SHRI KULDEEP KUMAR SHARMA, Jaipur V. ITO, Jaipur

ITA 1018/JPR/2011

• Counselvise Citation: 101823114 RSA 2011
• Duration Of Justice: 3 year(s) 2 month(s) 28 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 19-02-2015
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 16-11-2012
• Assessment Year: 2008-2009
• Appeal Filed On: 21-11-2011
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: RAJESH OJHA JCIT DHK
• Assessee Lawyers: KULBHUSHAN SHARMA
• Keywords: Gift; Additional evidence
• Section: 44AD; 131; 69

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR JH VKJ-IH-RKSYKUH] U;KF;D LNL; ,OA JH VH-VKJ-EHUK] YS[KK LNL; DS LE{K BEFORE: SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM VK;DJ VIHY LA-@ ITA NO. 1018/JP/2011 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2008-09 SHRI KULDEEP KUMAR SHARMA, B-2, SATYA NAGAR, JHOTWARA, JAIPUR CUKE VS. THE ITO WARD- 3 (1) JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AVEPS 4062 P VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT VK;DJ VIHY LA-@ ITA NO. 1049/JP/2011 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2008-09 THE ITO WARD- 3 (1) JAIPUR CUKE VS. SHRI KULDEEP KUMAR SHARMA, B-2, SATYA NAGAR, JHOTWARA, JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AVEPS 4062 P VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI KULBHUSHAN SHARMA, CA JKTLO DH VKSJ LS@ REVENUE BY : SHRI RAJESH OJHA, JCIT LQUOKBZ DH RKJH[K@ DATE OF HEARING : 31/12/2014 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 19 /02/2015 VKNS'K@ ORDER PER R.P. TOLANI, JM THESE ARE CROSS APPEALS AGAINST THE ORDER OF THE L D. CIT(A)-1, JAIPUR DATED 07-09-2011 FOR THE ASSESSMENT YEAR 200 8-09. ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 2 2.1 THE ASSESSEE HAS RAISED THE GROUND AGAINST THE ORDER OF THE LD. CIT(A) CHALLENGING THE RETENTION OF ADDITIONS OF RS . 7.70 LACS U/S 69 OF THE ACT QUA THE DEPOSITS IN BANK ACCOUNT. 2.2 THE REVENUE HAS RAISED THE GROUND AS UNDER:- WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. CIT(A) IS JUSTIFIED IN RESTRICTI NG THE ADDITION OF RS. 14.72 LACS MADE BY THE AO ON ACCOUN T OF UNEXPLAINED CASH DEPOSITS IN THE BANK ACCOUNT. 3.1 BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE C LAIMS TO BE A CIVIL CONTRACTOR AND HAS DECLARED INCOME FROM HOUSE PROPE RTY AND CIVIL CONTRACT WORKS IN THE RETURN OF INCOME. THE TURNOVE R BEING LESS THAN RS. 40.00 LACS, BOOKS OF ACCOUNTS ARE NOT MAINTAINED AN D THE INCOME IN THIS BEHALF IS OFFERED U/S 44AD OF THE I.T. ACT ON PRESU MPTIVE BASIS. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, ON THE BASIS OF AIR INFORMATION AO FOUND THAT THE ASSESSEE HAD DEPOSITED HUGE CASH AMOUNTS IN CANARA BANK, VIDHYADHAR, JAIPUR. REGARDING THE SOURCE THER EOF ASSESSEE REPLIED AS UNDER:- CASH DEPOSITS IN BANK A/C (1) DEPOSIT OF RS. 10 LACS:- AN AGRICULTURAL LAND WAS SOLD BY MR. KULDEEP SHARMA FOR RS. 10,00,000/-. THE SAME WAS DEPOSITED IN THE BANK. ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 3 (2) DEPOSITS OF RS. 20 LACS:- CASH GIFT OF RS. 20, 00,000/- WAS RECEIVED BY KULDEEP SHARMA FROM HIS FATHER. (3) OTHER CASH DEPOSITS & PAYMENTS:- ALL OTHER DEP OSITS AND PAYMENT RELATED TO BUSINESS ONLY. IT WAS STATED THAT THE ASSESSEE HAS RECEIVED CASH A MOUNTING TO RS. 20,00,000/- FROM HIS FATHER SHRI RAMJI LAL S HARMA ON 20-04-2007. ON BEING ASKED TO PROVE CASH AVAILABILI TY OF RS. 20,00,000/- WITH SHRI RAMJI LAL SHARMA, THE FATHER OF THE ASSESSEE. IT WAS FURTHER STATED THAT THE FATHER OF THE ASSESSEE IS A CULTIVATOR AT VILLAGE-DHOLA, TEHSIL-JAMUWARAMG ARH, DISTT. JAIPUR AND HE SOLD HIS AGRICULTURE LAND ON 1 6-04-2007 FOR A SALE CONSIDERATION OF RS. 10,00,000/- AND IT HAS ALSO STATED THAT THE FATHER OF THE ASSESSEE HAD KEPT PAS T SAVING AS WELL AS AGRICULTURAL RECEIPTS OF PAST TIME AND OUT OF THEM HE HAS GIFTED A SUM OF RS. 20,00,000/- TO SHRI KULEEP SHARMA IN CASH. THE AO ACCEPTED ASSESSEES VERSION ABOUT THE SALE O F AGRICULTURAL LAND BY HIM FOR THE REMAINING AMOUNTS AO WAS OF THE VIEW TH AT THE ASSESSEE HAS NOT FULLY DEMONSTRATED THE FINANCIAL CAPACITY OF HI S FATHER. THE OTHER CASH DEPOSITS IN THE ACCOUNT REPRESENT HIS INCOME FROM P ROPERTY BUSINESS. THE GIFT DEED FILED BY THE ASSESSEE WAS ONLY AN AFTERTH OUGHT TO JUSTIFY THE CASH AVAILABLE WITH HIS FATHER. THE FACTS THAT FATHER RE TAINED THE OLD SALE PROCEEDS OF AGRICULTURAL LAND AND USED THEM FOR MON EY LANDING BUSINESS WAS NOT BELIEVED. SIMILARLY SOURCES OF OTHER DEPOS ITS WERE NOT ACCEPTED. ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 4 CONSEQUENTLY, A SUM OF RS. 22,42,000/- WAS ADDED TO THE ASSESSEE'S INCOME. 3.2 AGGRIEVED, THE ASSESSEE PREFERRED FIRST APPEAL; WHEREIN IT WAS CONTENDED THAT QUA THE AMOUNT OF RS. 10.00 LACS GIV EN BY THE FATHER OF THE ASSESSEE; AN AMOUNT OF RS. 4.28 WAS RECEIVED BY HIM BY SALE OF AGRICULTURAL LAND IN THE YEAR 1996. BESIDES, THE FA THER OF THE ASSESSEE CARRIED OVER MONEY LENDING ACTIVITIES TO EARN INTER EST FROM OTHER AGRICULTURISTS AT HIS NATIVE PLACE. THE AMOUNT OF R S. 20 LACS WAS THUS ACCUMULATED BY FATHER AND GIFTED TO ASSESSEE. FRESH EVIDENCE BEING COPIES OF SOME AFFIDAVITS FROM FATHERS BORROWERS WERE FIL ED. THE LD. CIT(A) FORWARDED THESE AFFIDAVITS TO AO FOR REMAND REPORT WHO SUMMONED THE BORROWERS U/S 131 OF THE ACT. THE DEPONENTS VIZ. S/ SHRI BANNARAM GURJAR S/O LATE SHRI GHASILAL GURJAR FOR RS. 1.50 L ACS, SHRI PHOOLCHAND SAINI S/O SHRI SITARAM SAINI FOR RS. 2.50 LACS, SHR I BRIJ MOHAN SHARMA S/O LATE SHRI BHAGWANI SAHAI SHARMA FOR RS. 2.00 LA CS AND SHRI ISHWAR KUMAWAT S/O LATE SHRI PRABHULAL KUMAWAT FOR RS. 2.7 5 LACS; ACCEPTED HAVING TAKEN LOANS FROM THE ASSESSEE'S FATHER AND P AID INTEREST THEREON. THE AO IN HIS REMAND REPORT OBJECTED TO ADMISSION O F FRESH EVIDENCE AND ON AFFIDAVITS REPORTED THAT THEY WERE NOT RELIABLE AS THE DEPONENTS WERE ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 5 SMALL AGRICULTURISTS, SPECIFIC PERIOD OF LENDING AN D REPAYMENT WERE NOT MENTIONED, THEREFORE, THEY WERE URGED TO BE NOT CON SIDERED. THE LD. CIT(A), HOWEVER ADMITTED THE ADDITIONAL EVIDENCE & ON MERITS AND ACCEPTED THAT ASSESSEE'S FATHER SOLD LAND IN 1996 A ND THE AMOUNT WAS USED BY HIM FOR MONEY LENDING BUSINESS WHICH COULD ACCUM ULATE INTO 20 LACS USED FOR THE GIFTED. THE AFFIDAVITS SUPPORT THE CLA IM OF THE ASSESSEE. THE ADDITION IN THIS BEHALF WAS DELETED. 3.3 APROPOS OTHER ADDITIONS, THE LD. CIT(A) ACCEPTE D THE ASSESSEE'S CONTENTION THAT THE ASSESSEE BEING THE CIVIL CONTRA CTOR WAS NOT REQUIRED TO MAINTAIN THE BOOKS OF ACCOUNT U/S 44AD OF THE ACT. HOWEVER IT WAS HELD THAT IT CANNOT BE RULED OUT THAT HE MADE FINANCIAL GAINS FROM LOAN TRANSACTIONS WHICH WERE PRESENTED BY HIM QUA THE PO WER OF ATTORNEY GIVEN BY SMT. SAROJ DEEDWANIA WHO COULD NOT BE PRES ENTED FOR EXAMINATION BEFORE AO. IT WAS HELD THAT THE ASSESSE E U/S 44AD COULD HAVE EARNED ONLY RS. 3.20 LACS ON CONTRACT TURNOVER OF RS. 40.00 LACS. THE ASSESSEE HAD HIMSELF ACCEPTED THAT HE WAS PAYIN G EMI OF RS. 25,000/- PER MONTH FOR PURCHASE OF HOUSEHOLD GOODS TO FINANCIAL INSTITUTIONS. THUS ASSESSEE'S YEARLY CASH OUTFLOW W AS AT RS. 4.25 LACS. IN CONCLUSION OUT OF ENTIRE ADDITIONS A SUM OF RS. 7.7 0 LACS WAS CONFIRMED. ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 6 3.4 AGGRIEVED ON THE RESPECTIVE GROUNDS, BOTH THE P ARTIES ARE BEFORE US. 3.5 THE LD. COUNSEL FOR THE ASSESSEE REITERATED THE FACTS AS RELIED ON THE WRITTEN SUBMISSION FILED BY HIM AND CONTENDS THAT T HE LD. CIT(A) WAS JUSTIFIED IN ACCEPTING THE AFFIDAVITS AND FINANCIAL CAPACITY OF ASSESSEE'S FATHER WHILE DELETING THE ADDITION OF RS. 10.00 LAC S. 3.6 APROPOS ASSESSEE'S APPEAL, THE LD. COUNSEL FOR THE ASSESSEE DREW OUR ATTENTION TO THE SYNOPSIS OF FINANCIAL TRANSACT IONS AS MENTIONED IN THE WRITTEN SUBMISSION AND CONTENDS THAT NEITHER THE AO NOR THE LD. CIT(A) HAS CONSIDERED THE FOLLOWING ASPECT. (A) THE PRESUMPTIVE BASIS OF COMPUTATION OF INCOME U/S 44AD IS JUST FOR THE SAKE OF ADMINISTRATIVE CONVENI ENCE/ SIMPLIFICATION OF SYSTEM/ THUMB RULE FOR BENCHMARKI NG AND NOT A UNIVERSAL TRUTH OR YARDSTICK THAT PERSON ENGA GED IN THE CIVIL CONSTRUCTION CANNOT MAKE MORE PROFIT THAN 8% OF CONTRACT WORK. (B) FURTHER IN CASE OF CASH FLOW CONSIDERATION, INF LOW MAY BE HIGHER THAN THE NET INCOME DUE TO ANYTHING I.E. (A) AMOUNT RECEIVED TOWARDS THE MATERIAL SUPPLIED BUT NOT PAID TO THE SUPPLIER. (B) PAYMENT RECEIVED TOWARDS LABOUR PAYMENT BUT NOT PAID BY THE CONTRACTOR TO THE LABOUR/ SUB- CONTRACTOR. TOWARDS ADVANCE RECEIVED AGAINST WORK ORDER OR AT STAGE OF WORK COMPLETION ETC. ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 7 SAME WAY CONSIDERATION TOWARDS LOAN INSTALMENT, PLEASE NOTE THAT ALL THE LOANS HAD BEEN TAKEN BY TH E ASSESSEE IN THE PREVIOUS YEARS AND THE REPAYMENT WAS SCHEDUL ED AT THE TIME OF DISBURSEMENT ONLY. THE LOANS WERE TAKEN BY THE ASSESSEE BECAUSE HE WAS EXPECTING MORE REVENUE FROM HIS BUSINESS, OTHER THAN THAT EVEN IF THE ASSESSEE WERE NOT BY THE POWER OF ATTORNEY HOLDER STILL THE REPAYMENT OF LOA N WAS PRE- FIXED AND HE HAS TO MANAGE HIS CASH FLOWS ACCORDING LY. THIS MAY BE THE REASON WHY ASSESSEE HAS SOLD HIS AGRICUL TURAL LAND HOLDING DURING THE ASSESSMENT YEAR (D) FURTHER THE SYNOPSIS OF THE TRANSACTION TAKEN PLACE ARE AS FOLLOWS:- DATE PARTICULARS AMOUNT 18-04-2007 ASSESSEE AND HIS FATHER SOLD THEIR AGRICULTURE LAND AT DHOLA (DEPOSITED IN URBAN CO-OP. BANK ON 16-04-2007 IN CASH) (+) 10,00,000/- 19-04-2007 ASSESSEE'S FATHER MADE A GIFT DEED FAVOURING ASSESSEE (DEPOSITED IN CANARA BANK ON 20-04-2007 IN CASH) (+) 20,00,000/- 01-06-2007 CASH WITHDRAWAL FROM CANARA BANK, POWER OF ATTORNEY WAS GIVEN BY SAROJ DEEDWANIA (-) 12,50,000/- 18-06-2007 CASH RE-DEPOSITED IN CANARA BANK (+) 4,80,000/- 27-06-2007 CASH RE-DEPOSITED IN CANARA BANK (+) 7,50,000/- 07-11-2007 REALIZATION OF PLOT SOLD OF SAROJ DEEDWANIA IN CANARA BANK (+) 7,70,000/- 16-11-2007 CASHWITHDRAWAL AND RETURNED BACK TO SAROJ (-) 7,00,000/- ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 8 RELIANCE IS PLACED IN THE CASE OF CIT VS. SURINDER PAL ANAND, 192 TAXMAN 264 (P&H) FOR THE PROPOSITION THAT ASSESSEE NEED NOT EXPLAIN EACH AND EVERY ENTRY OF DEPOSIT/ INVESTMENT UNLESS SUCH ENTRY HAS NO NEXUS WITH GROSS RECEIPTS. HENCE, THE ASSESSEE IS U NDER NO OBLIGATION TO EXPLAIN ONLY THE DEPOSITS OR INVESTMENTS HIGHER THA N GROSS RECEIPTS OR TURNOVER. 3.7 THE LD. DR VEHEMENTLY CONTENDS THAT THE LD. CIT (A) HAS NEITHER REPRODUCED THE REMAND REPORT OBTAINED FROM AO NOR T HE ASSESSEE HAS SUPPLIED A COPY THEREOF, IN THE PAPER BOOK. FROM TH E INDEX OF THE PAPER BOOK, IT DOES NOT EMERGE THAT HE HAS FILED ANY CASH FLOW STATEMENT BEING RELIED ON BEFORE ITAT GIVING SUMMARY OF THE TRANSAC TIONS BEFORE LOWER AUTHORITIES. THE COPY OF THE STATEMENTS MADE BEFORE THE LD. CIT(A) AT PB PAGES 9 TO 18 DOES NOT CONTAIN ANY CASH FLOW STATEM ENT. THEREFORE, THE EVIDENCE CLAIMED BY THE ASSESSEE TO HIS ADVANTAGE A RE NOT COMING OUT FROM THE RECORD. THE DONOR WAS THE FATHER OF THE AS SESSEE, IT IS IRONICAL THAT INSTEAD OF PRODUCING THE DONOR HIS DEBTORS ARE PRODUCED. DESPITE ADEQUATE OPPORTUNITIES NO SUCH EVIDENCE OR AFFIDAVI TS WERE FILED BEFORE AO AND BY A DESIGN THEY HAVE BEEN FILED AT THE STAG E OF FIRST APPEAL BEFORE LD. CIT(A). THE COPY OF APPLICATION FOR ADMISSION O F FRESH EVIDENCE IS NOT ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 9 FILED BY THE ASSESSEE NOR LD. CIT(A) HAS GIVEN REAS ONS FOR CONCLUSION THAT ASSESSEE WAS PREVENTED BY SUFFICIENT REASONS BEFORE AO. THE FINANCIAL YEAR IN QUESTION IS 2007-08 AND THE AFFIDAVITS HAVE BEEN SWORN BY THE DEBTORS DURING 27-07-11 TO 25-07-2011 I.E. AFTER TH E ASSESSMENT ORDER, THE NAMES OF THESE DEBTORS WERE NOT GIVEN TO THE AO. TH US THE AFFIDAVITS ARE NOTHING BUT A MAKE BELIEVE EVIDENCE AND AN AFTERTHO UGHT. THE DEBTORS NOWHERE SPECIFIED WHEN THE LOANS WERE TAKEN AND WHE N REPAID SO AS TO DRAW ANY VIEW ABOUT AVAILABILITY OF CASH FOR THE AL LEGED GIFT. THUS ENTIRE EDIFICE OF THE ORDER IS BASED ON UNVERIFIED, VAGUE AND SPECIOUS PLEAS AND THE RELIEF GIVEN BY THE LD. CIT(A) AT RS. 10.00 LAC S IS WITHOUT PROPER REASONINGS & JUSTIFICATION. 3.8 APROPOS ADDITION OF RS. 7.70 LACS, THE ORDER OF THE LD. CIT(A) IS RELIED ON. 3.9 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. BASED ON THE ARGUMENTS MADE BY THE LD. DR, WE FIND THAT NEITHER THE REMAND REPORT IS AVAILABLE ON THE RECORD NOT IT FINDS PLACE IN THE ORDER OF THE LD. CIT(A). SIMILARLY, THE CASH FLOW STATEMENT DO NOT APPEAR TO HAVE BEEN FILED BEFORE LOWER AUTHORITIES. THEREFORE, THE CASH FLOW STATEMENT BECOME A NEW PIECE OF EVIDENCE WHICH IS NOT VERIFIED BY ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 10 LOWER AUTHORITIES. THE GIFT WAS MADE THE ASSESSEE S FATHER AND SURPRISINGLY DEBTORS AFFIDAVITS ARE FILED. THEREFOR E, IT WAS DESIRABLE THAT FATHER HIMSELF WAS PROPERLY EXAMINED AS TO DETAILS OF YEARS OF LENDING MONEY AND RECEIVING BACK SO AS TO EXPLAIN THE AVAIL ABILITY OF AMOUNT AT THE TIME OF GIFT. IF THE RATE OF INTEREST WAS 15% T O 18%, IT IS QUITE LIKELY THAT FATHERS INCOME COULD HAVE BEEN TAXABLE INCOME IN EARLIER YEARS. THE ASSESSEE WAS VERY SELECTIVE IN GIVING EFFECTIVE EXP LANATION AND EVIDENCE BEFORE THE AO DESPITE ADEQUATE OPPORTUNITIES. IN TH E ABSENCE CONTENTS OF APPLICATION FOR ADDITIONAL EVIDENCE, THE REMAND REP ORT AND LOOKING AT THE VAGUENESS IN THE AFFIDAVITS, WE ARE OF THE VIEW THA T PROPER ASSESSMENT CAN BE FRAMED ONLY BY SETTING ASIDE THE APPEALS BACK TO THE FILE OF THE AO TO DECIDE THE SAME AFRESH AFTER GIVING A REASONABLE OP PORTUNITY OF BEING HEARD TO THE ASSESSEE. THE ASSESSEE SHALL COOPERATE AND PRODUCE ALL THE MATERIALS WHICH IS ASKED FOR BY THE AO. WITH THESE OBSERVATIONS, BOTH THE APPEALS ARE SET ASIDE TO THE FILE OF THE AO TO DECI DE THE SAME AFRESH IN ACCORDANCE WITH LAW. ITA NO.1018/JP/2011 SHRI KULDEEP KUMAR SHARMA VS. ITO, WARD- 3 (1), JAI PUR . 11 4.0 IN THE RESULT, THE APPEALS OF THE ASSESSEE AND THE REVENUE ARE ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 19/02/2015. SD/- SD/- VH-VKJ-EHUK VKJ-IH-RKSYKUH (T.R. MEENA) (R.P.TOLANI) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 19 TH FEB, 2015 *MISHRA VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SHRI KULEEP KUMAR SHARMA, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- THE ITO,WARD- 3 (1), JAIPUR 3. VK;DJ VK;QDRVIHY@ THE CIT(A). 4. VK;DJ VK;QDR@ CIT, JAIPUR 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO.1018/JP/2011) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR