M/S MORANI CARS PVT. LTD., JAIPUR V. ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-6, JAIPUR

ITA 1088/JPR/2018

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 7512 (ITAT-JAIPUR)
• Duration Of Justice: 3 month(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-01-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2010-2011
• Appeal Filed On: 18-09-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: P P MEENA JCIT A
• Keywords: Retrospective amendment; Fair market value; Corroborative evidences; Notional interest; Commercial expediency
• Section: 40(a)(ia)

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S,A JAIPUR JH FOT; IKY JKO] U;KF;D LNL; ,OA JH FOE 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. 1088/JP/2018 FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2010-11 M/S MORANI CARS PVT. LTD., 14, BAJAJ NAGAR, JAIPUR. CUKE VS. THE ACIT, CIRCLE-6, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AAFCM 1226 N VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESP ONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI P.C. PARWAL (C.A.) JKTLO DH VKSJ LS @ REVENUE BY : SHRI P.P. MEENA (JCIT) A LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 01/01/2019 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 09/01/2019 VKNS'K@ ORDER PER: VIKRAM SINGH YADAV, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST TH E ORDER OF LD. CIT(A), JODHPUR (CAMP AT JAIPUR) DATED 14.06.2018 W HEREIN THE ASSESSEE HAS TAKEN THE FOLLOWING GROUNDS OF APPEAL: 1. THE LD. CIT(A) HAS ERRED ON FACTS AND IN LAW IN CONFIRMING THE DISALLOWANCE OF RS. 1,80,000/- OUT OF REMUNERATION PAID TO DIRECTOR. ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 2 2. THE LD. CIT(A) HAS ERRED ON FACTS AND IN LAW IN CONFIRMING THE DISALLOWANCE OF AUDIT FEES OF RS. 64,000/- U/S 40(A )(IA) OF THE IT ACT, 1961. 3. THE LD. CIT(A) HAS ERRED ON FACTS AND IN LAW IN CONFIRMING THE ADDITION OF RS. 17,60,000/- ON ACCOUNT OF NOTIONAL INTEREST CALCULATED ON INTEREST FREE DEPOSIT GIVEN TO M/S MORANI MOTORS PV T. LTD. AND M/S GENERAL HANDICRAFTS (JAIPUR) PVT. LTD. HE HAS FURTH ER ERRED IN NOT CONSIDERING THAT THE ABOVE DEPOSIT WAS GIVEN IN COM MERCIAL EXPEDIENCY AND ASSESSEE ALSO HAS INTEREST FREE FUNDS WHICH EXC EED THE INTEREST FREE DEPOSITS PROVIDED BY THE ASSESSEE. 2. IN RESPECT OF GROUND NO. 1, BRIEFLY THE FACTS OF THE CASE THAT THE ASSESSEE COMPANY IS AN AUTHORIZED DEALER OF HYUNDAI CARS. IT FILED ITS RETURN OF INCOME ON 14.10.2010 DECLARING TOTAL INCO ME OF RS.23,24,650/-. DURING THE YEAR, IT PAID REMUNERATI ON OF RS.3,60,000/- TO MR. JAWAHAR MORANI, DIRECTOR OF THE COMPANY. IN SUPPORT OF THE SAME, ASSESSEE SUBMITTED COPY OF BOARD RESOLUTION H ELD ON 29.09.2009 ACCORDING TO WHICH REMUNERATION @ RS.30,000/- P.M. SHALL BE PAYABLE RETROSPECTIVELY FROM 01.04.2009 ONWARDS. THE AO OBS ERVED THAT REMUNERATION PAID TO THE DIRECTOR OF A COMPANY IS A N ALLOWABLE EXPENSE WITHIN THE PROVISION OF INCOME TAX ACT, HOWEVER, TH E EXPENSES ARE ALLOWABLE IN PROSPECTIVE NATURE. IN THE PRESENT CAS E, THE DECISION OF ASSESSEE COMPANY IS SUPPORTED WITH A RESOLUTION PAS SED AT THE MEETING OF BOARD OF DIRECTORS HELD ON 29.09.2009. THE RESOL UTION CANNOT HAVE A RETROSPECTIVE EFFECT ESPECIALLY WHEN IT IS A BENEFI CIAL PROVISION. SUCH RESOLUTION HAS EFFECT FROM THE DATE OF PASSING THE SAME. ACCORDINGLY, REMUNERATION PAID FOR THE PERIOD PRIOR TO PASSING T HE RESOLUTION, BEING RS.1,80,000/- (FROM 01.04.2009 TO 29.09.2009 @ RS.3 0,000/- P.M.) WAS DISALLOWED. ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 3 3. ON APPEAL, LD. CIT(A) HELD THAT THE DATE ON WHIC H THE WORK OF DIRECTOR WAS BEING PERFORMED WAS NOT BACKED BY ANY AUTHORITY. IT IS ONLY ON A LATER DATE THAT THE RESOLUTION IS PASSED BY THE ASSESSEE TO REGULARIZE SUCH AN IRREGULARITY. THIS CANNOT BE ALL OWED AS ELIGIBLE EXPENDITURE. ACCORDINGLY, HE CONFIRMED THE DISALLOW ANCE MADE BY THE AO. 4. DURING THE COURSE OF HEARING, THE LD AR SUBMITT ED THAT REMUNERATION PAID TO MR. JAWAHAR MORANI, DIRECTOR O F THE COMPANY IS NOT IN DISPUTE. IT IS DULY SUPPORTED BY RESOLUTION PASSED AT THE BOARD MEETING HELD ON 29.09.2009. THE ONLY DISPUTE IS WHE THER REMUNERATION PAID FOR THE PERIOD APRIL, 2009 TO SEPTEMBER, 2009 IS ALLOWABLE OR NOT. THE AO HAS OBSERVED THAT A BENEFICIAL RESOLUTION CA NNOT HAVE RETROSPECTIVE EFFECT WHEREAS A BENEFICIAL RESOLUTIO N ALWAYS HAS A RETROSPECTIVE EFFECT. SIMILARLY, THE OBSERVATION OF LD. CIT(A) THAT THE DATE ON WHICH WORK OF DIRECTOR WAS BEING PERFORMED WAS NOT BACKED BY ANY AUTHORITY IS INCORRECT AS THE SAME IS BACKED BY THE BOARD RESOLUTION AND AS PER THE MASTER DATA OF THE COMPANY DOWNLOADE D FROM MCA WEBSITE, IT CAN BE NOTED THAT MR. JAWAHAR MORANI IS WORKING AS A DIRECTOR OF THE COMPANY FROM 26.06.2007 BUT HE WAS PAID REMUNERATION ONLY FROM 01.04.2009. 5. IT WAS FURTHER SUBMITTED BY THE LD AR THAT UNDE R THE INCOME TAX ACT, REMUNERATION PAID TO DIRECTOR CAN BE DISALLOWE D U/S 40A(2) IF THE REMUNERATION SO PAID IS EXCESSIVE OR UNREASONABLE H AVING REGARD TO THE FMV OF THE SERVICES OR FACILITIES FOR WHICH PAYMENT IS MADE. IN THE ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 4 PRESENT CASE, IT IS NOT THE CASE OF LOWER AUTHORITI ES THAT REMUNERATION PAID TO MR. JAWAHAR MORANI IS EXCESSIVE OR UNREASON ABLE. THE REMUNERATION SO PAID IS REASONABLE. HENCE, THE LOWE R AUTHORITIES HAVE INCORRECTLY DISALLOWED THE EXPENDITURE. 6. THE LD. DR IS HEARD WHO HAS RELIED ON THE FINDIN GS OF THE LOWER AUTHORITIES. 7. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. THE DIRECTOR OF THE ASSESSEE C OMPANY HAS BEEN WORKING SINCE 26.06.2007 AND THEREFORE, FOR THE PER IOD STARTING 1.4.2009 ONWARDS, HE WAS WORKING FOR THE COMPANY AN D THE COMPANY IN TURN IS BENEFITTED BY HIS SERVICES. THE ASSESSE E COMPANY TOOK A DECISION ON 29.09.2009 AT ITS BOARDS MEETING BY PA SSING AN APPROPRIATE RESOLUTION TO PAY REMUNERATION TO ITS DIRECTOR W.E. F 1.4.2009 AND THUS THE REMUNERATION SO PAID IS DULY AUTHORIZED AND PAI D FOR THE PERIOD HE HAS RENDERED SERVICES TO THE ASSESSEE COMPANY. THE RE IS NOTHING WHICH HAS BEEN BROUGHT ON RECORD TO SUGGEST THAT A RESOLUTION PASSED AT THE BOARD MEETING CANNOT HAVE A RETROSPECTIVE EF FECT FROM START OF THE FINANCIAL YEAR. THERE ARE DECISIONS WHERE ARE TAKEN VERBALLY AT TIMES AND WHICH ARE SUBSEQUENTLY REDUCED IN WRITING AND SUCH DECISIONS SO LONG AS TAKEN IN THE INTEREST OF THE COMPANY AFT ER DUE APPLICATION OF MIND AND IN ABSENCE OF ANY PATENT ILLEGALITY OR MAL AFIDE CANNOT BE CHALLENGED BY THE REVENUE. IT IS ALSO NOT THE CASE OF THE REVENUE THAT THE DIRECTOR HAS NOT SHOWN THE REMUNERATION IN HIS RETURN OF INCOME AND HAS NOT PAID TAXES THEREOF. THEREFORE, WE DONO T SEE ANY INFIRMITY IN THE ASSESSEE COMPANY DECISION IN ABSENCE OF ANY LOSS TO THE ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 5 REVENUE. IN LIGHT OF THE SAME, DISALLOWANCE OF DI RECTORS REMUNERATION IS HEREBY DIRECTED TO BE DELETED. 8. IN GROUND NO. 2, BRIEFLY THE FACTS OF THE CASE A RE THAT DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE AO OBSERVED T HAT ASSESSEE HAS MADE PAYMENT OF AUDIT FEES AMOUNTING TO RS.64,000/- . HOWEVER, SINCE ASSESSEE FAILED TO DEDUCT TDS AS REQUIRED U/S 194J, HE DISALLOWED RS.64,000/- U/S 40(A)(IA) OF IT ACT AND WHICH HAS B EEN CONFIRMED BY THE LD CIT(A). 9. AT THE OUTSET, THE LD AR SUBMITTED THAT ASSESSEE HAS NOT CLAIMED EXPENDITURE ON PAYMENT OF AUDIT FEES AT RS.64,000/- . IT HAS MADE PROVISION FOR AUDIT FEES AT RS.55,000 + 10.3% SERVI CE TAX, TOTALING TO RS.60,665/- WHICH IS CREDITED TO AUDIT FEES PAYABLE ACCOUNT. THUS, THE CLAIM OF AUDIT FEES IS RS.60,665/- AND NOT RS.64,00 0/-. THEREFORE, DISALLOWANCE OF RS.64,000/- IS INCORRECT AND THE SA ME BE RESTRICTED TO RS.55,000/-. 10. IT WAS FURTHER SUBMITTED BY THE LD AR THAT THE AUDIT WAS CARRIED OUT IN SUBSEQUENT PERIOD BY M/S KHILNANI & ASSOCIAT E. THE AUDIT REPORT WAS SIGNED ON 25.08.2010. THE ACTUAL PAYMENT WAS MA DE ON 10.11.2011 WHEN IT WAS ACTUALLY PAID THE AUDIT FEES FOR FY 2009-10 & 2010-11 AT RS.1 LACS ON WHICH TAX WAS DEDUCTED AT S OURCE OF RS.10,000/-. THUS, WHEN SERVICES WAS PROVIDED IN FY 2010-11 AND TAX IS ALSO DEDUCTED AT SOURCE SUBSEQUENTLY, DISALLOWANCE U/S 40(A)(IA) IS NOT JUSTIFIED. IN CASE IT IS HELD DISALLOWABLE, THEN AO BE DIRECTED TO ALLOW THE SAME IN AY 2012-13 WHEN ACTUAL PAYMENT IS MADE. ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 6 11. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. WE DONT SEE ANY INFIRMITY IN THE ACTION OF THE LOWER AUTHORITIES IN DISALLOWING THE AUDIT FEE IN TERMS O F SECTION 40(A)(IA), AT THE SAME TIME, THE AO IS DIRECTED TO ALLOW THE SAME IN THE YEAR OF ACTUAL PAYMENT SUBJECT TO VERIFICATION. IN THE RES ULT, THE GROUND IS DISPOSED OFF. 12. IN RESPECT OF GROUND NO. 3, BRIEFLY THE FACT OF THE CASE ARE THAT DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE AO OBSERVED THAT ASSESSEE HAS MADE PAYMENT OF RENT AMOUNTING TO RS.1 8,81,000/- TO THE FOLLOWING PARTIES:- S. NO. NAME OF PARTY ADDRESS OF LEASED PREMISES TOTAL RENT PAID SECURI TY DEPOSIT 1. M/S CHIMAN ENTERPRISES S - 137, RIICO INDUSTRIAL AREA, SITAPURA RS.2,52,000/- RS.60,000/- 2. SMT. VIMLA BARWA S - 137, RIICO INDUSTRIAL AREA, SITAPURA RS.1,89,000/ - RS.45,000/ - 3. M/S MORANI MOTORS (P) LTD. SITABARI, TONK ROAD, JAIPUR RS.12,00,000/- RS.1 CRORE THE INTEREST FREE SECURITY DEPOSIT IN RESPECT OF PR OPERTIES MENTIONED AT S.NO.1 & 2 IS IN AGREEMENT WITH LEASE DEED AND IS N EARLY EQUAL TO AN AMOUNT OF RENT FOR THREE MONTHS WHICH IS GENERAL MA RKET TREND. HOWEVER, SECURITY DEPOSIT IN RESPECT OF PROPERTY ME NTIONED AT S.NO.3 IS NOT IN AGREEMENT WITH RELEVANT LEASE AGREEMENT. NO SUCH CONDITION HAS BEEN LAID DOWN IN THE LEASE AGREEMENT. THE AMOUNT O F SECURITY DEPOSIT ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 7 IS AT HIGHER SIDE WITH REFERENCE TO THE MARKET TREN D. THE RENT PAID BY THE ASSESSEE IN RESPECT OF PROPERTY IS QUITE REASON ABLE AND CANNOT BE SAID TO BE AT LOWER SIDE. THE OWNER OF THE PROPERTY , I.E. M/S MORANI MOTORS (P) LTD. IS A SISTER CONCERN OF THE ASSESSEE COMPANY. FURTHER, THE ASSESSEE HAS TAKEN PREMISES ON RENT FOR CONSTRU CTION OF WORKSHOP FROM M/S GENERAL HANDICRAFTS (JAIPUR) PVT. LTD. AT SITAPURA INDUSTRIAL AREA, JAIPUR AND HAS DEPOSITED INTEREST FREE SECURI TY DEPOSIT OF RS.74 LACS. HOWEVER, NO SUPPORTING EVIDENCE IN THIS REGAR D HAS BEEN FURNISHED. THE LOCALITY OF PREMISES UNDER REFERENCE IS EXACTLY SAME AS OF THE PREMISES MENTIONED AT S.NO.1 & 2 ABOVE. THE ASS ESSEE HAS ALLOWED UNREASONABLE INTEREST FREE DEPOSIT WITH M/S GENERAL HANDICRAFTS (JAIPUR) PVT. LTD. MOREOVER, M/S GENERAL HANDICRAFTS (JAIPUR ) PVT. LTD. IS A SISTER CONCERN OF THE ASSESSEE COMPANY. THE OWN FUNDS AVAI LABLE WITH THE ASSESSEE WERE NOT SUFFICIENT TO MEET THE BUSINESS R EQUIREMENTS. HENCE, THE ASSESSEE HAS RAISED INTEREST BEARING LOANS FROM VARIOUS BANKS & PRIVATE PARTIES AND HAS ALLOWED UNDUE PROFIT TO ITS RELATED PARTIES IN THE SHAPE OF INTEREST FREE SECURITY DEPOSITS WITHIN THE MEANING OF PROVISIONS OF SECTION 40A(2)(B) OF THE IT ACT. ACCORDINGLY, IN TEREST @12% (AS ASSESSEE COMPANY HAS RAISED INTEREST BEARING LOANS ON IDENTICAL RATES), I.E. RS.17,60,000/- (AS PER THE WORKING GIVEN AT PG 8 OF THE AOS ORDER) WAS DISALLOWED. 13. ON APPEAL, THE LD. CIT(A) CONFIRMED THE DISALLO WANCE BY HOLDING THAT IN VIEW OF THE PROVISIONS OF SECTION 40A(2)(B) OF THE ACT, ANY UNDUE BENEFIT TO SPECIFIED PERSONS AS COVERED BY THESE PR OVISIONS IS REQUIRED TO BE DISALLOWED TO THE EXTENT PROVIDED AND THUS, A O HAS RIGHTLY MADE THE ADDITION OF RS.17,20,000/- U/S 40A(2)(B) OF THE ACT. ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 8 14. DURING THE COURSE OF HEARING, THE LD. AR SUBMIT TED THAT ASSESSEE HAS GIVEN RS.1 CRORE TO M/S MORANI MOTORS PVT. LTD. IN EARLIER YEARS AND RS.74 LACS TO M/S GENERAL HANDICRAFTS (JAIPUR) PVT. LTD. DURING THE YEAR. FROM BOTH THE PARTIES, THE ASSESSEE HAS TAKEN THE P REMISES ON RENT. FROM M/S MORANI MOTORS PVT. LTD., A SHOWROOM MEASUR ING 4752 SQ. FT. AT MAIN TONK ROAD IS TAKEN ON RENT IN THE YEAR UNDE R CONSIDERATION FOR WHICH RENT OF RS.1 LACS PER MONTH IS PAID. THUS, TH ERE IS A COMMERCIAL EXPEDIENCY IN PROVIDING INTEREST FREE DEPOSIT OF RS .1 CRORE TO M/S MORANI MOTORS PVT. LTD. SIMILARLY, INTEREST FREE DEPOSIT O F RS.74 LACS WAS PROVIDED TO M/S GENERAL HANDICRAFTS (JAIPUR) PVT. L TD. FROM WHOM PROPERTY SITUATED AT G-227,SITAPURA INDUSTRIAL AREA , JAIPUR HAVING AREA OF 2041 SQM. IS TAKEN ON RENT FROM 01.04.2010 AT RS .50,000/- P.M. THUS, THE INTEREST FREE DEPOSIT IS PROVIDED IN COMM ERCIAL EXPEDIENCY. THE HONBLE SUPREME COURT IN CASE OF CIT VS. S.A. BUILD ERS 288 ITR 1 HAS HELD THAT INTEREST ON MONIES BORROWED FROM BANK AND LENT TO SISTER CONCERN WITHOUT CHARGING INTEREST IS ADMISSI BLE IF MADE AS A MEASURE OF COMMERCIAL EXPEDIENCY. THEREFORE, DISAL LOWANCE OF INTEREST BY CALCULATING NOTIONAL INTEREST ON SUCH AMOUNT @ 1 2% P.A. IS UNJUSTIFIED. 15. THE LD. AR FURTHER SUBMITTED THAT THAT ASSESSEE HAS INTEREST FREE FUNDS BY WAY OF SHARE CAPITAL, SHARE APPLICATION MO NEY AND RESERVE & SURPLUS TO THE EXTENT OF RS.2,29,86,932/-. THIS IS MORE THAN THE INTEREST FREE SECURITY DEPOSIT OF RS.1.74 CRORES. THUS, WHEN INTEREST FREE FUNDS ARE MORE THAN THE INTEREST FREE SECURITY DEPOSIT, N O DISALLOWANCE OUT OF ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 9 INTEREST CAN BE MADE. IN SUPPORT, RELIANCE WAS PLAC ED ON THE FOLLOWING DECISIONS:- HERO CYCLES PVT. LTD. VS. CIT (2016) 379 ITR 347/ 2 36 TAXMAN 447 (SC) CIT VS. RAM KISHANVERMA(2016) 132 DTR 107 (RAJ) CIT VS. VIJAY SOLVEX LTD. (2015) 113 DTR 382 (RAJ) CIT VS. RELIANCE UTILITIES & POWER LTD. 313 ITR 340 (BOM) 16. THE LD. DR IS HEARD WHO HAS RELIED ON THE FINDI NGS OF THE LOWER AUTHORITIES. 17. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. THE ASSESSEE HAS EXPLAINED THE BUSINESS NECESSITY OF TAKING THE PREMISES ON RENT AND PLACING THE SECU RITY DEPOSIT. FURTHER, THE AO HAS NOT ESTABLISHED THE NEXUS BETWE EN THE INTEREST BEARING BORROWED FUNDS AND AMOUNT PLACED AS SECURIT Y DEPOSIT. THEREFORE, WHERE THE INTEREST FREE FUNDS ARE SUFFIC IENT TOWARDS PLACING THE SECURITY DEPOSIT AND THE COMMERCIAL EXPEDIENCY OF TAKING THE PREMISES ON RENT HAVING BEEN ESTABLISHED AND THE RE NT PAYMENT HAS BEEN ALLOWED, THERE IS NO BASIS FOR NOTIONAL DISALL OWANCE OF INTEREST EXPENSES. IN THE RESULT, THE ADDITION SO MADE BY T HE AO IS HEREBY SET- ASIDE. IN THE RESULT, THE GROUND OF APPEAL IS ALLO WED. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOW ED IN LIGHT OF ABOVE DIRECTIONS. ITA NO. 1088/JP/2018 M/S MORANI CARS PVT. LTD. VS. ACIT 10 ORDER PRONOUNCED IN THE OPEN COURT ON 09/01/2019. SD/- SD/- FOT; IKY JKO FOE FLAG ;KNO (VIJAY PAL RAO) (VIKRAM SINGH YADAV) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 09/01/2019. *SANTOSH VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- M/S MORANI CARS PVT. LTD., JAIPUR. 2. IZR;FKHZ@ THE RESPONDENT- ACIT, CIRCLE-6, 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. 1088/JP/2018} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR