Income Tax Appellate Tribunal - Jaipur
M/S Om Plantation, Jaipur vs Income Tax Officer, Jaipur on 9 October, 2018
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IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR
Jh fot; iky jko] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k
BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM
vk;dj vihy la-@ITA No. 1047/JP/2017
fu/kZkj.k o"kZ@Assessment Year :2006-07
M/s Om Plantation, cuke I.T.O.,
22, Path No. 6, Vijay Bari, Teen Dukan, Vs. Ward 4(3),
Sikar Road, Jaipur. Jaipur.
LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABFO 5180 A
vihykFkhZ@Appellant izR;FkhZ@Respondent
fu/kZkfjrh dh vksj ls@ Assessee by : Shri P.C. Parwal (CA)
jktLo dh vksj ls@ Revenue by : Shri J.C. Kulhari (JCIT)
lquokbZ dh rkjh[k@ Date of Hearing : 06/09/2018
mn?kks"k.kk dh rkjh[k@ Date of Pronouncement : 09/10/2018
vkns'k@ ORDER
PER: VIJAY PAL RAO, J.M. This appeal by the assessee is directed against the order dated 10/10/2017 of ld. CIT(A), Ajmer for the A.Y. 2006-07. The assessee has raised following grounds of appeal:
"1. The ld. CIT(A) has erred on facts and in law in confirming the addition of Rs. 2,23,10,000/- U/s 69 of the IT Act by holding that assessee has made payment in cash over and above the sales consideration recorded in the sale deeds, source of which remained unexplained.
1.1 The ld. CIT(A) has further erred on facts and in law in stating that the appellant instead of cross examining the sellers took adjournment and choose not to cross examine them ignoring that 2 ITA 1047/JP/2017_ Om Plantation Vs ITO none of the sellers appeared before A.O. in remand proceedings for cross examination.
2. The assessee craves to amend, alter and modify any of the grounds of appeal.
3. The appropriate cost be awarded to the assessee."
2. The assessee is a partnership firm constituted on 11/05/2005 with the objects of carrying out plantation, real estate and construction business. The assessee filed its return of income on 31/10/2006 declaring a loss of Rs. 10,772/-. The Assessing Officer received a report of DDIT(Inv), Jaipur vide letter dated 28/3/2010 regarding the on money payment by the assessee in respect of purchase of land situated at Bhankrota, Jaipur for a sale consideration of Rs. 1,76,34,000/- shown in the sale deed, however, an amount of Rs. 1,80,80,000/- was also found to have been paid in cash and was deposited in the bank account of the sellers of the land. Accordingly, the Assessing Officer reopened the assessment by issuing notice U/s 148 of the Income Tax Act, 1961 (in short the Act) on 21/3/2013. The Assessing Officer in the assessment framed U/s 143(3) read with Section 147 of the Act has made an addition of Rs. 2,23,10,000/- U/s 69 of the Act on account of cash payment over and above the sale consideration recorded in the sale deed.
3. The assessee challenged the action of the Assessing Officer before the ld. CIT(A) and also raised an objection of non-grant of opportunity to 3 ITA 1047/JP/2017_ Om Plantation Vs ITO cross examine the sellers. The ld. CIT(A) called for a remand report from the Assessing Officer and after considering the remand report as well as the statements of the assessee, has confirmed the addition made by the Assessing Officer on this account.
4. Before us, the ld AR of the assessee has submitted that the Assessing Officer has made addition on the basis of cash deposits in the bank accounts of the sellers and their relatives in the month of May and August, 2005. Whereas the assessee has purchased the lands in question vide two sale deeds dated 11/8/2005. The consideration thereof is clearly stated in the registered sale deeds, which was duly authenticated by the parties before the Sub-Registrar. The assessee has paid the consideration only in cheque as stated in the registered deed and no amount has been paid in cash. The Assessing Officer for making the addition, has relied upon a copy of the agreement for sale of land with Shri Bhagwata Meena in which the rate of sale of agricultural land is mentioned at Rs. 28,25,000/- per bigha and accordingly calculated the consideration over and above the amount shown in the sale deed and the differential amount of Rs. 2,23,10,000/- was added to the income of the assessee as unexplained investment U/s 69 of the Act. The alleged agreement is only a photo copy and does not bear the signature of the assessee. The agreement is neither registered nor notarized, therefore, in absence of 4 ITA 1047/JP/2017_ Om Plantation Vs ITO corroborative evidence, no addition can be made on a such photo copy of an agreement not signed by the assessee. The ld. AR has contended that the said photo copy is not a primary evidence under the Evidence Act and even if it is considered as a secondary evidence, it can be established that the copy is made from the original agreement. In absence of the original agreement and also in absence of any record to show that the photo copy found was taken from the original agreement it has no evidentiary value. In support of his contention, he has relied upon the decision of the Hon'ble Kerala High Court in the case of CIT Vs. Smt. K.C. Agnes 128 Taxman 848 (Ker.). The ld. AR has further contended that in absence of registration of the alleged agreement, it would not confer any title or any interest in the immovable property, therefore, the registered sale deed cannot be disputed by placing reliance on such photo copy of unregistered agreement, which is not signed by the assessee. Further the Assessing Officer has relied upon the statements recorded of various persons including the sellers without giving an opportunity of cross examination to the assessee. The ld AR has referred to the letter dated 24/2/2014 and 06/3/2014 filed by the assessee during the assessment proceedings and submitted that the assessee has demanded the cross examination of the persons whose statements were proposed to be relied upon by the assessee for making the addition. However, the Assessing 5 ITA 1047/JP/2017_ Om Plantation Vs ITO Officer did not grant the opportunity of cross examination to the assessee and therefore, in view of the decision of the Hon'ble Supreme Court in the case of Andaman Timber Industries Vs. CCE passed in Civil Appeal No. 4228 of 2006 judgment dated 02/09/2015, the addition made in violation of principles of natural justice is not sustainable. The second leg of argument advances by the ld AR that this is the first year of the assessee firm after its constitution and therefore, in absence of any source of income in the hands of the assessee firm, no addition U/s 69 of the Act can be made in the hands of the assessee. In support of his contention, he has relied upon the decision of the Hon'ble Supreme Court in the case of CITP.K. Noorjehan 237 ITR 570 and submitted that the word "may" used in the Section 69 cannot be read as "shall" and therefore, a discretion is conferred on the Assessing Officer in the matter of treating the source of investment which has not been satisfactory explained by the assessee as income of the assessee. The ITO is not obliged to treat such source of investment as income in every case where explanation offered by the assessee is not found to be satisfactory. The ld AR has thus, contended that when the assessee is having no source of income in the year under consideration then the addition U/s 68 of the Act cannot be made in the hands of the assessee. The ld AR has also relied upon the decision of the Coordinate Bench of this Tribunal in the case of M/s 6 ITA 1047/JP/2017_ Om Plantation Vs ITO Kamakshi Hospitality Pvt. Ltd. Vs. DCIT in ITA No. 481/JP/2016 order dated 20/12/2017.
5. On the other hand, the ld DR has submitted that it is a full proof case made out by the Assessing Officer that on money of Rs. 2,23,10,000/- was paid by the assessee over and above the consideration shown in the sale deed for purchase of the lands. Even the statement of the Branch Manager of Jaipur Thar Gramin Bank was recorded wherein the cash deposited in the account of the owner of the land was confirmed as sale consideration received from the sale of the agricultural land. It is not a simple case of addition made based on the statements but an agreement dated 11/5/2005 was also found which has clearly established the sale consideration @ 28,25,000/- per bigha. Further the said agreement also contains the particulars of payment of consideration in cash as well as in cheque, therefore, the part consideration paid in cheque at the time of agreement is also referred in the registered sale deed which establishes the fact that there was an agreement between the parties prior to the sale deed dated 11/8/2005. Hence, the contents recorded in the agreement to sell dated 11/5/2005 has been corroborated by the contents of the sale deed where the part consideration was paid through cheque as mentioned in the agreement. The ld DR has further submitted that the timing of the cash deposited in the bank account of 7 ITA 1047/JP/2017_ Om Plantation Vs ITO the sellers and their relatives being sons, grandsons and wife of sellers further establishes this fact that there was a cash payment over and above consideration shown in the sale deed. The deposit made in the bank account of the sellers and their relatives matches with the dates of the agreement and sale deeds. Hence, even if the said agreement was not signed by both the parties, the facts revealed in the agreements are further corroborated and established by the sale deed as well as the statements of the sellers and the bank manager. Hence, the ld DR has submitted that this is not a case of addition based on mere statement but tangible material was available with the Assessing Officer which cannot be disputed being the bank account statement, agreement as well as the sale deeds all are conferring the fact of payment of cash against the purchase of the lands in question. As regards the opportunity for cross examination, the ld DR has submitted that the ld. CIT(A) has called for a remand report from the Assessing Officer for giving the opportunity of cross examination to the assessee. During the remand proceedings, one of the person was available for cross examination, however, the assessee chose not to cross examine the witness and therefore, the assessee cannot take this objection at this stage. He has relied upon the orders of the authorities below.
8 ITA 1047/JP/2017_ Om Plantation Vs ITO
6. We have considered the rival submissions as well as the relevant material on record. The assessee purchased the land situated at Bhankrota, Jaipur vide two sale deeds both dated 11/8/2005 for a total consideration mentioned in the sale deeds at Rs. 1,76,34,000/-. However, the Assessing Officer received the report of the DDIT(Inv) alongwith the details of the cash deposits in the bank accounts of the sellers and their relatives and further an agreement to sell dated 11/5/2005 wherein the consideration @ Rs. 28,25,000/- per bigha was agreed upon between the parties and part consideration was stated to have been paid at the time of agreement in cash as well as in cheque. The Assessing Officer has computed the total purchase consideration by adopting the rate of Rs. 28,25,000/- per bigha as stated in the agreement to sell dated 11/5/2005. Though the said agreement is not signed by both the parties and it was signed only by the seller, however, we find that the details given in the agreement regarding the agricultural lands, its khasaras numbers as well as the part consideration of Rs. 15,50,000/- through a cheque No. 582863/- dated 10/6/2005 is not in dispute. The deailsof the said cheque also find place in the registered sale deed dated 11/8/2005. Thus, the contents of the agreement to the extent of part payment of consideration has been established by the sale deed dated 11/8/2005. Therefore, even if the said agreement is not enforceable in law due to the non-bearing of 9 ITA 1047/JP/2017_ Om Plantation Vs ITO the signature of the assessee and further due to non-registration, the contents of the said agreement which has been proved and corroborated by the sale deed go to establish the existence of the agreement between the parties. Further the details of the cash deposited in the bank account of the sellers and their relatives has been reproduced by the Assessing Officer in the assessment proceedings at page No. 4 and 5 of the assessment order as under:
S. Name of person Bank Deposited Date Relation with the No. account cash amount seller No.
1. Smt. Dhapu Devi 210501000 32,74,000/- 12/08/2005 Seller of land Meena 00001
2. Sh. Dulharam Meena 1007813 1,50,000/- 14/05/2005 Do 10,00,000/- 12/08/2005 1,60,000/- 16/08/2005
3. Sh. Ballu Ram Meena 1007108 4,00,000/- 14/05/2005 Do 11,70,666/- 12/08/2005
4. Sh. Harphool Meena 1004534 11,70,667/- 12/08/2005 Do
5. Sh. Satendra 1007978 14,00,000/- 12/08/2005 Son of Sh.
Basanwal Bagwataram Seller
6. Sh. Rajendra Kumar 1003946 1,50,000/- 12/05/2005 Do
Meena 14,00,000/- 12/08/2005
7. Sh. Om Prakash 1004337 1,50,000/- 12/05/2005 Do
Meena 14,00,000/- 12/08/2005
8. Sh. Ashok Kumar 1001168 14,00,000/- 12/08/2005 Do
Meena
9. Sh. Roshal Lal Meena 1006877 1,50,000/- 12/05/2005 Grandson of Sh
14,00,000/- 12/08/2005 Bagwataram, Seller
10. Sh. Jagdish Pd. 100131 7,50,000/- 12/08/2005 Son of Smt. Dhapu
Meena Devi Meena, Seller
11. Sh. Manna Lal Meena 1008064 7,15,800/- 12/08/2005 Son of Smt. Dhapu
Devi Meena, Seller
12. Sh. Nemi Chand 1005293 7,50,000/- 12/08/2005 Son of Smt. Dhapu
Meena Devi Meena, Seller
13. Smt. Sushila Meena 210501000 7,50,000/- 12/08/2005 W/o- Sh. Prabhu
W/o Prabhu Dayal 07726 Dayal Meena, S/o-
Meena Smt. Dhapu Devi
Meena, Seller
10 ITA 1047/JP/2017_
Om Plantation Vs ITO
The dates of deposit of cash as well as cheques in the bank accounts of the sellers, their sons, grandsons and wife are clearly matching to the dates of agreement to sell and sale deed i.e. 11/5/2005 and 11/8/2005.
All the deposits of cash in the bank accounts of these persons were made on the very next day of execution of agreement and sale deed respectively. In absence of any other source of income of the sellers, the only inference which can be drawn from the details of the bank accounts and particularly the deposits made on the particular dates which is just one day after the execution of the agreement to sell and sale deeds that the cash deposits in the bank accounts of the sellers and their relatives is only from the sale consideration received against the sale of agricultural lands in question. There is no other transaction either on those dates or in around those dates of deposits in the bank accounts other than the present transaction of sale of lands by the sellers. Further the Assessing Officer has reproduced the statements of the branch manager wherein the amounts were deposited as well as the relatives of the sellers who have confirmed the receipt of cash and deposit of the same in the bank account. Thus, we find that the assessment framed by the Assessing Officer is not solely based on the statements recorded by the Investigation Wing but there was tangible material in the shape of the bank accounts statements, agreement to sell and sale deeds which are of 11 ITA 1047/JP/2017_ Om Plantation Vs ITO course not in dispute. The only dispute raised by the assessee is regarding the photo copy of the agreement and its evidentiary value, however, it is not the issue of legal enforceability of the said agreement and the claim under the agreement but the contents of the agreement which are to the extent corroborated by the independent evidence being sale deeds and further the bank statements of the sellers cannot be denied on the technical ground of admissibility. Therefore, once the payment of cash is reflected from all these documents as well as statements of the parties then the technical objection raised by the assessee will not help the case of the assessee.
6.1 The decision relied upon by the ld AR of the assessee that the Assessing Officer has the discretion to make the addition U/s 69 of the Act and not bound to make the addition in a case the explanation was not found satisfactory, we note that the said decision is no doubt laid down a guidance and liberty for deciding the issue of addition U/s 69 of the Act but once the fact of payment of cash by the assessee and indisputably the failure of the assessee to explain the source is established by the Assessing Officer then the said decision of the Hon'ble Supreme Court cannot be applied in the facts of the present case. Moreover, it is not the case of the explanation of source of investment was not found to be satisfactory but the assessee has denied the payment of the cash against 12 ITA 1047/JP/2017_ Om Plantation Vs ITO the purchase of the land and hence there was no explanation on the part of the assessee for the source of such cash payment. Once the fact of payment of cash is established and there is no explanation of such investment by the assessee then the decision of the Hon'ble Supreme Court has no role in the case of the assessee. The ld AR has also relied upon the decision of the Coordinate Bench in the case of M/s Kamakshi Hospitality Pvt. Ltd. Vs DCIT (supra) wherein the Coordinate Bench has deleted the addition made by the Assessing Officer on the ground that the said addition was made on the basis of statement of a third person without giving a opportunity of cross examination and in absence of any documentary and independent evidence, such addition based on the statement of third party without cross examination is not sustainable. In the case in hand, we find that the addition is not based merely on the statement but the documentary evidence in the shape of agreement dated 11/05/2005, the bank statement of the sale deeds showing deposits of cash on the dates of the execution of the agreement as well as sale deeds and further the part consideration paid through cheque find mentioned in the agreement to sell as well as in sale deed established the fact of existence of the said agreement between the parties. The statements recorded by the Investigation Wing further corroborates the documentary evidence and hence it is not a case of addition based on 13 ITA 1047/JP/2017_ Om Plantation Vs ITO mere statement of third party. Further the statements of the seller cannot be said to be the statement of the third party but they were very much party to the transaction of sale of the lands in question to the assessee. As regards the opportunity for cross examination, the ld CIT(A) called for a remand report from the Assessing Officer after allowing the opportunity of cross examination. The Assessing Officer in its remand report has stated that he has summoned both the parties for their presence and after giving 2-3 opportunities at last on 09/1/2017 one Smt. Malti Devi Meena, widow of Late Madan Lal Meena appeared before the Assessing Officer and confirmed the earlier statement made by her husband. The Assessing Officer again summoned the remaining parties for subsequent dates. We find that despite various opportunities given by the Assessing Officer, both the parties kept on seeking deferment of remand proceedings and finally the statements on behalf of the sellers were made that they stand by their statements made on the earlier occasions. One Shri Munna Lal Meena, S/o Smt. Dhapu Devi appeared for cross examination, however, the assessee did not chose to cross examine him. The remand report of the Assessing Officer has been reproduced by the ld. CIT(A) at page 7 and 8 of the impugned order as under:
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14 ITA 1047/JP/2017_ Om Plantation Vs ITO bl lEcU/k esa ys[k gS fd ØkWl ,Xtkfeu ds fy, nksuksa i{kksa dks lwfpr fd;k x;k ,oa nksuksa i{kksa dh lgefr ls nksuksa i{kksa dks dk;kZy; esa mifLFkr gksus dks dgk x;kA fdUrq /kkiw nsoh ds i{k ls le; ij dksbZ Hkh mifLFkr ugha gqvk rc bUgsa fnuakd 04- 01-2017 dks HkkxhjFk eh.kk] gjQwy eh.kk] cYywjke eh.kk] /kwykjke eh.kk] enu yky eh.kk] ¼/kkiwnsoh ds fogki ij½ lEeu tkjh fd;k x;k fnuakd 09-01-2017 dks fu;r fd xbZ fnuakd 09-01-2017 dks vkse IykUVs'ku dh rjQ ls buds ,-vkj- Jh ds-ds-xqIrk us LFkxu ds fy, izkFkZuk i= izLrqr fd;k] fnuakd 14-01-2017 dks iqu% Økl ,Xtkfeu gsrq fu;r dh xbZA fnuakd 09-01-2017 dks ekyrh nsoh eh.kk iRuh Lo- enu yky eh.kk] mifLFkr gqbZ vkSj blus dgk dh eq>s bl izdj.k esa T;knk tkudkjh ugh gSA esjs ifr dk bl fo'k; esa iwoZ esa gh c;ku vkids ikl ntZ gks pqdk gSA fnuakd 09-01-2017 dks Jh iz'kkar caly lh-,- mifLFkr gq, vkSj mUgksusa izkFkZuk i= fd /kwykjke eh.kk dh ckbZ ikl ltZjh gqbZ gSA cYyw jke eh.kk gkbZ ch-ih- dk ejht gS ,oa t;iqj ls ckgj gSA tks fd vU; O;fDr;ksa ds lkFk mifLFkr gksxkA dsl dks iqu% 14- 01-2017 LFkfxr fd;k ,oa 14-01-2017 ds ckn esa blesa dksbZ Hkh i{k mifLFkr ugh gqvk fnuakd 07-07-2017 dks gjQwy eh.kk] cyywjke eh.kk] /kwykjke eh.kk] enu yky eh.kk dks iwu% lEeu tkjh fd;s x;s] ,oa Økl ,Xtkfeu gsrq fnuakd 19-07-2017 fu;r dh xbZ fnukad 18-07-2017 dks iz'kkar caly us dsl dh lquokbZ 20-07-2017 dks dgkA fnuakd 20-07-2017 dks nksuksa i{kksa us iqu% Økl ,Xtkfeu LFkkxu gsrq ,oa Økl ,xtkfeu LFkkxu gsrq dgk vkSj iqu% lquokbZ dh rkjh[k 08-08-2017 j[kh blesa dksbZ Hkh i{k mifLFkr ugh gqvk fnuakd 07-09-2017 dks iz'kkar caly ,oa gjQwy eh.kk] cYywjke eh.kk] eUukyky eh.kk mifLFkr gq, vkSj Økl ,Xtkfeu dh rkjh[k 11-09- 2017 j[kh xbZ fnuakd 11-09-2017 dks Jh iz'kkar caly] Jh ds-ds-xqIrk lh-,- nksuksa i{k dh rjQ ls mifLFkr gq, vkSj iqu% mUgksusa Økl ,Xtkfeu gsrq fnuakd 12-09-2017 j[kh] fnuakd 12-09-2017 dks Jh ds-ds-xqIrk lh-,- vfuy uwvky lh-,- vkSj eUukyky eh.kk vkSj iz'kkar caly lh-,- mifLFkr gq, vkSj iz'kkar caly ls dgk fd enuyky eh.kk dk LoxZokl gks x;k gSA gjQwy eh.kk vkSj vU; lHkh vius iwoZ c;ku ntZ djok pqds gS Jh enu yky eh.kk ,oa Jh gjQwy eh.kk us fnuakd 28-01-2014 dks vius c;ku fn;s gS] Jh cyywjke eh.kk ,oa Jh nwyk jke eh.kk us fnuakd 20-01-2014 dks vius c;ku fn;s gSA vr% fdlh dk Hkh Økl ,xtkfeu ugha gks ik;k gSA D;ksfa d eqUukyky eh.kk Jherh /kkiwnsoh ds iq= gS vr% budk Økl ,xtkfeu djus ds fy, nksuksa i{kksa gh lger ugha gq,A"
Thus, it is clear that the Assessing Officer made sincere efforts for granting the opportunity to cross examine to the assessee, however, it appears that both the parties in collusion avoided the cross examination.
15 ITA 1047/JP/2017_ Om Plantation Vs ITO Thus, the blame cannot be shifted on the Assessing Officer for non-cross examination if any.
6.2 The addition made by the Assessing Officer in the hand of seller U/s 68 instead of capital gain would not affect the merits of the addition made in the hand of the assessee. The ld. CIT(A) has considered the objections raised by the assessee on this issue in para 4.3 as under:
"4.3 I have gone through the assessment order, statement of facts, grounds of appeal, written submission, remand report and rejoinder carefully. It is seen that the AO has made the addition in respect of the unaccounted cash of Rs. Rs. 2,23,10,000/- paid by the appellant towards purchase of land situated at Bhankrota, Jaipur. The cash paid by the appellant over and above the sales consideration recorded in the sale deed was deposited by the sellers in their bank account. The bank manager in his statement recorded by the DDIT, Jaipur has confirmed that it was explained by the depositors that the cash being deposited by them was received by them on sale of the land (Page No. 2 & 3 of the assessment order). The statements of the sellers of property were also recorded u/s 131 and they also confirmed that the cash deposited by them in the bank accounts was received by them from M/s Om Plantation on sale of their land to M/s Om Plantation (Page No. 5 to 9 of the assessment order). The ITO, Ward - 7(2) was in possession of the copy of agreement to sale made by the assessee with the seller Shri Bhagwat Meena on 11.05.2005.
In the agreement, there is mention of cash payment as well as payment by cheque. The payments by cheque recorded in the agreement is also found recorded in the bank statement of the seller. Thus, the genuineness of the agreement cannot be doubted. During the course of appellate proceedings, the AO was directed to allow the appellant, the opportunity to cross examine 16 ITA 1047/JP/2017_ Om Plantation Vs ITO the sellers. The AO in the remand report dated 19.09.2017 has mentioned that the appellant instead of cross examining the sellers took adjournment on one pretext or another and it chose not to cross examine any of the seller. Hence, in view of the facts discussed by the AO in the assessment order, specifically at para 5.4 and 5.5 (page no. 13 to 16) of the assessment order, I am of the considered view that the appellant did make payment of Rs. 2,23,10,000/- in cash over and above the sales consideration recorded in the sales deeds, source of which remained unexplained. Accordingly, the addition of Rs. 2,23,10,000/- made by the AO u/s 69 is hereby confirmed." Having analysed the entire facts, the relevant record including the evidence brought on record by the Assessing Officer, we do not find any error or illegality in the orders of the authorities below, hence uphold the order of the ld. CIT(A) qua this issue.
7. In the result, appeal of the assessee is dismissed.
Order pronounced in the open court on 09/10/2018.
Sd/- Sd/-
¼foØe flag ;kno½ ¼fot; iky jko½
(VIKRAM SINGH YADAV) (VIJAY PAL RAO)
ys[kk lnL;@Accountant Member U;kf;d lnL;@Judicial Member
Tk;iqj@Jaipur
fnukad@Dated:- 09th October, 2018
*Ranjan
vkns'k dh izfrfyfi vxzsf'kr@Copy of the order forwarded to:
1. vihykFkhZ@The Appellant- M/s Om Plantation, Jaipur.
2. izR;FkhZ@ The Respondent- The I.T.O., Ward 4(3), Jaipur.
3. vk;dj vk;qDr@ CIT 17 ITA 1047/JP/2017_ Om Plantation Vs ITO
4. vk;dj vk;qDr¼vihy½@The CIT(A)
5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur
6. xkMZ QkbZy@ Guard File (ITA No. 1047/JP/2017) vkns'kkuqlkj@ By order, lgk;d iathdkj@Asst. Registrar