed dividend wherein it has been held that loan advances given against the consideration are business transactions not deemed dividend U/s 2(22)(e) of the Act. Therefore, we held that the transaction made between the assessee and the company are business transactions and is not covered U/s 2(22)(e) of 19 ITA 312/JP/2015_ Prateek Kothari Vs ACIT the Act. Accordingly, we reverse the order of the ld CIT(A) and appeal of the assessee is allowed.
10. In the result, the assessee's appeal is allowed.
Order pronounced in the open court on 15/6/2016.
Sd/- Sd/-
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(R.P.Tolani) (T.R. Meena)
U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member
Tk;iqj@Jaipur
fnukad@Dated:- 15th June, 2016
*Ranjan
vkns'k dh izfrfyfi vxzsf'kr@Copy of the order forwarded to:
1. vihykFkhZ@The Appellant- Shri Prateek Kothari, Jaipur.
2. izR;FkhZ@ The Respondent- The ACIT, Central Circle-2, Jaipur.
3. vk;dj vk;qDr@ CIT
4. vk;dj vk;qDr@ CIT(A)
5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur
6. xkMZ QkbZy@ Guard File (ITA No. 312/JP/2015) vkns'kkuqlkj@ By order, lgk;d iathdkj@Asst. Registrar