THE DY. CIT-1(1), RAIPUR (CG) V. SHRI ABHAY JAIN, RAIPUR (CG)

ITA 109/BIL/2014

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 9108 (ITAT-RAIPUR)
• Duration Of Justice: 2 year(s) 9 month(s) 29 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-05-2017
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2010-2011
• Appeal Filed On: 10-07-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: D K JAIN
• Assessee Lawyers: R B DOSHI
• Keywords: Unexplained cash credit; Business income
• Section: 143(3); 68

Judgement Text

. IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE S/SHRI N.S SAINI, ACCOUNTANT MEMBER AND GEORGE GEORGE K, JUDICIAL MEMBER ITA NO. 109 /RPR /201 4 ASSESSMENT YEAR : 2010 - 2011 DCIT - 1(1), RAIPUR VS. SHRI ABHAY JAIN, PROP. M/S. ABHAY LOGISTICS, H.NO.104, MARUTI ENCLAVE, TATIBANDH, RAIPUR PAN/GIR NO. ACMPJ 5664 P (APPELLANT ) .. ( RESPONDENT ) C.O.NO.06/RPR/2014 (ARISING OUT OF ITA NO. 109/RPR/2014) ASSESSMENT YEAR :2010 - 2011 SHRI ABHAY JAIN, PROP. M/S. ABHAY LOGISTICS, H.NO.104, MARUTI ENCLAVE, TATIBANDH, RAIPUR VS. DCIT - 1(1), RAIPUR PAN/GIR NO. ACMPJ 5664 P (CROSS OBJECTOR ) .. ( RESPONDENT ) ASSESSEE BY : SHRI R.B.DOSHI, AR REVENUE BY : SHRI D.K.JAIN, DR DATE OF HEARING : 4 /05 / 2017 DATE OF PRONOUNCEMENT : 8 /05 / 2017 2 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 O R D E R PER N.S.SAINI, AM THE APPEAL FILED BY THE REVENUE AND CROSS OBJECTION FILE BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER OF CIT(A) - RAIPUR, DATED 17.4.2014, FOR THE ASSESSMENT YEAR 2010 - 2011. 2. IN GROUND NO.1 OF THE APPEAL, THE GRIEVANCE OF THE REVENUE IS THAT THE CIT(A) ERRED IN DELETING THE ADDITION OF RS.53,27,925/ - MADE BY THE ASSESSING OFFICER ON ACCOUNT OF UNEXPLAINED CASH CREDIT U/S.68 OF THE ACT. 3. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSING OFFICER THAT THE ASSESSEE HAD TAKEN UNSECURED LOAN AS PER THE BALANCE SHEET OF THE ASSESSEE AS ON 31.3.2010 OF RS.53,27,925/ - , THE DETAILS OF WHICH ARE AS UNDER: SR.NO. NAME OF LOAN CREDITORS AMOUNT (RS.) 1. ASHOK KOTHARI, AKOLA 10,00,000 2. REKHACHAND LUNIA, RAIPUR 14,00,000 - 3. R.K.TRANSPORT, DURG 10,00,000 4. SHEKHAR SHAHU 4,00,000 5. ASHA DEVI LUNIA 6,00,000 6. TARACHAND JAIN 4,48,995 7. TARACHAND JAIN & SONS(HUF) 4,78,930 TOTAL: 53,27,925 3 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 4. HE OBSERVED THAT THE ASSESSEE HAS NOT PROVED THE CREDITWORTHINESS OF THE LOAN CREDITORS AND ADDED RS.53,27,925/ - TO THE INCOME OF THE ASSESSEE. 5. ON APPEAL, THE CIT(A) OBSERVED TH A T THE UNSECURED LOAN OF RS.10,00,000/ - FROM ASHOK KOTHARI, RS.4,48,995/ - FROM TARACHAND JAIN AND RS.4,78, 930/ - F ROM TARACHAND JAIN & SONS (HUF) AGGREGATING TO RS.19,27,925/ - WERE RAISED IN THE PREVIOUS ASSESSMENT YEAR AND NOT DURING THE ASSESSMENT YEAR UNDER CONSIDERATION. HE OBSE RVED THAT THE CARRY FORWARD CASH CREDIT BALANCES CANNOT BE ADDED U/S.68 OF THE ACT. HE OBSERVED THA T THE ASSESSMENT IN THE THAT YEAR HAS BEEN COMPLETED U/S.143(3) AN D UPON FILING CONFIRMATIONS THAT YEAR, THE ISSUE CANNOT BE RAKED UP NOW. HE OBSERVED THAT AS REGARDS THE LOANS OBTAINED FROM M/S. R.K.TRANSPORT OF RS .14,00,000/ - , SHRI SHEKHAR SAHU OF RS.4,00,000/ - AND SMT. ASHA DEVI LUNIA OF RS.6,00,000/ - AGGREGATING TO RS.24,00,000/ - , THE ASSESSEE FILED XEROX COPY OF INCOME TAX RETURNS OF THE LOAN CREDITORS AND, THEREFORE, IN VIEW OF THE EVIDENCE PRODUCED IN SUPPORT OF THE UNSECURED LO ANS AND ALSO THE DECISIONS RELIED IN THE CASE OF (I) RAMESH CHANDR A R AVINDRA KUMAR RAI VS ITO, 14 TTJ 34 (2010 ) , (JAB) ; (II) ACIT V. HEENA INVESTMENT PVT LTD.,, 141 TTJ 772 (JODH); (III) CIT VS. PARMESHWAR BOHARA (2008) 301 ITR 404(RAJ) AND (IV) CIT VS. US HA STUD AGRICULTURAL FARMS LTD 4 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 (2008) 301 ITR 384 (DEL), THE ADDITION OF RS.53,27,925/ - MADE UNDER SECTION 68 OF THE ACT CANNOT BE SUSTAINED. 6. LD D.R. RELIED ON THE ORDER OF THE ASSESSING OFFICER. 7. LD A.R. SUBMITTED THAT IT WILL BE OBSERVED FROM PAPER BOOK FILED BY THE ASSESSEE THAT THE ASSESSEE FILED BEFORE THE ASSESSING OFFI C ER ON 8.3.2013, THE REQUIRED DETAILS OF UNSECURED LOAN S IN THE PRESCRIBED FORMAT , COPY OF WHICH IS PLACED AT PAGE 22 OF THE PAPER BOOK . AGAIN AT PAGE 24 AND 25 OF THE PAPER BOOK IS PLACED LETTER DATED 8.3.2013 ALONGWITH WHICH THE ASSESSEE FILED DETAILS OF UNSECURED LOAN S AS PER THE PRESCRIBED FORMAT WITH CONFIRMATION OF ALL UNSECURED LOANS RECEIVED DURING THE YEAR AND ADDITION TO THE OL D UNSECURED LOANS. FURTHER, IT WILL BE OBSERVED FROM PAGES 26 - 27 OF THE PAPER BOOK THAT VIDE LETTER DATED 12.3.2013, THE ASSESSEE FILED BEFORE THE ASSESSING OFFICER, COPY OF ALL UNSECURED LOAN LENDER S INCOME TAX RETURN, COMPUTATION OF TOTAL INCOME, CAPIT AL ACCOUNT WITH BALANCE SHEET . HE SUBMITTED THAT IN DOING SO, THE ASSESSEE DISCHARGE D ITS INITIAL BURDEN, WHICH LAY UPON HIM AS PER SECTION 68 OF THE ACT TO PROVE THE GENUINENESS OF THE TRANSACTIONS, IDENTITY OF THE LOAN CREDITORS AND CREDITWORTHINESS OF LOAN CREDITORS. HE SUBMITTED THAT THEREAFTER THE ASSESSING OFFICER AFTER EXAMINING THE SAME HAS NOT BROUGHT ANY MATERIAL ON RECORD TO SHOW THAT THE LOANS ARE NOT GENUINE OR THE LOAN CREDITORS DID NOT HAVE THE CAPACITY TO 5 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 ADVANCE THE LOANS TO THE ASSESSEE. THEREFORE, THE CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION. HE FURTHER SUBMITTED THAT OUT OF TOTAL LOAN OF RS. 53,27,925/ - , RS.19,27,925/ - WAS THE OPENING BALANCE BROUGHT FORWARD FROM THE EARLIER YEARS, WHEREIN, IN AN ASSESSMENT UNDER SECTION 143(3) O F THE ACT, THE LOANS WERE ACCEPTED AS GENUINE BY THE ASSESSING OFFICER AND, THEREFORE, THE CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION ON THAT COUNT ALSO. 8. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS OF LOWER AUTHORITIES AND MATERIALS A VAILABLE ON RECORD. IN THE INSTANT CASE, THE ASSESSING OFFICER OBSERVED FROM THE BALANCE SHEET OF THE ASSESSEE AS ON 31.3.2010 THAT THE ASSESSEE HAD TAKEN UNSECURED LOAN OF RS.53,27,925/ - FROM 7 LOAN CREDITORS. THE ASSESSING OFFICER OBSERVING THAT THE AS SESSEE HAS NOT DISCHARGED HIS ONUS OF PROVING THE LOANS TAKEN, ADDED THE S AME UNDER SECTION 68 OF THE ACT TO THE TOTAL INCOME OF THE ASSESSEE. 9. ON APPEAL, THE CIT( A) FOUND THAT OUT OF LOANS OF RS.53,27,9 25/ - TAKEN FROM 7 PERSONS, LOANS OF RS.19,27,925/ - TAKEN FROM THREE PERSONS, NAMELY; ASHOK KOTHARI, AKOLA, TARACHAND JAIN AND TARACHAND JAIN & SONS ( HUF) WERE BROUGHT FORWARD BALANCES FROM EARLIER YEARS, WHICH WAS ACCEPTED AS GENUINE BY THE ASSESSING OFFICER IN AN ASSESSMENT U/S.143(3 ) OF THE ACT. THEREFORE, HE DELETED THE ADDITION OF RS.19,27,925/ - FOR THE R EASON THAT 6 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 U/S.68 OF THE ACT, THE ADDITION TO THE INCOME OF THE ASSESSEE AS UNEXPLAINED CASH CREDIT CAN BE MADE WHERE ANY SUM IS FOUND CREDITED IN THE BOOK OF AN ASSESSEE MAINTAINED FOR ANY PREVIOUS YEAR, AND THE ASSESSEE OFFERS NO EXPLANATION ABOUT THE NATURE AND SOURCE THEREOF OR THE EXPLANATION OFFERED BY HIM IS NOT, IN THE OPINION OF THE ASSESSING OFFICER, SATISFACTORY. NO ERROR IN THIS FINDING OF THE CIT(A) COULD BE POINTED OUT BY LD D.R. DURING THE COURSE OF HEARING. FURTHER, IT IS OBSERVED THAT REGARDING BALANCE FOUR LOAN CREDITORS FROM WHOM LOAN OF RS.24,00,000/ - WAS TAKEN BY THE ASS ESSEE, THE ASSESSEE FILED THE LOAN CONFIRMATIONS, COPY OF INCOME TAX RETURNS, BALA NCE SHEET, COMPUTATION OF INCOME AND CAPITAL ACCOUNT OF THE LOAN CREDITORS. THUS, THE ASSESSEE HAS DISCHARGED ITS INITIAL BURDEN OF PROVING THE IDENTITY, GENUINENESS AND CREDITWORTHINESS OF LOAN CREDITORS. THEREAFTER, THE ASSESSING OFFICER HAS NOT BROUGH T ANY MATERIAL ON RECORD TO SHOW THAT EITHER THE LOAN CREDITORS ARE BOGUS OR THAT THEY DID NOT HAVE THE CAPACITY TO ADVANCE THE LOAN TO THE ASSESSEE. THEREFORE, IN OUR CONSIDERED VIEW, THE ADDITION U/S.68 OF THE ACT TO THE INCOME OF THE ASSESSEE IS NOT WA RRANTED. OUR ABOVE VIEW FINDS SUPPORT FROM THE DECISION OF HONBLE SUPREME COURT IN THE CASE OF CIT VS ORISSA CORPORATION PVT LTD., 159 ITR 78 (SC), WHEREIN, IT WAS HELD AS UNDER: 7 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 THE ASSESSEE HAD GIVEN THE NAMES AND ADDRESS OF THE ALLEGED CREDITORS. IT WAS IN THE KNOWLEDGE OF THE REVENUE THAT THE SAID CREDITORS WERE INCOME TAX ASSESSES. THEIR INDEX NUMBER WAS IN THE FILE OF THE REVENUE. THE REVENUE, APART FROM ISSUING NOTICES UI/ S.131, AT THE INSTANT OF THE ASSESSEE, DID NOT PURSUE THE MATTER FURTHER. THE REVENUE DID NOT EXAMINE THE SOURCE OF INCOME OF THE SAID ALLEGED CREDITORS TO FIND OUT WHETHER THEY WERE CREDITWORTHY OR WERE SUCH WHO COULD ADVANCE THE ALLOWED LOANS. THERE WA S NO EFFORT MADE TO PURSUE THE SO - CALLED ALLEGED CREDITORS. IN THOSE CIRCUMSTANCES, THE ASSESSEE COULD NOT DO ANY FURTHER. IN THE PREMISES, IF THE TRIBUNAL CAME TO THE CONCLUSION THAT THE ASSESSEE HAS DISCHARGED THE BURDEN THAT LAY ON HIM THEN IT COULD N OT BE SAID SUCH A CONCLUSION WAS UNREASONABLE OR PERVERSE OR BASED ON NO EVIDENCE. 10. THEREFORE, WE FIND NO INFIRMITY IN THE ORDER OF THE CIT(A) IN DELETING THE ADDITION OF RS.53,27,925/ - MADE U/S.68 OF THE ACT ON ACCOUNT OF UNEXP LAINED CASH CREDIT. HENCE, THE ORDER OF THE CIT(A) IS CONFIRMED AND GROUND OF REVENUE IS DISMISSED. 11. IN GROUND NO.2 OF THE APPEAL, THE GRIEVANCE OF THE REVENUE IS THAT THE CIT(A) ERRED IN DELETING THE ADDITION OF RS.4,02,523/ - MADE BY THE ASSESSING OFF ICER ON ACCOUNT OF INTEREST ON UNSECURED LOAN. 12. WE FIND THAT THIS GROUND OF APPEAL IS CONSEQUENTIAL TO GROUND NO.1 OF APPEAL OF THE REVENUE. THE DISALLOWANCE OF INTEREST WAS MADE BY THE ASSESSING OFFICER AS HE HAD HELD THAT THE UNSECURED LOAN AS NOT GE NUINE AND ADDED THE SAME U/S.68 OF THE ACT. AS WE HAVE CONFIRMED THE ORDER OF THE CIT(A) THAT TH E LOAN CREDITORS ARE GENUINE , THEREFORE, THE DISALLOWANCE OF 8 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 INTEREST PAID TO THE LOAN CREDITORS CANNOT BE MADE. ACCORDINGLY, WE HOLD THAT THE CIT(A) WAS JUS TIFIED IN DELETING THE DISALLOWANCE OF INTEREST OF RS.4,02,523/ - MADE BY THE ASSESSING OFFICER. HENCE, WE DO NOT FIND ANY MERIT IN THIS GROUND OF THE REVENUE AND DISMISS THE SAME. 13. IN GROUND NO.3 OF THE APPEAL, THE GRIEVANCE OF THE REVENUE IS THAT THE CIT(A) ERRED IN DELETING THE ADDITION OF RS.60,000/ - MADE BY THE ASSESSING OFFICER ON ACCOUNT OF LOW WITHDRAWALS FOR HOUSEHOLD EXPENSES. 14. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS OF LOWER AUTHORITIES AND MATERIALS AVAILABLE ON RECORD. THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE HAD SHOWN ONLY RS.60,000/ - AS HOUSEHOLD WITHDRAWALS. HE OBSERVED THAT THE FAMILY OF THE ASSESSEE CONSISTING OF TWO ADULTS AND TWO CHILDREN AND THE AMOUNT WAS NOT SUFFICIENT TO MEET THE REQUIREMENTS OF HOU SEHOLD EXPENSES AND, THEREFORE, ESTIMATED THE HOUSEHOLD EXPENSES OF THE ASSESSEE AT RS.1,20,000/ - AND MADE THE ADDITION OF RS.60,000/ - TO THE INCOME OF THE ASSESSEE. 15. ON APPEAL, THE CIT(A) DELETED THE ADDITION OF RS.60,000/ - ON THE GROUND THAT THE WIFE OF THE ASSESSEE IS INCOME TAX ASSESSEE WHO HAS SHOWN WITHDRAWAL OF RS.60,000/ - FOR HOUSEHOLD EXPENSES IN HER RETURN OF INCOME FILED. 9 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 16. LD D.R. COULD NOT POINT OUT ANY SPECIFIC ERROR IN THE FINDINGS OF THE CIT(A). 17. ON THE OTHER HAND, LD A.R. OF THE ASSESSEE HAS FILED COPY OF BALANCE SHEET OF THE WIFE OF THE ASSESSEE, SMT. CHANCHAL JAIN, PLACED AT PAGE 72 OF THE PAPER BOOK , WHICH SHO WS THE DRAWING OF RS.60,000/ - FOR HOUSEHOLD EXPENSES. 18. IN VIEW OF THE ABOVE , WE F IND NO GOOD REASON TO INTERFERE WITH THE ORDER OF THE CIT(A), WHICH IS HEREBY CONFIRMED AND GROUND OF APPEAL OF THE REVENUE IS DISMISSED. 19. IN THE CROSS OBJECTION, THE ASSESSEE HAS CHALLENGED THE CONFIRMATION OF ADDITION OF RS.1,33,269/ - MADE BY THE ASSE SSING OFFICER BY ESTIMATING THE NET PROFIT RATE. 20. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS OF LOWER AUTHORITIES AND MATERIALS AVAILABLE ON RECORD. IN THE INSTANT CASE, THE UNDISPUTED FACTS ARE THAT THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE HAS DERIVED INCOME FROM THE BUSINESS OF CIVIL CONTRACT. THE ASSESSEE WAS ASKED TO PRODUCE COMPARISON CHART OF TURNOVER, GROSS PROFIT AND NET PROFIT WITH LAST YEAR OF THE BUSINESS OF THE ASSESSEE. ON PERUSAL OF COMPARISON CHART, HE OBSERVED T HAT THE NET PROFIT WAS SHOWN AT 5.02% IN COMPARISON TO 10 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 LA S T YEAR WHICH WAS 5.29%. THE ASSESSING OFFICER REQUIRED THE ASSESSEE TO EXPLAIN THE REASON OF DECREASE OF THE RATIO IN GROSS PROFIT AND NET PROFIT. SINCE, THE ASSESSEE DID NOT POINT OUT ANY REASON IN FALL IN GROSS PROFIT/NET PROFIT, HE ESTIMATED THE INCOME BY APPLYING NET PROFIT AT 5.67% AND ADDED RS. 1,33,269/ - TO THE INCOME OF THE ASSESSEE. 21. ON APPEAL, THE CIT(A) CONFIRMED THE ACTION OF THE ASSESSING OFFICER. 22. BEFORE US, LD A.R. ARGUED THAT THE ASSESSING OFFICER HAS NOT REJECTED THE BOOKS OF ACCOUNT PRODUCED BY THE ASSESSEE. NO EXPENDITURE SHOWN IN THE BOOKS OF ACCOUNT OF THE ASSESSEE HAS BEEN FOUND TO BE INFLATED OR NOT FOR THE PURPOSE OF THE BUSINESS OF THE ASSESSEE. NO BUSINESS RECEIPT HAS BEEN FOUND TO BE SUPPRESSED OR NOT SHOWN BY THE ASSESSEE. HENCE, HE ARGUED THAT WITHOUT REJECTING BOOKS OF ACCOUNT OF THE ASSESSEE, THE ASSESSING OFFICER CANNOT MAKE ESTIMATE OF THE INCOME OF THE ASSESSEE BASED ON THE TURNOVER OF THE ASSESSEE. HENCE, HE PRAYED THAT THE ADDITION SHOULD BE DELETED. 23. LD D.R. RELIED ON THE ORDERS OF LOWER AUTHORITIES. 11 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 24. WE FIND THAT IT IS NOT IN DISPUTE THAT BOOKS OF ACCOUNT OF THE ASSESSEE HAS NOT BEEN REJECTED BY THE ASSESSING OFFICER BEFORE ESTI MATING THE INCOME OF THE ASSESSEE BY APPLYING NET PROFIT RATE. THEREFORE, IN OUR CONSIDERED VIEW, THE ADDITION OF RS.1,33,269/ - TO THE INCOME OF THE ASSESSEE CANNOT BE SUSTAINED IN LAW. OUR ABOVE VIEW FINDS SUPPORT FROM THE DECISION OF CUTTACK BENCH OF T HE TRIBUNAL IN THE CASE OF UTKAL ALLOYS STEEL LTD VS DCIT, 82 ITD 120 (CTC) CONFIRMED BY THE HONBLE ORISSA HIGH COURT IN CIT VS. UTKAL ALLOYS STEELS LTD., 319 ITR 339 (ORI), YOG RAJ & SONI VS ACIT, 108 TTJ 912, ACIT V/S INTERMEDIA CABLE COMMUNICATION PVT LTD, 145 TTJ 476 ( PUNE) . THEREFORE, WE SET ASIDE THE ORDERS OF LOWER AUTHORITIES AND DELETE THE ADDITION OF RS.1,33,269/ - AND ALLOW THE GROUND TAKEN IN CROSS OBJECTION BY THE ASSESSEE. 25. IN THE RESULT, THE APPEAL F ILED BY THE REVENUE IS DISMISED AND CROSS OBJECTION FILED BY THE ASSESSEE IS ALLOWED. ORDER PRONOUNCE D IN THE OPEN COURT ON 8 /05 /2017 IN THE PRESENCE OF PARTIES. SD/ - SD/ - (GEORGE GEORGE K ) ( N.S SAINI) JUDICIAL MEMBER A CCOUNTANT MEMBER RAIPUR ; DATED 8 /05 /2017 B.K.PARIDA, SPS 12 ITA NO. 109/RPR/2014 C.O.NO.04/RPR/2014 ASSESSMENT YEAR :2010 - 2011 COPY OF THE ORDER FORWARDED TO : BY ORDER, SR.PRIVATE SECRETARY 1. THE APPELLANT : DCIT - 1(1), RAIPUR 2. THE RESPONDENT. SHRI ABHAY JAIN, PROP. M/S. ABHAY LOGISTICS, H.NO.104, MARUTI ENCLAVE, TATIBANDH, RAIPUR 3. THE CIT(A) RAIPUR 4. PR.CIT , RAIPUR 5. DR, ITAT, RAIPUR 6. GUARD FILE. //TRUE COPY//