Appeal details
Counselvise Citation
[2016] 132 COUNSELVISE.COM (IT) 5402 (ITAT-JAIPUR)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
3 month(s) 15 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
15-04-2016
Appeal Filed By
Assessee
Order Result
Dismissed
Bench Allotted
Not Allotted
Assessment Year
2001-2002
Appeal Filed On
31-12-2015
Judgement Text
VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES (SMC), JAIPUR JH VKJ-IH-RKSYKUH] U;KF;D LNL; DS LE{K BEFORE: SHRI R.P. TOLANI, JUDICIAL MEMBER VK;DJ VIHY LA-@ ITA NO. 1029 & 1030/JP/2015 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2001-02 & 2008-09 M/S. JASORIA PRODUCTS ATTE WALI GALI ALWAR CUKE VS. THE ITO WARD- 1(3) JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: AABFJ 2464 N VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT JKTLO DH VKSJ LS@ REVENUE BY :SHRI MANISH AGARWAL FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI RAJ MEHRA, JCIT-DR LQUOKBZ DH RKJH[K@ DATE OF HEARING : 17/03/2016 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 15/04/2016 VKNS'K@ ORDER PER R.P. TOLANI, JM BOTH THESE APPEALS HAVE BEEN FILED BY THE ASSESSE E AGAINST SEPARATE ORDERS OF THE LD. CIT(A), ALWAR; DATED 13- 11-2015 FOR THE ASSESSMENT YEARS 2001-02 AND 2008-09 RESPECTIVELY REGARDING IMPOSITION OF PENALTY U/S 271(1)( C) OF THE I.T. ACT, 1961. 2.1 FIRST OF ALL, WE TAKE UP THE APPEAL OF THE ASSE SSEE FOR THE ASSESSMENT YEAR 2001-02 WHEREIN THE ASSESSEE HAS CHALLENGED TH E IMPOSITION OF ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 2 PENALTY U/S 271(1)( C) OF THE ACT AMOUNTING TO RS. 1,17,934/- CONTENDING IT TO BE WITHOUT ANY JUSTIFICATION. 2.2 ALTERNATIVELY ITS CLAIMED THAT LD. CIT(A) HAS E RRED IN SUSTAINING THE PENALTY AT RS. 1,17,934/- BY COMPLETE IGNORING THAT THE TAX ALLEGED AS SOUGHT TO BE EVADED COMES TO RS. 1,12,291/- ONLY. 2.3 THE LD. COUNSEL FOR THE ASSESSEE CONTENDS THAT THE LD. CIT(A) HAS RETAINED PENALTY ON ASSUMPTION AND PRESUMPTION AND ON ESTIMATE BUSINESS WITHOUT THERE BEING FURNISHING ANY INACCUR ATE PARTICULARS OF INCOME OR CONCEALMENT OF INCOME. THE FACTS ARE THAT THE ADDITIONS IN QUESTION WERE MADE CONSEQUENT TO SURVEY CONDUCTED B Y COMMERCIAL TAX DEPARTMENT WHEREIN CERTAIN PAPERS WERE IMPOUNDED BE ING A ROBIN BRAND RED BAHI AND 82 LOOSE PAPERS, PHOTOCOPIES OF WHICH WERE SUBSEQUENTLY FORWARDED TO THE INCOME TAX DEPARTMENT. SUCH LOOSE PAPERS NOT BEING IN THE NATURE OF REGULAR BOOKS OF ACCOUNT WERE RECOMME NDED BY THE AO FOR SPECIAL AUDIT U/S 142(2A) OF THE I.T. ACT, 1961. 2.4 IN FIRST ROUND, THE ASSESSEE APPROACHED UP TO T RIBUNAL CHALLENGING THE ADDITION MADE BY THE AO ON THE BASIS OF REPORT OF SPECIAL AUDITOR. ITAT VIDE ITS ORDER IN ITA NO. 975/JP/2006 DATED 30 -05-208 SET ASIDE THE MATTER BACK TO THE AO TO GO FOR SPECIAL AUDIT U/S 1 42(2A) OF THE ACT AFRESH BY STRICTLY COMPLYING PROVISIONS OF I.T. ACT . IN THE SECOND ROUND, ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 3 THE SPECIAL AUDIT COMPLETED AND BASED THEREON THE A O MADE AN ADDITION OF RS. 9,27,027/- WHICH WAS REDUCED TO RS. 3,34,38 5/- BY THE LD. CIT(A) AFTER AWARDING RELIEF OF RS. 5,92,642/-. THE ASSESS EE ACCEPTED THE ORDER OF THE LD. CIT(A) AND DID NOT PURSUE ANY FURTHER APPEA L. PENALTY PROCEEDINGS WERE INITIATED AND AO REJECTED ASSESSEE'S EXPLANATI ON AND IMPOSED PENALTY OF RS. 3,35,802/- BEING 300% OF THE TAX SOU GHT TO BE EVADED. 2.5 AGGRIEVED, THE ASSESSEE PREFERRED FIRST APPEAL BEFORE THE LD. CIT(A) WHO REDUCED THE PENALTY FROM 300% TO 100% AT RS. 1, 17,934/-. THE LD. CIT(A) HAS GIVEN FINAL FINDING OF THE ACT AS UNDER: - (I) ADDITIONS OF RS. 3,34,202/- HAS BEEN SUSTAINED OUT OF WHICH ADDITION OF RS. 2,76,610/- PERTAIN TO UNACCOU NTED INCOME FOND TO HAVE BEEN RECORDED IN THE RED BAHI/ DIARY AND LOOSE PAPERS WERE FOUND IN THE COURSE OF SALES TAX SURVEY. (II) DUE TO SURVEY PROCEEDINGS BY COMMERCIAL/ SALES TAX DEPARTMENT, EVIDENCE OF UNACCOUNTED INCOME WAS FOUN D AND THE ADDITIONS MADE ON THAT ACCOUNT HAVE ALSO ACHIEV ED FINALITY IN THE COURSE OF QUANTUM PROCEEDINGS THERE FORE, I DO NOT FIND ANY FORCE IN THE CONTENTIONS OF THE APPELL ANT THAT NO EVIDENCE OR INCRIMINATING MATERIAL WAS FOUND IN THE COURSE OF SURVEY PROCEEDINGS. THE VERY FACT THAT SUCH INVE STMENTS HAVE BEEN HELD TO BE THE ADDITIONAL INCOME OF THE A PPELLANT FIRM IN THE COURSE OF QUANTUM APPEAL PROCEEDINGS PR OVES ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 4 BEYOND DOUBT THAT SUCH INCOME WOULD NOT HAVE BEEN DISCLOSED IN THE ABSENCE OF SURVEY PROCEEDINGS. (III) THE JUDICIAL DECISIONS RELIED BY THE APPELLAN T ARE DISTINGUISHABLE ON FACTS AND ARE FOUND TO BE NOT AP PLICABLE IN THE PRESENT FACTUAL MATRIX. FURTHER, I PLACE RELIAN CE ON THE FOLLOWING DECISION OF HON'BLE SUPREME COURT IN THE CASE OF MAK DATA (P) LTD. VS. CIT, 358 ITR 593 (SC) WHERE P ENALTY WAS HELD TO BE VALIDLY LEVIED, EVEN IF AMOUNT SURRE NDERED IN SURVEY WAS TO BUY PEACE OF MIND 2.6 AFTER THESE OBSERVATIONS, THE LD. CIT(A) HELD A S UNDER:- 4.8 IN VIEW OF THE ABOVE DISCUSSION, I HOLD THAT THE AO WAS JUSTIFIED IN INITIATING THE PENALTY PROCEEDINGS UNDER THE PROVISIONS OF SECTION 271(1)(C ) OF THE I.T. ACT. H OWEVER, I FIND FORCE IN THE CONTENTIONS OF THE APPELLANT THAT PENALTY @ 300% OF THE TAX SOUGHT TO BE EVADED IS ON THE HIGHE R SIDE. CONSIDERING THE FACTS AND CIRCUMSTANCES OF THE CASE , I HOLD THAT IT WOULD BE JUST FAIR AND TO RESTRICT THE SAME TO 100% OF THE AMOUNT OF TAX SOUGHT TO BE EVADED WORKS OUT TO RS. 1,12,291 AS AGAINST AN AMOUNT OF RS. 1,17,934/- AS WORKED OUT BY THE AO. THE ASSESSING OFFICER IS DIRECTED TO CHECK THE COMPUTATION OF THE AMOUNT OF TAX SOUGHT TO BE EVADE D AND ACCORDINGLY PROVIDE THE RELIEF TO THE APPELLANT, IF NECESSARY. ACCORDINGLY, I CONFIRM THE LEVY OF PENALTY @ 100% O F THE TAX SOUGHT TO BE EVADED OF RS. 1,17,934/- OUT OF THE TO TAL PENALTY OF RS. 3,53,802/- IMPOSED BY THE AO U/S 271(1)( C) OF THE I.T. ACT, 1961. 2.7 AGGRIEVED, THE ASSESSEE IS NOW IN SECOND APPEAL . THE LD. COUNSEL FOR THE ASSESSEE MADE ARGUMENTS, FILED THE WRITTEN SUBMISSION AND CONTENDS THAT THE ADDITION OF RS. 2,76,610/- MADE B Y THE AO U/S 69 AND ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 5 SUSTAINED BY THE LD. CIT(A). IT IS SUBMITTED THAT T HIS ADDITION WAS MADE BY HOLDING THE SAME AS INVESTMENT MADE IN PURCHASE OF KIRANA GOODS OUT OF BOOKS AND THE SAME WAS TREATED BY HIM AS UNEXPLAINE D MONEY OF ASSESSEE U/S 69 OF THE ACT. DURING THE COURSE OF SPECIAL AUD IT, THE ASSESSEE PRODUCED DULY CONFIRMED COPIES OF LEDGER ACCOUNTS B EFORE THE SPECIAL AUDITOR, WHICH WERE CONSIDERED BY THE SPECIAL AUDIT OR AND PURSUANT TO SUCH CONSIDERATION, THE OWN MONEY OF ASSESSEE WAS W ORKED OUT AT RS. 2,25,335/- (ON THE BASIS OF ROBIN BRAND RED BAHI) A ND RS. 10,333/- (ON THE BASIS OF 82 LOOSE PAPERS). THE AO DURING THE CO URSE OF ASSESSMENT PROCEEDINGS REQUIRED THE ASSESSEE TO PRODUCE SUNDRY DEBTORS AND CREDITORS FROM WHOM PAYMENTS WERE MADE/ RECEIVED AS PER THE C ONFIRMED COPIES OF LEDGER ACCOUNTS. IN COMPLIANCE THERETO, THE ASSESSE E PRODUCED 4 SUNDRY CREDITORS WHICH ARE AS UNDER:- 1. SHRI OM PRAKASH AHUJA, PROP. M/S. AHUJA FLOUR MI LLS, K.GANG, ALWAR 2. SHRI DAYA RAM AGARWAL P/O M/S. SARASWATI OIL AN D DISALLOWANCE MILLS, LAKHANDAWLA, KUA, ALWAR 3. SHRI SHIV DAYAL PROP. M/S. FAQIR CHAND ASHOK KUMAR, OLD STATION ROAD, ALWAR 4. SHRI RAM NIWAS PROP. M/S. B.R. INDUSTRIES, NEW MANDI, ALWAR ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 6 THESE PERSONS AFFIRMED BEFORE THE AO THAT THEY WERE SUNDRY CREDITORS TO THE ASSESSEE AND ENDORSED COPY OF LEDGER SUBMITTED BEFORE THE SPECIAL AUDITOR AS WELL AS DURING THE COURSE OF ASSESSMENT PROCEEDINGS. THE ASSESSEE EXPRESSED HIS INABILITY TO PRODUCE RESTS O F THE PARTIES. THE AO DID NOT MAKE ANY EFFORT TO COMPEL THEIR PRODUCTION WHICH IS NOT IN THE HANDS OF THE ASSESSEE BUT WAS WITHIN THE POWER OF A O U/S 131 OF THE ACT WHICH WAS NOT EXERCISED BY HIM. THE AO HELD THE CON FIRMED COPIES OF LEDGER SUBMITTED BY ASSESSEE AS FALSE / FABRICATED WITHOUT ANY REASON AND WITHOUT PROVIDING ANY BASIS FOR THE SAME AND MERELY BY ALLEGING THAT NO SUPPORTING EVIDENCE WAS SUBMITTED BY THE ASSESSEE. THUS THE ASSESSEE HAS SUBMITTED COMPLETE EVIDENCES IN SUPPORT OF THE GENU INENESS OF THE SUNDRY CREDITORS/ DEBTORS WHICH WERE BRUSHED ASIDE BY THE ASSESSEE. THE AO HAS LEVIED THE IMPUGNED PENALTY SOLELY ON THE BASIS OF OBSERVATIONS MADE IN THE ASSESSMENT ORDER WITHOUT ANY MANNER SATISFYING HIMSELF AS TO CONCEALMENT OF INCOME ON PART OF ASSESSEE OR FURNIS HING OF INACCURATE PARTICULARS OF INCOME. THE AO HAS COMPLETELY IGNORE D THE WELL ESTABLISHED LAW THAT QUANTUM AND PENALTY PROCEEDING S ARE QUITE DISTINCT AND SEPARATE AND IN ORDER TO LEVY PENALTY U/S 271(1 ) (C ), CONCEALMENT OF INCOME ON PART OF ASSESSEE OR FURNISHING OF INACCUR ATE PARTICULARS OF INCOME HAS TO BE PROVED WHICH HAS NOT BEEN DONE BY THE AO AND HE HAS ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 7 BLINDLY FOLLOWED THE OBSERVATIONS MADE IN THE ASSES SMENT ORDER WHILE IMPOSING PENALTY ON ASSESSEE. IT IS WELL SETTLED LA WS THAT QUANTUM AND ASSESSMENT PROCEEDINGS ARE DISTINCT AND SEPARATE AN D ASSESSEE CAN ALWAYS RAISE A FRESH PLEA IN THE PENALTY PROCEEDINGS. RELI ANCE IS PLACED AS UNDER:- (I) SMT. DURGA DEVI SOMANI VS. ITO, KISHANGARH (ITA NO. 672/JP/2011) (II) ELILLY LILLY & COMPANY, 312 ITR 225 (SC) (III) JHAVAR PROPERTIS (P) LTD. VS. ACIT , 317 ITR 278 (RAJ.) (IV) NARANG INTERNATIONAL HOTELS (P) LTD. VS. DCIT ,CIRCLE- 1(2), MUMBAI (V) NATIONAL TEXTILES VS. CIT , 249 ITR 125 (GUJ. ) (VI) GOSWAMI SMT. CHANDRALATA, 125 ITR 700 (RAJ.) AND OTHER JUDGMENTS WERE RELIED ON BY THE LD. AR. 2.8 THE LD. DR ON THE OTHER HAND CONTENDS THAT:- (I) IT HAS NOT BEEN DISPUTED THAT INCRIMINATING MA TERIALS WERE IMPOUNDED DURING THE COURSE OF SURVEY BY COMMERCIAL TAX DEPARTMENT. THESE DOCUMENTS WERE FORWARDED TO THE INCOME TAX DE PARTMENT AND SPECIAL AUDIT WAS CARRIED OUT NOT ONCE BUT TWICE. T HUS THE ADDITIONS HAVE BEEN MADE NOT ON THE VOLITION OF THE AO BUT BASED O N THE ADVERSE REMARKS OF THE SPECIAL AUDITORS AND ASSESSEE COULD NOT EXPLAIN THOSE INCONSISTENCIES. ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 8 (II) IN THE ENTIRE LENGTH AND BREADTH OF ASSESSMEN T PROCEEDINGS, APPELLATE PROCEEDINGS AND CONTENTIONS BEFORE THE IT AT, IT HAS NOT BEEN CLAIMED THAT COMMERCIAL TAX DEPARTMENT DELETED THE ADDITION WHICH CLEARLY IMPLIES THAT THE COMMERCIAL TAX DEPARTMENT HAS LEVIED THE TAX BY HOLDING THE IMPUGNED TRANSACTIONS AS UNDISCLOSED TR ANSACTIONS. THE ASSESSEE HAS NOT RAISED ANY CONTENTION THAT THE COM MERCIAL TAX DEPARTMENT HAS DELETED THE ADDITIONS. THUS THE ADDI TIONS HAVE BEEN SUSTAINED NOT ONLY ON THE BASIS OF DOCUMENTS BUT TH E FACT IS THAT THE COMMERCIAL TAX DEPARTMENT HAS NOT EXONERATED THE AS SESSEE IN THIS BEHALF. (III) THE ALLEGATION OF THE ASSESSEE THAT THE AO H AS LEVIED THE PENALTY MERELY BASED ON ASSESSMENT PROCEEDINGS IS U NJUSTIFIED AS IN PENALTY PROCEEDINGS THE AO AFTER CONSIDERING THE AS SESSEE'S EXPLANATION AND CITATIONS HAS GIVEN CLEAR FINDING OF THE FACTS AND THE COGENT AVERSE INFERENCE DRAWN AS UNDER: (1) THE ASSESSEE FIRM HAS NOT INCLUDED THE TRANSAC TIONS RECORDED IN ROBIN BRAND LAL BAHI AND 82 LOOSE PAPER S IN ITS REGULAR BOOKS OF ACCOUNT WHICH WERE AUDITED U/S 44A B (2) THE ASSESSEE DID NOT PRODUCE ANYTHING TO PROVE THAT THE TRANSACTIONS RECORDED IN ROBIN BRAND LAL BAHI A ND 82 LOOSE PAPERS ARE INCLUDED IN ITS REGULAR BOOKS OF A CCOUNT AND WERE AUDITED U/S 44AB ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 9 (3) THE ADDITIONS WERE NOT MADE BY THE LD. AO MEREL Y ON THE BASIS OF ESTIMATE, BUT THE ADDITIONS OF RS. 7,3 4,087/- WERE ON THE BASIS OF UNDISCLOSED TRANSACTIONS RECORDED T HE HON'BLE BOMBAY HIGH COURT IN THE CASE OF THE ASSES SEE IN THE ROBIN BRAND LAL BAHI AND82 LOOSE PAPERS ARE DUL Y AUDITED U/S 142(2A). THE ADDITIONS OF RS. 2,76,610/ - WERE UPHELD BY THE LD. CIT(A) ALSO. (4) THE EXISTENCE OF THE ROBIN BRAND LAL BAHIAND 82 LOOSE PAPERS AND TRANSACTION RECORDED THEREIN WHICH DOES NOT FIND PLACE IN THE REGULAR BOOKS OF ACCOUNT, HAS NOT BEEN DENIED BY THE ASSESSEE AT ANY STAGE, ITSELF IS SUFF ICIENT TO PROVE THAT THE ASSESSEE HAS CONCEALED ITS INCOME EARNED/INVESTED FROM / IN THE TRANSACTION RECORDED IN ROBIN BRAND LAL BAHI AND 82 LOOSE PAPERS. ADDITIONS OF RS . 57,775/- MADE BY THE AO WAS ALSO UPHELD BY THE LD. CIT(A). (5) THE EXISTENCE OF THE ROBIN BRAND LAL BAHI AND 8 2 LOOSE PAPERS AND TRANSACTIONS RECORDED THEREIN WERE IN THE KNOWLEDGE OF THE PARTNERS OF THE FIRM. EVEN AFTER T HE SURVEY PROCEEDINGS OF THE SALES TAX DEPARTMENT THE ASSESSE E DID NOT INCLUDE THE TRANSACTIONS RECORDED THEREIN IN ITS REGULAR BOOKS OF ACCOUNT. THIS FACT IS ITSELF SUFFICIENT TO PROVE THE MOTIVE OF THE ASSESSEE TO CONCEAL ITS INCOME AND IN VESTMENT RECORDED IN ROBIN BRAND LAL BAHI AND 82 LOOSE PAPER S. IN VIEW OF THESE FACTS, IT IS CONTENDED THAT PENALT Y HAS BEEN IMPOSED AFTER CLEARLY DEMONSTRATING THAT THE ASSESSEE FURNISHED I NACCURATE PARTICULARS OF INCOME AND CONCEALED THE INCOME. 2.9 I HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. I FIND MERIT IN THE CONTENTION S OF THE LD. DR THAT THE ADDITIONS ARE NOT BASED ON ANY ASSUMPTIONS AND PRES UMPTIONS AS CLAIMED BY THE ASSESSEE BUT THE AO HAD INCRIMINATING MATERI ALS IN THE SAID ROBIN ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 10 BRAND LAL BAHI AND 82 LOOSE PAPERS AND TRANSACTIONS RECORDED THEREIN. THE ASSESSEE HAS NOT CONTROVERTED THE FACTS THAT TH ESE TRANSACTIONS DO NOT FIND PLACE IN THE BOOKS OF ACCOUNT. IT IS OBSERVED THAT THERE IS A SUBSTANCE IN THE CONTENTION OF THE LD. DR THAT THE ASSESSEE H AS NOT MADE ANY PLEADINGS THAT THE COMMERCIAL TAX DEPARTMENT HAS DE LETED THESE ADDITIONS. THE IMPOUNDED RECORDS WERE CONFRONTED TO THE ASSESSEE BY THE AO AND AFTER CONSIDERING THESE FACTS THE PENALTY HA S BEEN RIGHTLY RETAINED AT 100% TAX SOUGHT TO BE EVADED. 3.1 APROPOS ALTERNATIVE GROUND ABOUT 100% TAX SOUGH T TO BE EVADED AT RS. 1,21,291/- AND NOT AT RS. 1,17,934/-, THE AO WI LL WORK OUT THE FIGURE AND FINALIZE THE PENALTY ACCORDINGLY. 4.0 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DI SMISSED WITH ABOVE DIRECTIONS. 5.1 IN ITA NO. 1030/JP/2015 THE ASSESSEE HAS CHALLE NGED THE IMPOSITION OF PENALTY U/S 271(1)( C) OF THE ACT AMO UNTING TO RS. 52,738/- WITHOUT ANY JUSTIFICATION. THE ISSUE AS TO IMPOSIT ION OF PENALTY HAS BEEN DECIDED BY US AGAINST THE ASSESSEE IN ITA NO. 1029/ JP/2015 FOR THE ASSESSMENT YEAR 2001-02 AND BEING THE SAME FACTS AN D CIRCUMSTANCES OF THE ASSESSEE, HENCE THE DECISION TAKEN BY THIS BENC H IN THE APPEAL OF THE ASSESSEE FOR THE ASSESSMENT YEAR 2001-02 SHALL APPL Y MUTATIS MUTANDIS TO ITA NO.1029/JP/2015 M/S. JASORIA PRODUCTS VS. ITO, WARD- 1 (3),JAIPUR . 11 THE APPEAL OF THE ASSESSEE FOR THE 2008-09 ALSO. T HEREFORE, THE APPEAL OF THE ASSESSEE IS DISMISSED. 6.0 IN THE RESULT, APPEALS OF THE ASSESSEE ARE DISM ISSED AS INDICATED ABOVE. ORDER PRONOUNCED IN THE OPEN COURT ON 15 /04/201 6. SD/- VKJ-IH-RKSYKUH (R.P.TOLANI) U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 15 /04/ 20156 *MISHRA VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO:- 1. VIHYKFKHZ@ THE APPELLANT- M/S. JASORIA PRODUCTS, ALWAR 2. IZR;FKHZ@ THE RESPONDENT- THE ITO, WARD- 1 (3), JAIPUR 3. VK;DJ VK;QDRVIHY@ CIT(A). 4. VK;DJ VK;QDR@ CIT, 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO. 1029/JP/2015) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR
