Income Tax Appellate Tribunal - Jaipur
Acit, Jaipur vs Arpit Marbles Pvt. Ltd., Jaipur on 16 December, 2016
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IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR
Jh dqy Hkkjr] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k
BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YADAV, AM
vk;dj vihy la-@ITA No. 320/JP/2016
fu/kZkj.k o"kZ@Assessment Year : 2011-12
A.C.I.T., cuke M/s Arpit Marbles Pvt. Ltd.,
Circle-5, Vs. C-146-147, Road No. 9, VKI
Jaipur. Area, Jaipur.
LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AACCA 0145 P
vihykFkhZ@Appellant izR;FkhZ@Respondent
izR;k{[email protected]. No. 06/JP/2016
(Arising out of vk;dj vihy la-@ITA No. 320/JP/2016)
M/s Arpit Marbles Pvt. Ltd., cuke A.C.I.T.,
C-146-147, Road No. 9, VKI Area, Vs. Circle-5,
Jaipur. Jaipur.
LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AACCA 0145 P
izR;k{ksid@Objector izR;FkhZ@Respondent
vk;dj vihy la-@ITA No. 705/JP/2016
fu/kZkj.k o"kZ@Assessment Year : 2011-12
M/s Arpit Marbles Pvt. Ltd., cuke A.C.I.T.,
C-146-147, Road No. 9, VKI Area, Vs. Circle-5,
Jaipur. Jaipur.
LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AACCA 0145 P
vihykFkhZ@Appellant izR;FkhZ@Respondent
2 ITA 320 & 705/JP/2016 & CO 06/JP/2016_
ACIT Vs. M/s Arpit Marbles
jktLo dh vksj ls@ Revenue by : Mrs. Neeja Jeph (JCIT)
fu/kZkfjrh dh vksj l@
s Assessee by : Shri Manish Agarwal (CA)
lquokbZ dh rkjh[k@ Date of Hearing : 30/11/2016
mn?kks"k.kk dh rkjh[k@ Date of Pronouncement : 16/12/2016
vkns'k@ ORDER
PER: KUL BHARAT, J.M. ITA No. 320/JP/2016 filed by the revenue and C.O. No. 06/JP/2016 filed by the assessee arise against the order dated 29/01/2016 passed by the ld. CIT(A)-2, Jaipur for the A.Y. 2011-12. It is also pertinent to mention here that ITA No. 705/JP/2016 filed by the assessee is against the rectification order dated 25/05/2016 passed by the ld. CIT(A)-2, Jaipur for the A.Y. 2011-12, wherein the grounds of appeal taken by the revenue as well as the assessee are as under:-
Grounds of revenue's appeal in ITA No. 320/JP/2016.
"(i) Whether on the facts and in the circumstances of the case and in law, the CIT(A), has erred in deleting the trading addition of Rs.341546/- as made by A.O. on account of valuation of closing stock.
(ii) Whether on the facts and in the circumstances of the case and in law, the CIT(A), has erred in deleting the disallowance of interest of Rs. 35,93,757/- as made by A.O. on account of interest free advance to sister concern.
(iii) a) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT is justified 3 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles in deleting addition of Rs. 80374/- made by A.O. for depositing the employees contribution to PF & ESI beyond the prescribed time limit provided in the respective Acts.
b) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT is justified in holding that employees contribution to PF & ESI are governed by the provisions of section 43B and not by section 36(1)(va) r.w.s. 2(24)(x) of I.T. Act.
Grounds of assessee's C.O. No. 06/JP/2016.
"(i) On the facts and in the circumstances of the case, the ld. CIT(A) erred in confirming the disallowance @ 10% out of following expenses claimed in Profit and Loss account, which was made by ld. A.O. alleging the same as incurred for non business purposes:
S. Particulars Amount % of Disallowance
No. disallowance
1. Telephone Exp 49369.00 10% 4,937.00
2. Vehicle repairs 3,56,729.00 10% 35,673.00
& maintenance
Exp.
3. Staff welfare 51,345.00 10% 5,134.00
exp.
4. Travelling Exp. 11,605.00 10% 1,160.00
46,904.00
Disallowance so made, were without proving a single instance of non business purposes, thus same deserves to be hold bad on law as well as on facts more particularly when the appellant is a private limited company having separate legal entity."
4 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles Grounds of assessee's appeal in ITA No. 705/JP/2016.
"1. On the facts and in the circumstances of the case and in law, Ld. CIT(A) erred in passing rectification order on the basis of an afterthought, which could not be treated as mistake apparent from record and hence not a rectifiable mistake covered by section 154 of the Income Tax Act. Thus, the order passed u/s 154/250 may please be held as bad in law.
2. Without prejudice to above and in the alternative, on the facts and in the circumstances of the case and in law, Ld. CIT(A) erred in passing order u/s 154/250 of the Act, confirming the disallowance of interest on advances made to Andhi Marbles Pvt. Ltd. (AMPL) during the year ignoring the fact that the same was under business and commercial expediency and in the nature of trade advance. Appellant prays the disallowance so made may please be held as bad in law.
2.1 On the facts and in the circumstances of the case and in law, Ld. CIT(A) erred in confirming the disallowance of interest on advances made to AMPL during the year without considering the fact that assessee company had sufficient interest free funds in the shape of Share Capital and Reserves & Surplus to the extent of Rs.2,95,98,400/- and interest free unsecured loans of Rs.4,26,30,961/- from directors & their relatives (aggregating to Rs.7,22,29,361/-), which were utilized for the purpose of making advance to AMPL, thus no disallowance is called for. Appellant prays the disallowance made may be held as bad in law.
5 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles
2. Both the appeals and C.O. are being heard together and for the sake of convenience and brevity, a common order is being passed.
3. At the time of hearing, the ld AR of the assessee has submitted that the issues involved in these appeals and C.O. are covered by the decision of the Hon'ble ITAT, Jaipur Benches in assessee's own case for the A.Y. 2010-11 passed in ITA No. 203 & 704/JP/2016 and C.O. 05/JP/2016 order dated 31/10/2016. Therefore, he prayed that issues may be decided in the light of the Hon'ble ITAT's order passed in the assessee's own case for A.Y. 2010-11.
4. At the outset, the learned D.R. has vehemently supported the assessment order, but conceded the fact that the issues involved in the appeals are covered by the order of the Hon'ble ITAT passed in assessee's own case for A.Y. 2010-11.
5. We have heard the rival contentions of both the parties, perused the material available on the record as well the order passed by the Coordinate Bench in the case of assessee itself. We find that the issue related to trading addition i.e. ground No. 1 of the revenue's appeal and the issue related to the disallowance of interest i.e. ground No. 2 of the revenue's appeal have been decided by the Coordinate Bench in 6 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles assessee's own case in ITA No. 203 & 704/JP/2016. The finding of the Coordinate Bench is reproduced hereunder:-
"4.3. We have heard rival contentions, perused the material available on record and gone through the orders of the authorities below. We find that the ld. CIT (A) has decided this issue by following the order of the Coordinate Bench of the Tribunal in the assessee's own case for the assessment year 2006-07 by observing in para 2.3 of his order as under :-
"2.3. I have perused the facts of the case, the assessment order and the submissions of the appellant. The fact of this issue is similar to the fact of the assessee's own case for the assessment year 2006-07, wherein the Hon'ble ITAT (appeal No. ITA No. 96/JP/2010) decided this issue in favour of the assessee. My predecessor for A.Y. 2007- 08 in the assessee own case also ordered in the favour of the assessee. Since, the facts are identical and issue is covered therefore, following the above decisions, the disallowance on account of valuation of closing stock made by the Assessing Officer is directed to be deleted. This ground is allowed."
Respectfully following the decision of Coordinate Bench in the assessee own case in ITA No. 96/JP/2010, we uphold the order of ld. CIT (A). This ground of the revenue is dismissed.
5.3. We have heard rival contentions, perused the material available on record and gone through the orders of the authorities below. We find that the ld. CIT (A) has decided this issue by following the order of the Coordinate Bench of the Tribunal in the assessee's own case in ITA No. 96/JP/2010 for the assessment year 2006-07. We also find that the Coordinate Bench of the Tribunal vide its order dated 11.02.2016 in assessee's appeal in 7 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles ITA No. 648/JP/2014 has decided the identical issue by observing in para 1.4 of its order as under :-
"1.4 We have heard the rival contentions and perused the material available on record. The AO noted that the assessee has given additional interest free advances of Rs. 1,44,67,000/- during the year to M/s AMPL. Further no purchases have been made either against opening debit balance of Rs. 1,58,04,153/- or against the additional advances given to M/s AMPL during in the year. The AO further observed that the assessee company has taken loans from financial institutions such as SIDBI, RFC, ICICI bank, Bank of Rajasthan Ltd, etc. and the nexus between the loan taken and advances given to sister concern is also established as loans raised from these institutions in turn transferred to M/s AMPL.
1.5 It is noted that during the year under consideration, the assessee company has debited a sum of Rs. 1,22,42,655/- towards interest expense in his profit and loss account. Out of this, the AO disallowed a sum of Rs. 37,28,395/- being interest at the rate of 15% paid to the financial institutions. The Ld. CIT(A) confirmed the findings of the AO that the nexus has been established between the loans taken from financial institutions and advances given to M/s AMPL. However, there is no discussion as to how such a nexus has been established which we could gather from the order of AO and ld CIT(A). Further the ld. CIT(A) held that no purchases have been made from M/s AMPL during the year and inspite of opening debit balance of Rs. 1,58,04,153/-, further advances have been made to it leaving a closing debit balance of Rs. 4,40,07,213/- which does not indicate that advance given during the year was based on any commercial expediency. Ld CIT(A) accordingly upheld the disallowance of interest on advances given to M/s AMPL during the year under consideration. At the same time, in respect of interest payment on the opening debit balance of advances, following order of the Co-ordinate Bench for A.Y, 2006-07 and 2007-08, necessary relief was given to the assessee.
1.6 It is noted from the perusal of the audit report where the auditors have observed that the company has incurred cash losses during the Financial Year covered by our audit and have incurred cash losses during the immediately preceding financial year, which has resulted in accumulated losses to the tune of Rs.
8 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles 2,42,55,443/- as on 31.03.2009 which effectively wipes out the share capital of 2,41,06,500/- leaving aside an amount of Rs. 54,91,900/- in the reserve and surplus account. Further, from the perusal of the notes to the financial statement of the assessee, it is noted that there are transactions which have been carried out during the year in terms of purchase of marble blocks amounting to Rs. 60,51,457/- and sale of marble slabs and tiles amounting to Rs. 55,15,779/-to M/s AMPL.
1.7 Firstly, regarding nexus which the AO and the Ld. CIT(A) has held to have been established between the amount borrowed from the financial institutions and advances given to M/s AMPL, it is unclear as to how such an nexus has been established by merely stating that the cheques have been issued to M/s AMPL from the cash credit account of the assessee maintained with Bank of Rajasthan Ltd. It is unclear whether at the time of issuing cheques and making payment to M/s AMPL, there was a debit or a credit balance in the cash credit account. It is likely that there are sales realization and other deposits received by the assessee prior to making such advances to M/s AMPL and out of which such advances have been paid. Here, what needs to be examined is at the point of time when the funds were actually advanced to M/s AMPL, what was the position of funds actually available with the assessee in terms of the borrowed funds to establish the necessary nexus. In absence of such a finding, it cannot be said that the nexus has been established between the borrowings from the financial institutions and advances to AMPL.
1.8 Secondly, where a nexus has not been established between the borrowings and the interest free advances, the Courts have held that where the assessee has sufficient interest free funds available in the form of share capital reserves and surplus, no disallowance of interest can be made where the assessee establishes the commercial expediency behind giving such advances. The assessee have taken this alternate contention and let's examine the same in the context of facts before us. In the instant case, we have noted above that in view of the consistent cash loss position of the assessee, the accumulated losses have almost wipes off entire share capital leaving side a sum of Rs. 54,91,900/- which is a minuscule number as against the additional advances of Rs. 12,44,67,000/- made by the assessee to M/s AMPL. Therefore, it cannot be said that the advances have been made out of share capital and free reserves 9 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles and surplus and the contention of the ld AR to this extent cannot be accepted. The ld AR has further submitted that the assessee company has interest free funds in the form of unsecured loan of Rs. 2.58 crores taken from Director and relatives on which no interest was given by the appellant and out of such interest free funds, the advances were given to M/s AMPL. Here again, what needs to be examined (which is not apparent from the records) is that at the point of time when the funds were actually advanced, what was the position of interest free funds actually available with the assessee in the form of cash and bank deposits and how the same has been dispersed to M/s AMPL to establish the necessary nexus as claimed by the ld AR.
1.9 Lastly, regarding the test of commercial expediency, the assessee has submitted that it is engaged in the manufacturing and producing of marble slabs which have been made from the marble blocks. The mining of the blocks from the mines owned by the assessee company was very low due to closer of mines and majority of raw material was purchased from the mines owned by sister concern M/s AMPL and payment was made in advance which is in the nature of business advances and thus no disallowance of interest paid on borrowed funds should be made. It is submitted that it is under such business expediency, the advance payments were made towards purchase of raw material and the same cannot be tagged as interest free funds given for non-commercial purposes. It was further submitted that under similar facts pattern, the Co-ordinate Bench of ITAT in assessee's own case for AYs 2006-07 and 2007-08 has deleted the disallowance of interest in the hands of the assessee. We have gone through the order of Co-ordinate Bench for AY 2006- 07 and noted the following findings of the Co-ordinate Bench:
"We have considered the arguments of both the parties and have perused the material available on record. The contention of the assessee that it had business relationship with the sister concern is a fact proved from the records as the AO in the assessment order have admitted that during the year under appeal the assessee had received goods of Rs. 28,77,791/- from its sister concern M/s Andhi Marble Pvt. Ltd. The contention of the assessee that there is no diversion of the funds and the circumstances explaining the business expediency having arisen due to closer of its marble mining area also inspires confidence and prove the necessity of acquiring raw material of the nature 10 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles of marble blocks required to keep its marble cutting establishment running."
1.10 In this regard, the ld. CIT(A) has noted that during the year under consideration, there are no purchases made by the assessee from M/s AMPL hence the alleged decision of Co- ordinate Bench are distinguishable on facts. As we have noted above, there are transactions which have been carried out during the year in terms of purchase of marble blocks amounting to Rs. 60,51,457/- and sale of marble slabs and tiles amounting to Rs. 55,15,779/-to M/s AMPL. However, at the same time, there is an opening balance of Rs. 1,58,04,153/- against which no purchases have been reflected during the year except for Rs 60,51,457/-. Further there is an additional advance of Rs. 1,44,67,000/- which has been made during the year. Nothing has been brought on record in terms of basis of advancing such huge amount to sister concern year on year basis in absence of any corresponding purchases either in the year under consideration or in subsequent years. It is true that the Courts cannot sit in judgement to decide the quantum of advances and the terms and conditions of such advances. At the same time, the assessee has to demonstrate through its conduct and appropriate documentation in order to satisfy the test of commercial expediency which apparently has not been done in the instant case. In this regard, we refer to the decision of Hon'ble Supreme Court in case of S.A. Builders 288 ITR 1 where the Court have laid down the following proposition of law in respect of commercial expediency (head notes):
"The High Court and other authorities should have examined the purpose for which the assessee advanced the money to its sister concern, and what the sister concern did with the money, in order to decide whether it was for commercial expediency, but that had not been done. [Para 30] It is not in every case that interest on borrowed loan has to be allowed if the assessee advances it to a sister concern. It all depends on the facts and circumstances of the respective case. For instance, if the directors of the sister concern utilize the amount advanced to it by the assessee for their personal benefit, obviously it cannot be said that such money was advanced as a measure of commercial expediency. However, money can be said to be advanced to a sister concern for commercial expediency in many other circumstances. Where 11 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles holding company, has a deep interest in its subsidiary, and the holding company advances borrowed money to a subsidiary and the same is used by the subsidiary for some business purposes, the holding company would ordinarily be entitled to deduction of interest on its borrowed loans. [Para 35]"
1.11 Considering the entirety of facts and circumstances of the case and in light of Hon'ble Supreme Court in case of S.A. Builders 158 Taxmann 74 , in our view, the contention of both sides needs to be adequately demonstrated through appropriate documentation and in absence thereof, the matter require further examination and we accordingly set-aside this issue to the file of the AO to examine the same afresh after giving reasonable opportunity to the assessee."
The issue involved in this appeal is identical to ground raised in ITA No. 648/JP/2014 for the immediately preceding year 2009-10 wherein the Coordinate Bench while dealing with the issue, placing reliance on the judgment of Hon'ble Supreme Court rendered in the case of S.A. Builders, 158 Taxmann 74 (SC), set aside the order of ld. CIT (A) and restored the matter to the file of A.O. for deciding the matter afresh. In the present case, considering the entirety of facts and circumstances of the case and in the light of judgment of Hon'ble Supreme Court (supra), it will be appropriate to examine the matter in detail thereby affording opportunity to both the parties to prove their contentions. Therefore, respectfully following the decision of Coordinate Bench in the assessee's own case in ITA No. 648/JP/2014, we set aside the order of ld. CIT (A) and restore the matter to the file of A.O. to be decided afresh after giving reasonable opportunity of being heard to the assessee. This ground of the revenue is allowed for statistical purposes.
The facts are identical as there is no change into the facts and circumstances as pointed out by the revenue, therefore by respectfully 12 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles following the decision of the Coordinate Bench in assessee's own case in ITA No. 203 & 704/JP/2016, ground No. 1 of the revenue's appeal is dismissed whereas ground No. 2 of the revenue's appeal is allowed for statistical purposes only.
6. Ground No. 3 of the revenue's appeal is against deletion of disallowance of contribution towards PF & ESI made by the A.O..
The ld. CIT(A) has deleted the addition by holding as under:-
"6.3 I have perused the facts of the case, the assessment order and the submissions of the appellant. Admittedly, employee's contribution to ESI and PF has been paid by the appellant, in all instances, before the due date of filing the return of income under section 139(1). This fact is therefore, not in dispute. In view of the judgments of the Rajasthan High Court in the case of Jaipur Vidhyut Nigam Ltd. 265 CTR 62 (Raj.), IT Vs SBBJ (2014) 99 DTR 131 (Raj), and other case laws on this issue, the claim of the appellant is allowable. Accordingly, the addition made by the Assessing Officer, is deleted. This ground is allowed."
6.1 Now the revenue is in appeal before us. The ld DR has supported the order of the Assessing Officer. At the outset, it is stated by the ld.
Authorized representative of the assessee that the issue is no more res 13 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles integra, has been settled by the decision of the Hon'ble Supreme Court in the case of CIT Vs Binay Cement 213 CTR 268 and the decision of the Hon'ble Jurisdictional High Court in the case of CIT Vs. SBBJ (2014) 99 DTR 131 (Raj).
7. We have heard the rival contentions of both the parties, perused the material available on the record and also gone through the orders of the authorities below. As the issue has been decided by the Hon'ble Jurisdictional High Court in the case of CIT Vs. SBBJ (supra), therefore, we do not see any reason to interfere into the order of the ld. CIT(A), accordingly, we affirm the order of the ld. CIT(A) on this ground. This ground of revenue's appeal is dismissed.
8. Now coming to the C.O. of the assessee i.e. C.O. No. 06/JP/2016 in ITA No. 320/JP/2016. It is stated by the ld. Counsel of the assessee that the issue under consideration in this C.O. is also covered by the decision of the Hon'ble ITAT, Jaipur Bench decision in the case of assessee itself in ITA No. 648/JP/2014 for the A.Y. 2009-10.
8.1 At the outset, the ld. DR has supported the order of the Assessing Officer.
14 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles
9. We have heard the rival contentions of both the parties, perused the material available on the record and also gone through the orders of the authorities below. We find that the Coordinate Bench of the Tribunal has decided this issue in assessee's own case for the A.Y. 2009-10 by observing as under:-
"2.2. We have heard the rival contentions and pursued the material on record. The AO has disallowed 10% of telephone, vehicle repair & maintenance and depreciation on car holding that these facilities are such that they can be used for other than business purposes. Further, 10% of staff welfare and travelling expenses have been disallowed holding that the expenses are not fully verifiable. In our view, these disallowances cannot be sustained in eye of law on ground of adhoc nature and secondly, the concept of personal use is alien to a corporate entity. In a corporate structure, the facilities are provided to employees as per terms of his / her employment and such facilities suffer the necessary perquisite taxation in hands of the employees. There is nothing on record which proves that the facilities have been used for personal purposes and secondly, they have escaped the perquisite taxation. Regarding disallowance of bonus, no basis has been given by AO to disallow the same. Hence, these disallowances are hereby deleted. Hence, these grounds are allowed."
15 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles Therefore, by respectfully following the order of Coordinate Bench in the assessee's own case referred above, the ground raised in the C.O. of the assessee is allowed."
10. Now we take assessee's appeal being ITA No. 705/JP/2016.
Ground No. 2 and 2.1 of the appeal is related to confirmation of the disallowance of interest. It is stated by the ld. AR of the assessee that the Hon'ble ITAT, Jaipur Bench in assessee's own case for the A.Y. 2009-10 has set aside this issue to the file of the Assessing Officer for fresh decision. Therefore, he prayed that this issue for the year under consideration may also be restored to the file of the Assessing Officer.
10.1 The ld. DR has no objection if the issue under consideration may be restored to the file of the Assessing Officer.
11. We have heard the rival contentions of both the parties, perused the material available on the record and also gone through the orders of the authorities below. We find merit in the submissions of the ld. AR of the assessee that in earlier year also, the issue is restored to the file of the Assessing Officer. Therefore, by following the decision of the Coordinate Bench, the issue under consideration is restored to the file of the Assessing Officer and we decided in terms of paragraph No. 5.3 of 16 ITA 320 & 705/JP/2016 & CO 06/JP/2016_ ACIT Vs. M/s Arpit Marbles the decision of the Coordinate Bench rendered in assessee's own case in ITA No. 203 & 704/JP/2016 for A.Y. 2010-11. Accordingly, the ground of appeal is allowed for statistical purposes only.
12. In the result, appeal of the revenue is partly allowed for statistical purposes, Cross Objection of the assessee is allowed and appeal of the assessee is also allowed for statistical purposes only.
Order pronounced in the open court on 16th December, 2016.
Sd/- Sd/-
¼foØe flag ;kno½ ¼dqy Hkkjr½
(Vikram Singh Yadav) (Kul Bharat)
ys[kk lnL;@Accountant Member U;kf;d lnL;@Judicial Member
Tk;iqj@Jaipur
fnukad@Dated:- 16th December, 2016
*Ranjan
vkns'k dh izfrfyfi vxzfs 'kr@Copy of the order forwarded to:
1. vihykFkhZ@The Appellant- The A.C.I.T., Circle-5, Jaipur..
2. izR;FkhZ@ The Respondent- M/s Arpit Marbles Pvt. Ltd., 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. 320 & 705/JP/2016 & CO 06/JP/2016) vkns'kkuqlkj@ By order, lgk;d iathdkj@Asst. Registrar