Income Tax Appellate Tribunal - Jaipur
Basant Bansal , Alwar vs Department Of Income Tax on 23 April, 2015
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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 Nos. 610 & 611/JP/2012
fu/kZkj.k o"kZ@Assessment Years : 2007-08 & 2008-09
D.C.I.T. cuke Basant Bansal,
Central Circle, Alwar. Vs. C-13, Sushant Lok-1, Gurgaon,
Haryana.
LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AHYPB 1937 A
vihykFkhZ@Appellant izR;FkhZ@Respondent
jktLo dh vksj ls@ Revenue by : Mrs. Rolee agarwal (CIT)
fu/kZkfjrh dh vksj ls@ Assessee by : Shri Rakesh Gupta &
Shri Milap Chaturvedi (Adv)
lquokbZ dh rkjh[k@ Date of Hearing : 06/04/2015
?kks"k.kk dh rkjh[k@ Date of Pronouncement : 23/04/2015
vkns'k@ ORDER
PER: T.R. MEENA, A.M. These are the appeals filed by the department against the order dated 30/03/2012 passed by the learned CIT(A), Central, Jaipur for A.Y. 2007-08 & 2008-09. The respective grounds of both the appeals are as under:-
2 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal Grounds in revenue's appeal ITA No. 610/JP/2012 "1(i) Whether on the facts and circumstances of the case of CIT(A) (Central), Jaipur has erred in law and on facts in holding that the amount of Rs. 25,25,000/- paid by M/s Mistry Meadows Pvt. Ltd. to M/s Benchmark Infotech Pvt. Ltd. where the assessee was holding 18.8% and 50% shares respectively, do not fall within the purview of section 2(22)(e) and thereby deleting the addition of Rs. 25,25,000/- made by the A.O. by invoking provisions of sec 2(22)(e) of the Act.
1(ii) Whether on the facts and circumstances of the case the CIT(A) (Central), Jaipur has erred in law and on facts in holding that the amount advanced by M/s Manglam Multiplex Pvt. Ltd., to M/s Benchmark Infotech Pvt. Ltd., where the assessee was one of the directors holding more than 10% shares respectively do not fall within the purview of section 2(22)(e) and thereby deleting the addition of Rs. 7,85,559/- representing 50% of the accumulated profit of P&L a/c.
Grounds in revenue's appeal ITA No. 611/JP/2012 "1(i) Whether on the facts and circumstances of the case of CIT(A) (Central), Jaipur has erred in law and on facts in holding that the amount advanced by M/s Mistry Meadows Pvt. Ltd. to M/s Martial Buildcon Pvt. Ltd., where the assessee was one of the directors holding more than 10% shares respectively do not fall within the purview of section 2(22)(e) and thereby deleting the addition of Rs. 13,76,629/-.
1(ii) Whether on the facts and circumstances of the case the CIT(A) (Central), Jaipur has erred in law and on facts in holding that the amount advanced by M/s Manglam Multiplex Pvt. Ltd., to M/s Martial Buildcon Pvt. Ltd. where the assessee was one of the directors holding more than 10% shares respectively do not fall 3 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal within the purview of section 2(22)(e) and thereby deleting the addition of Rs. 16,71,302/- representing 50% of the accumulated profit of P&L a/c.
1(iii) Whether on the facts and circumstances of the case the CIT(A) (Central), Jaipur has erred in law and on facts in holding that the amount advanced by M/s B&B Mercantile Pvt. Ltd., to M/s Martial Buildcon Pvt. Ltd. where the assessee was one of the directors holding more than 10% shares respectively do not fall within the purview of section 2(22)(e) and thereby deleting the addition of Rs. 40,23,050/- representing 50% of the total advance of Rs. 80,46,100/-.
2. In both the assessment years, the revenue is challenging the deleting addition of Rs. 25,25,000/- and Rs. 7,85,559/- in A.Y. 2007-08 and Rs. 13,76,629/- , 16,71,302/- and Rs. 80,46,100 in A.Y. 2008-09, the additions made U/s 2(22)(e) of the Income tax Act, 1961 (hereinafter referred as the Act) as deemed dividend. The ld Assessing Officer observed that from HDFC Book for the period 01/4/2006 to 31/3/2007 submitted alongwith reply dated 10/08/2010 during the course of assessment proceedings in the case of M/s Benchmark Infotech Pvt. Ltd. that an amount of Rs. 25.25 lacs had been received by it from M/s Misty Meadows Pvt. Ltd., which has been repaid on 22/03/2007. Shri Basant Bansal held 18.80% shares of M/s Misty Meadows (P) Ltd. and 50% shares of M/s Benchmark Infotech Pvt. Ltd. during the year 2006-07. Shri Basant Bansal held more than 10% 4 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal shares in M/s Misty Meadows (P) Ltd., which had given the loan and held more than 20% shares of M/s Benchmark Infotech Pvt. Ltd., which had received the advance. Accumulated profit on the M/s Misty Meadows (P) Ltd. as on 31/3/2007 was Rs. 1,85,91,329.39. Therefore, the amount of Rs. 25.25 lacs paid by M/s Misty Meadows (P) Ltd. to M/s Benchmark Infotech Pvt. Ltd. was considered to be dividend paid to Shri Basant Bansal in view of the provisions of Section 2(22)(e) of the Act. The ld Assessing Officer gave show cause notice on it, which was replied by the assessee and considered by him during the course of assessment proceedings. It was submitted before him that M/s Misty Meadows (P) Ltd. had share premium account, which was not available for any distribution to the company. The ld Assessing Officer found that accumulated profit as on 31/3/2007 under the head share premium account at Rs. 99,50,000/- and P&L account at Rs. 86,41,329.39. The share premium account remained constant, therefore, there was no question of advancing any amount from this account. During the year, the assessee held sufficient profit of M/s Misty Meadows (P) Ltd. and from which it had advanced Rs. 25.25 lacs to M/s Benchmark Infotech Pvt. Ltd.. The assessee also relied before the Assessing Officer a decision of Hon'ble ITAT, Mumbai Bench in the case of ACIT vs. 5 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal Bhaumik Colour Pvt. Ltd. (2009) 118 ITD 1 (Mum) (SB). As per the Assessing Officer's finding, the case law is not squarely applicable on the assessee's case as the assessee is a registered share holder in both the companies having minimum share holding as required by the law to be held deemed dividend U/s 2(22)(e) of the Act. He further relied on the decision in the case of CIT Vs. Hotel Hiltop, 313 ITR 116 of Hon'ble Rajasthan High Court wherein it has been held that deemed dividend would be deemed dividend in the hands of the beneficial owner and not the concern. The assessee's argument was also not found convincing to the Assessing Officer that so called loan and advance is not itself a loan but repayable on demand, the assessee's case is covered U/s 2(22)(e) of the Act. M/s Misty Meadows Pvt. Ltd. have accumulated profit of Rs. 86,41,329.39 other than share premium reserve of Rs. 99,50,000/-. As such case of the assessee is within the four corners of section 2(22)(e). Therefore, the amount of Rs. 25,25,000/- advanced by M/s Misty Meadows Pvt. Ltd. to M/s Benchmark Infotech Pvt. Ltd. was considered to be deemed dividend and made the addition of Rs. 25.25 lacs.
It is further held that Rs. 9 crores had been advanced by M/s Manglam Multiplex Pvt. Ltd. to M/s Benchmark Infotech Pvt. Ltd.. Shri 6 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal Basant Bansal held 74% shares of M/s Manglam Multiplex Pvt. Ltd. and 50% of M/s Benchmark Infotech Pvt. Ltd. during the year 2006-07. Similarly, Roop Bansal also held 12% of M/s Manglam Multiplex Pvt. Ltd. and 50% shares of M/s Benchmark Infotech Pvt. Ltd. during the said period. Both the persons held more than 10% shares each in M/s Manglam Multiplex Pvt. Ltd. and more than 20% shares in M/s Benchmark Infotech Pvt. Ltd., which had received the advance of Rs. 9 crores. Accumulated profit of M/s Manglam Multiplex Pvt. Ltd. as on 31/3/2007 was Rs. 2,11,71,118.50 against the amount of 9 crores paid by M/s Manglam Multiplex Pvt. Ltd. to M/s Benchmark Infotech Pvt. Ltd. was considered to be dividend paid to Shri Basant Bansal and Shri Roop Bansal in equal proportion in view of the provisions of Section 2(22)(e) of the Act. The Assessing Officer also sought clarification from the assessee, which has been availed by him. The identical reply was also submitted against this query by the assessee before the Assessing Officer. The assessee submitted that these are business transactions between the companies and cannot be treated as deemed dividend U/s 2(22)(e) of the Act. The assessee relied on the following case laws:-
(i) CIT Vs. Badiani P.K. (Bom) 076 ITR 369
7 ITA 610 & 611/JP/2012_
DCIT Vs. Basant Bansal
(ii) CIT vs. Rajkumar (Delhi High Court) 318 ITR 426 After considering the assessee's reply, the ld Assessing Officer held that accumulated profit was Rs. 15,71,118.50/- considered to be advanced by M/s Manglam Multiplex Pvt. Ltd. to M/s Benchmark Infotech Pvt. Ltd., which has been considered by the Assessing Officer for deemed dividend in the hands of the assessee and Shri Roop Bansal equally. Accordingly he made addition of Rs. 7,85,559/- U/s 2(22)(e) of the Act.
In A.Y. 2008-09, it was noticed by the Assessing Officer that in case of M/s Martial Buildcon Pvt. Ltd. that M/s Misty Meadows Pvt. Ltd had paid Rs. 8 crores to M/s Martial Buildcon Pvt. Ltd. on 08/3/2008, which has been paid back by M/s Martial Buildcon Pvt. Ltd. on 26/03/2008. Shri Basant Bansal held 34% of M/s Martial Buildcon Pvt. Ltd. and 18.80% shares of M/s Misty Meadows Pvt. Ltd. during the year 2007-08, which means that the assessee held more than 10% shares in M/s Misty Meadows Pvt. Ltd. which has extended the advance and held more than 20% shares of M/s Martial Buildcon Pvt. Ltd., the accumulated profit as on 31/3/2008 at Rs. 1,13,26,629.58/-. Accordingly, he treated the deemed dividend to the extent of accumulated profit in the hands of the assessee. A show cause notice 8 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal was given by the Assessing Officer to the assessee, which has been replied by him and considered by the Assessing Officer. The assessee submitted before the Assessing Officer that 99.95 lacs was in the share premium account, which is not available for dividend. The ld Assessing Officer held that if the assessee's contention is accepted even after reducing share premium account from the accumulated profit, the remaining amount would be Rs. 13,76,629. The assessee's argument before the Assessing Officer that these transactions does not fall within the definition of loan and advances as the loan is repayable on demand by the lender. However, these submissions were not found convincing to him as these transactions are covered U/s 2(22(e) of the Act. The submissions before the Assessing Officer is that these transactions are business transactions between M/s Martial Buildcon (P) Ltd. and M/s Manglam Multiplex Pvt. Ltd. but the Assessing Officer asked to file copy of the sale deed of land to prove the business transaction made by these companies were not submitted in either cases. The assessee party has not advanced any evidence to prove that these transactions are business transactions between M/s Manglam Multiplex Pvt. Ltd. to M/s Martial Buildcon (P) Ltd. for purchase of land. The assessee also 9 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal relied upon various case laws before the A.O. on deemed dividend/business transactions. The cases are as under:-
(i) CIT Vs. Badiani P.K. (Bom) (supra)
(ii) CIT vs. Rajkumar (Delhi High Court) (supra) There was accumulated profit at Rs. 33,42,604/- has been considered to be advanced by the M/s Mangalam Multiplex Pvt. Ltd. to M/s Martial Buildcon Pvt. Ltd. and as such Rs. 33,42,604/- has been considered as deemed dividend in the hands of the assessee and Shri Roop Bansal. As such ½ of Rs. 33,42,604/- i.e. Rs. 16,71,302/- was added to the income of the assessee as deemed dividend. The ld Assessing Officer further noticed that in case of M/s Martial Buildcon Pvt. Ltd. that M/s B&B Mercantile Pvt. Ltd. had paid Rs. 80,46,100/- to M/s Martial Buildcon Pvt. Ltd. as on 04/02/2008, which has been paid back by M/s Martial Buildcon Pvt. Ltd. on 25/03/2008. Shri Basant Bansal and Shri Roop Bansal held 34% and 33% shares of M/s Martial Buildcon Pvt. Ltd. respectively and 50% each of M/s B&B Mercantile Pvt. Ltd. during the year 2007-08. As such Shri Basant Bansal and Shri Roop Bansal held more than 10% shares in M/s B&B Mercantile Pvt. Ltd. which has given the loan and held more than 20% shares of M/s Martial Buildcon Pvt.
10 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal Ltd., which had received the advance. Therefore, the Assessing Officer held that the amount of Rs. 80,46,100/- paid by M/s B&B Mercantile Pvt. Ltd. to M/s Martial Buildcon Pvt. Ltd. was considered to be dividend paid to Shri Basant Bansal and Shri Roop Bansal in equal proportion in view of the provisions of section 2(22)(e) of the Act. The Assessing Officer gave reasonable opportunity of being heard and assessee also replied in response to notice. After considering the assessee's reply, the ld Assessing Officer held that the assessee had relied upon the decision of ITAT, Mumbai Bench (SB) in case of ACIT Vs. Bhaumik Colour Pvt. Ltd. (supra), which is not squarely applicable in the case of assessee as the assessee is a registered share holder and beneficial owner of the share. In Bhaumiks colour Pvt. Ltd. case, the common share holder is a trust. Share certificates are in the name of the Trustees. Thus the registered holders are the trustees, whereas the beneficial owners are the beneficiaries of the Trust. Hence, the primary condition for invoking section 2(22)(e) is not fulfilled and consequently, section 2(22)(e) does not apply to the case of ACIT Vs. Bhaumik Colour Pvt. Ltd. (supra) as held by the Special Bench ITAT, Mumbai. In case of Basant Bansal (assessee), there is no ambiguity as he is the registered share holder of both the companies with share holding of 50% in M/s B&B Mercantile 11 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal Pvt. Ltd. and 34% shares holding in M/s Martial Buildcom Pvt. Ltd.. He is also a beneficial owner. It has more than 20% shares in the advance recipient company i.e. M/s Martial Buildcom Pvt. Ltd. and the shares held by Shri Basant Bansal are entitled to dividend. He further relied on the decision of Hon'ble Rajasthan High Court in the case of Hotel Hiltop (supra). He further considered the assessee's argument that sale proceeds of agricultural land are to be treated capital reserve and not eligible for distribution of dividend as the appellant in the case of share premium account but the Assessing Officer held that these proceeds also part of the profit. Therefore, this is a case of deemed dividend U/s 2(22)(e) of the Act. He further considered the assessee's argument that these transactions between both the companies were business transactions and the ld Assessing Officer found that the assessee failed to file the copy of consultation-cum-development agreement entered with both the companies to support the claim. He also considered the case laws submitted by the assessee, which was not found squarely applicable in the case of assessee particularly CIT Vs. Badiani PK and CIT Vs. Rajkumar (supra). It has been held that amount of Rs. 80,46,100/- advanced by M/s B&B Mercantile Pvt. Ltd. to M/s Martial Buildcon Pvt. Ltd. and as such covered U/s 2(22)(e) of the Act in the 12 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal hands of the assessee and Shri Roop Bansal. Being ½ of Rs. 80,46,100/- i.e. Rs. 40,23,050/- has been held as deemed dividend in the hands of the assessee. The same has been added in the income of the assessee.
3. Being aggrieved by the order of the Assessing Officer, the assessee carried the matter before the learned CIT(A), who had allowed the appeal for A.Y. 2007-08 by observing that the assessee has filed additional evidence before him, the same has been remanded back and report has been called for and the ld Assessing Officer has not rebutted the submission made by the assessee, therefore, the additional evidence was considered for disposal of appeal before the ld CIT(A). As regards addition of Rs. 25.25 lacs made U/s 2(22)(e) of the Act on the ground that M/s Misty Meadows Pvt. Ltd. had made payment of Rs. 25.25 lacs to M/s Benchmark Infotech Pvt. Ltd. during the year under consideration, which has been received back on 22/3/2007. It is undisputed that Shri Basant Bansal, the appellant is holding more than 10% of share in M/s Misty Meadows Pvt. Ltd. and is also holding more than 20% shares if M/s Benchmark Infotech Pvt. Ltd.. As per decision of Hon'ble Jurisdictional High Court in the case of CIT Vs. Hotel Hiltop 13 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal (supra), deemed dividend would be added in the hands of beneficial owner and not in the hands of the concern. The Assessing Officer was justified in considering it in the hands of appellant. The Assessing Officer has also appreciated the fact of accumulated profit in remand report. The ld Assessing Officer considered the MOU between M/s Misty Meadows Pvt. Ltd. and M/s Benchmark Infotech Pvt. Ltd. and had not rebutted the submission of the assessee that these transactions were not made for business purposes. He further relied upon the following decisions:-
(i) CIT Vs. Creative Dyeing and Printing P. Ltd. (2009) 318 ITR 476 (Del).
(ii) CIT Vs. Ambassador Travels Pvt. Ltd. (2009) 318 ITR 376 (Del).
(iii) CIT Vs. Raj Kumar (2009) 318 ITR 462 (Del)
(iv) Pradeep Kumar Malhotra s. CIT (2011) 338 ITR 538 (Cal). The ld CIT(A) held that these payments were not loan or advances fallen within Section 2(22)(e) of the Act but payment for proposed purchase of land and are usual business transaction. Therefore, he deleted the addition made by the Assessing Officer to the extent of Rs. 25.25 lacs.
14 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal Regarding deletion of addition of Rs. 7,85,559/-, the ld CIT(A) has held that after considering the addition evidence filed before him in form of MOU between M/s Mangalam Multiplex Pvt. Ltd. and M/s Benchmark Infotech Pvt. Ltd reflected that M/s Mangalam Multiplex Pvt. Ltd. entered into collaboration of Joint Development of the land with M/s Benchmark Infotech Pvt. Ltd. under the terms of which a sum of Rs. 9 cores was paid to M/s benchmark Infotech Pvt. Ltd. for payment of license fee/scrutiny fee/other charges. The collaboration for joint development is further evidenced by a copy of form LC-1 filed to Director Town and Country Planning Development of Haryana Government which is an application for granting development license. The A.O. in the remand report, has verified these facts and has mentioned the same. The A.O. has not given any adverse comments on these points and also particularly on the claim of the AR that these documents established that the payment of Rs. 9 cores was made not as an advance or loan but for the purpose of business i.e. for joint development of land between M/s Mangalam Multiplex Pvt. Ltd. and M/s Benchmark Infotech Pvt. Ltd. Therefore, the ld. CIT(A) deleted the addition.
15 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal Regarding deletion of addition of Rs. 13,76,629/-, Rs. 16,71,302/- and Rs. 40,23,050/- in A.Y. 2008-09 the ld. CIT(A) has held as under:-
"4.10 I have considered the submission of ld. A.R., remand report of present A.O., counter comments of A.R. and further submissions as well as material available on record. In the remand report, after examination of the additional evidences, the A.O. has not made any adverse comments on the argument of the A.R. that the transactions between
(i) M/s Misty & M/s Martial, (ii) M/s Mangalam and M/s Martial and (iii) M/s B.B. Mercantile and M/s Martial are not of lender and borrower which are covered u/s 2(22)(e) and are rather commercial business transactions. In brief, A.O. has not objected to the argument of A.R. that M/s Misty entered into agreement with M/s Martial for purchase of 100 kanals of land at agreed consideration of Rs. 40 crores against which a sum of Rs. 8 crore was given as intial payment by m/s Misty to M/s Martial and thus it was not an advance within the meaning of section 2(22)9e) but was initial payment for purchase of land. Similarly the A.O. has also not made any adverse comments, after considering the additional evidence in the form of agreement, on the argument of the A.R. that M/s Mangalam made initial payment of Rs. 8.4 crore for purchase of 100 kanals of land for total consideration of Rs. 42 crores as per the agreement filed (wherein as Rs. 33.42 lakhs was the
16 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal accumulated profit of M/s Mangalam, Rs. 16.71 lakhs was added in the hands of both the assessees.
4.11 Similarly after examination of additional evidence being an MOU between M/s B.B. and M/s Martial by the A.O., the A.O. has not made any adverse comments on the argument of A.R. regarding payment being in furtherance of business transaction as per the MOU between the two A.O. has also mentioned that the case of M/s Martial was under scrutiny and no adverse inference was drawn by the then A.O. in regard to these payments.
4.12 Considering the facts and in the circumstances of the case as discussed hereinabove, material available on record including the additional evidence and also the remand report of the A.O., it is held that none of these three payments namely (i) payment made by M/s Misty to M/s Martial (leading to addition of Rs. 13,76,629/-), (ii) payment made by M/s Mangalam to M/s martial (leading to addition of Rs. 16,71,302/- in the case of Shri Basant Bansal and Shri Roop Bansal both) and (iii) payment made by M/s B.B. to M/s Martial (leading to addition of Rs. 40,23,050/- in each of the case of Shri Basant Bansal and Shri Roop Bansal) can be treated to be covered U/s 2(22)9e) of the Act in view of the various judicial pronouncements as discussed while deciding the similar issue in A.Y. 2007-08 as above. Accordingly, additions of 17 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal Rs. 13,76,629/-, Rs. 16,71,302/- and Rs. 40,23,050/- made in A.Y. 2008-09 are hereby deleted."
4. Now the Revenue are in appeals before us. The learned C.I.T. D.R. vehemently supported the order of the Assessing Officer.
5. At the outset, the learned A.R. for the assessee supported the order of the ld CIT(A). He further submitted that whatever advances considered by the ld Assessing Officer for the purpose of deemed dividend were transactions for business purposes. All the evidences had been filed before the ld CIT(A). The ld CIT(A) has called remand report from the Assessing Officer also on these evidences, which has not been controverted by him that these transactions were loan and advances as envisaged in Section 2(22)(e) of the Act. Every debt does not involve a loan, the principle that has been laid down is that in Section 2(22)(e) of the Act applies to gratuitous loan or advances. He further relied the case laws referred by the ld CIT(A) on page No. 26 and 27 of his order and prayed to dismiss the appeal of the revenue.
6. We have heard the rival contentions of both the parties and perused the material on record. The ld CIT(A) thoroughly examined the issue in detail after admitted the additional evidence and calling the remand report from the Assessing Officer. He held that these 18 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal transactions made between the companies for business purposes, which does not form part of loan and advances as envisages in Section 2(22)(e) of the Act. The ld DR has not controverted the findings given by the ld CIT(A). The case laws relied upon by the A.R. are squarely applicable on the case of assessee, therefore, we do not find any reason to intervene in the order of ld CIT(A). Accordingly, we uphold the order of ld. CIT(A)
7. In the result, both the revenue's appeals are dismissed. Order pronounced in the open court on 23/04/2015.
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(R.P.Tolani) (T.R. Meena)
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fnukad@Dated 23rd April, 2015
*Ranjan
vkns'k dh izfrfyfi vxzsf'kr@Copy of the Order forwarded to:
1. vihykFkhZ@The Appellant- The DCIT, Central Circle, Alwar.
2. izR;FkhZ@ The Respondent- Basant Bansal, Gurgaon, Haryana.
3. vk;dj vk;qDr@ CIT
4. vk;dj vk;qDr@ vk;dj vk;qDr¼vihy½@The CIT(A) 19 ITA 610 & 611/JP/2012_ DCIT Vs. Basant Bansal
5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur
6. xkMZ QkbZy@ Guard File (ITA No. 610 & 611/JP/2012).
vkns'kkuqlkj@ By order, lgk;d iathdkj@Asst. Registrar