SUPERSONIC TURNERS PVT. LTD, Jaipur V. ACIT, Jaipur

ITA 1129/JPR/2016

• Counselvise Citation: [2018] 126 COUNSELVISE.COM (IT) 2049 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 2 month(s) 5 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 28-02-2018
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Next Hearing Date: 19-05-2017
• Assessment Year: 2012-2013
• Appeal Filed On: 23-12-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: K C GUPTA
• Keywords: Gross profit estimation; Principle of natural justice; Additional evidence; Corroborative evidences; Onus to prove
• Section: 40A(3); 133(6); 131; 68

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 FOT; IKWY 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. 1129/JP/2016 FU/KZKJ.K O'K Z@ ASSES SMENT YEARS : 2012-13 M/S SUPERSONIC TURNERS PVT. LTD., F-393-A, ROAD NO. 9-F-2, VKI AREA, JAIPUR CUKE VS. ACIT, CIRCLE-6, JAIPUR LFKK;H YS[KK LA -@THVKBZVKJ LA -@ PAN/GIR NO.: AADCS5144H VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI SATISH GUPTA (CA) JKTLO DH VKSJ LS @ REVENUE BY : SHRI K.C. GUPTA (JCIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 26/02/2018 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 28/02/2018 VKNS'K@ ORDER PER: VIKRAM SINGH YADAV, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER OF LD. CIT(A)-2, JAIPUR DATED 25.08.2016 FOR ASSESSMENT YEAR 2012-13 WHEREIN THE ASSESSEE HAS TAKEN THE FOLLOWING GROUNDS OF APPEAL: 1. ON THE FACTS & CIRCUMSTANCES OF THE CASE & IN LAW ALSO LD. LOWER AUTHORITIES GROSSLY ERRED IN MAKING DISALLOWANCE OF RS. 25 LACS ON A/C OF JOB WORK PAYMENT BY FOLLOWING THE DECISION OF CIT(A) FOR A.Y. 2010-11 (APPEAL NO. 358/12-13) ONLY WITHOUT CONSIDERING THE FACTS INDEPENDENTLY. ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 2 2. ON THE FACTS & CIRCUMSTANCES OF THE CASE & IN LAW ALSO LD. LOWER AUTHORITIES GROSSLY ERRED IN MAKING DISALLOWANCE OF RS. 15 LACS ON A/C OF THE CERTAIN EXP. LIKE WAGES, TELEPHONE, CONVEYANCE, STATIONERY, OFFICE AND REPAIR & MAINTENANCE ON LUMPSUM BASIS WITHOUT MAKING ANY SPECIFIC DETAILS. 3. ON THE FACTS & CIRCUMSTANCES OF THE CASE & IN LAW ALSO LD. CIT (A) GROSSLY ERRED IN CONFIRMING THE ADDITION OF RS. 97,05,000/- U/S 68 OF THE INCOME TAX ACT, 1961. 4. ON THE FACTS & CIRCUMSTANCES OF THE CASE & IN LAW ALSO LD CIT(A) GROSSLY ERRED IN HOLDING THAT THE GROUND OF APPEAL IS DISMISSED WHERE AS LD. CIT(A) HAS ONLY CONFIRMED THE ADDITION OF RS. 97,05,000/- (71,80,000/- + 25, 75,000/-) AS CLEAR FOR THE LAST PARA OF APPEAL ORDER AGAINST THE GRIEVANCE OF ASSESSEE FOR THE ADDITION OF RS. 1,63,55,000/- U/S 68 OF THE INCOME TAX ACT 1961, MADE BY THE AO. 2. AT THE OUTSET, THE LD. AR SUBMITTED THAT GROUND NO. 1 OF THE ASSESSEES APPEAL IS SQUARELY COVERED BY THE DECISION OF THE COORDINATE BENCH IN ASSESSEES OWN CASE IN ITA NO. 276/JP/2014 DATED 23.02.2017 FOR AY 2010-11 WHEREIN RELEVANT FINDINGS OF THE CO-ORDINATE BENCH ARE AS UNDER:- 6. WE HAVE HEARD THE RIVAL CONTENTIONS AND PURSUED THE MATERIAL AVAILABLE ON RECORD. THE ASSESSING OFFICER HAS DISALLOWED A LUMP SUM AMOUNT OF RS.25 LACS OUT OF RS. 8,77,81,594/- JOB WORK EXPENSES ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 3 CLAIMED BY THE ASSESSEE IN ITS PROFIT & LOSS ACCOUNT. AS PER THE ASSESSING OFFICER, THE BILLS SUBMITTED BY THE ASSESSEE FOR VERIFICATION DONOT CONTAIN ANY DETAILED DESCRIPTION OF THE WORK AND SOME OF BILLS WERE FOUND TO BE UNSIGNED AND SOME OF THE BILLS WERE SIGNED IN THE SAME HANDWRITING. THE MATTER WAS AGAIN EXAMINED BY THE LD. CIT(A). CONSIDERING THE DEFECTS IN VOUCHERS AND SUBSTANTIAL CASH PAYMENT OF MORE THAN RS.20 LACS PAID TO RELATED PARTY, M/S PAWANSUT AND GIVEN THAT THE EXPENSES DISALLOWED BY THE ASSESSING OFFICER IS LESS THAN 3% OF THE TOTAL EXPENSES CLAIMED, THE DISALLOWANCE MADE BY THE ASSESSING OFFICER WAS FOUND REASONABLE AND DISALLOWANCE WAS CONFIRMED BY LD CIT(A). THE LD. A.R. HAS SUBMITTED THAT 100% OF THE JOB WORK EXPENSES ARE VOUCHED AND NO SPECIFIC INSTANCE OF ANY UNVOUCHED EXPENSES HAS BEEN GIVEN BY THE LOWER AUTHORITIES. ALL THE BILLS CONTAINS THE DESCRIPTION OF WORK DONE, THOUGH IN SHORT FORM, AS PER THE TRADE PRACTICE AND CUSTOM OF THE ASSESSEE TRADE. SO FAR AS THE PAYMENT IN CASH IS CONCERNED, THE SAME WAS MADE WITHIN THE PERMISSIBLE LIMITS OF SECTION 40A(3) OF THE ACT. WE HAVE GIVEN A CAREFUL CONSIDERATION TO THE MATTER AND WE ARE OF THE VIEW THAT THE ASSESSEES CONTENTION DESERVES TO BE ACCEPTED. FIRSTLY, THE ADDITION HAS BEEN MADE ON PURELY AN ADHOC BASIS WITHOUT HIGHLIGHTING ANY SPECIFIC INSTANCE WHERE THE PAYMENT IS NOT ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 4 VERIFIABLE OR THE EXPENSES CLAIMED BY THE ASSESSEE ARE BOGUS OR HAVE NOT BEEN INCURRED FOR THE PURPOSE OF BUSINESS. FURTHER, NO SPECIFIC INSTANCE OF CASH PAYMENT HAS BEEN HIGHLIGHTED WHICH HAS VIOLATED THE PROVISIONS OF SECTION 40A(3) OF THE ACT. IN LIGHT OF ABOVE, WE HEREBY DELETE THE DISALLOWANCE OF RS.25 LACS MADE BY THE ASSESSING OFFICER. IN THE RESULT, GROUND NO.1 OF THE ASSESSEE IS ALLOWED. 3. UNDISPUTEDLY, THERE ARE NO CHANGES IN THE FACTS AND CIRCUMSTANCES OF THE CASE. THE LD CIT(A) HAS ALSO RETURNED A FINDING THAT NATURE OF EXPENDITURE AND DEFECTS POINTED OUT BY THE AO ARE IDENTICAL TO AY 2010-11. FOLLOWING THE DECISION OF THE CO-ORDINATE BENCH FOR AY 2010-11 REFERRED SUPRA, THE GROUND NO. 1 OF THE ASSESSEES APPEAL IS ALLOWED. 4. REGARDING GROUND NO. 2, BRIEFLY, THE FACTS OF THE CASE ARE THAT THE ASSESSEE HAS CLAIMED VARIOUS EXPENSES IN THE NATURE OF WAGES, TELEPHONE, CONVEYANCE, STATIONERY, OFFICE AND REPAIR & MAINTENANCE EXPENSES TOTALLING TO RS. 1,93,30,521/- IN ITS PROFIT AND LOSS ACCOUNT. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSEE WAS ASKED TO PRODUCE SUPPORTING VOUCHERS TO SUBSTANTIATE ITS CLAIM AND ON VERIFICATION OF THE VOUCHERS SO PRODUCED BY THE ASSESSEE, MANY DEFECTS WERE NOTICED BY THE AO WHICH WERE CONFRONTED TO THE ASSESSEE VIDE ORDERSHEET ENTRY DATED 13.03.2015 AND THE ASSESSEE WAS ASKED TO SHOW CAUSE AS TO WHY LUMPSUM DISALLOWANCE OUT OF THESE EXPENSES SHOULD NOT BE MADE. IN RESPONSE, THE ASSESSEE SUBMITTED THAT IT MAINTAINING VOUCHERS TO THE EXTENT POSSIBLE FOR PURCHASE, SALES, WAGES AND OTHER ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 5 EXPENSES INCLUDING TELEPHONE, CONVEYANCE, STATIONARY, OFFICE EXPENSES AND REPAIR AND MAINTENANCE EXPENSES. FURTHER DAY TO DAY REGISTER IS MAINTAINED AS PER NORMS OF EXCISE DEPARTMENT. ALL THE BOOKS ARE AUDITED BY A CHARTERED ACCOUNTANT. THEREFORE NO DISALLOWANCE IS CALLED FOR. HOWEVER, THE AO OBSERVED THAT AS SOME OF THE EXPENSES WERE SHOWN THROUGH SELF MADE VOUCHERS WITHOUT ANY SUPPORTING, THEREFORE THE SAME CANNOT BE CONSIDERED TO BE COMPLETELY GENUINE BEYOND REASONABLE DOUBT. IT WAS FURTHER OBSERVED BY THE AO THAT ALL THE EXPENSES WERE INCURRED IN CASH AND CASH IS A VERY VOLATILE FACTOR IN THE BUSINESS WHICH CAN BE MANIPULATED VERY EASILY. ON VOUCHERS, NO CROSS SIGNATURE OF PARTNER AND ACCOUNTANT WAS DONE. NO VOUCHER NUMBERS WERE MENTIONED ON THESE VOUCHERS. IT WAS OBSERVED BY THE AO THAT DEBITING OF BOGUS EXPENSE IN THE FORM OF CASH IS VERY EASY BECAUSE IT NEED JUST A DEBIT ENTRY IN THE BOOKS OF ACCOUNTS AND A SELF MADE VOUCHERS. AS ALL THESE EXPENSES WERE INCURRED IN CASH AND FOR ALL DEBIT ENTRY, NO WELL MAINTAINED SUPPORTING EVIDENCE WERE PRODUCED BY THE ASSESSEE, SO IT CANNOT BE PROVED THAT THE WHOLE EXPENSES WERE INCURRED FOR BUSINESS PURPOSE. FINALLY, THE AO OBSERVED AS UNDER:- CONSIDERING THE ABOVE DISCREPANCIES, THE GENUINENESS OF THE EXPENDITURE IS NOT PROVED. IN FACT, THE ASSESSEE HAD INFLATED THESE EXPENSES, FOR WHICH IT HAD NO EXPLANATION. AFTER VERIFICATION OF PAYMENT VOUCHERS, IT WAS NOTICED THAT THESE, VOUCHERS WERE NOT MAINTAINED IN PROPER MANNER. ON SOME VOUCHERS DATE WERE NOT MENTIONED, ON SOME SIGNATURE WERE NOT THERE, ON SOME VOUCHERS THE EXPENSES HEAD WAS NOT MENTIONED. THUS, THE ONUS IS ON THE ASSESSEE TO BRING ALL MATERIAL FACTS ON RECORD TO SUBSTANTIATE ITS CLAIM. A PERSON WHO CLAIMS THAT HE HAS MADE CERTAIN EXPENDITURE IS EXPECTED TO HAVE ALL DOCUMENTARY EVIDENCE ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 6 IN RESPECT OF THE CLAIM SO MADE. UNDER THESE CIRCUMSTANCES, I AM CONSTRAINED TO HOLD THAT THE ASSESSEE HAS INFLATED VARIOUS EXPENSES TO ITS P & L A/C. HOWEVER, SINCE 10% OF ABOVE EXPENSES AMOUNTS TO RS. 19,33,052/- THEREFORE, I PROCEED FOR A LUMP SUM DISALLOWANCE OF RS. 15,00,000/- OUT OF THE ABOVE EXPENSES WHICH IS VERY JUSTIFIED AND REASONABLE LOOKING TO THE NATURE OF EXPENSES. 5. BEING AGGRIEVED, THE ASSESSEE HAS CARRIED THE MATTER IN APPEAL BEFORE LD. CIT(A) WHO HAS CONFIRMED THE SAID ADDITION AND HIS FINDINGS ARE REPRODUCED AS UNDER:- I HAVE PERUSED THE FACTS OF THE CASE, THE ASSESSMENT ORDER AND THE SUBMISSIONS OF THE APPELLANT. ON EXAMINATION OF THE EXPENSES UNDER THE SIX HEADS ENUMERATED ABOVE AND THE DETAILS PRODUCED THEREIN, THE ASSESSING OFFICER NOTICED DEFECTS WHICH WERE CONFRONTED TO THE ASSESSEE VIDE ORDER DATED 13.03.2015. AS REPRODUCED BY THE ASSESSING OFFICER, IT HAD BEEN SUBMITTED THAT THE ASSESSEE WAS MAINTAINING VOUCHERS TO THE EXTENT POSSIBLE FOR PURCHASE SALES WAGES AND OTHER EXPENSES IN INCLUDING TELEPHONE, CONVEYANCE, STATIONARY, OFFICE EXPENSES AND REPAIR AND MAINTENANCE EXPENSES. THUS, IT IS CLEAR THAT THE EXPENSES INCURRED UNDER THESE HEADS COULD NOT BE PROVED TO HAVE BEEN INCURRED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS. THE ASSESSING OFFICER HAS DISALLOWED LESS THAN 10% OF THIS EXPENDITURE WHICH IS FOUND TO BE REASONABLE, THE DISALLOWANCE MADE IS CONFIRMED. GROUND OF APPEAL IS DISMISSED. 6. DURING THE COURSE OF HEARING, THE LD. AR SUBMITTED THAT A COPY OF ACCOUNTS OF ALL SUCH EXPENSES WERE SUBMITTED BEFORE LD. CIT(A). A ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 7 COMPARISON CHART OF EXPENSES INCURRED IN COMPARISON TO EARLIER YEAR IS ALSO SUBMITTED HEREWITH:- S.N. HEAD EXPENSE CLAIMED IN FY 2011-12 EXPENSES CLAIMED IN FY 2010-11 1. WAGES 1,44,62,259.00 1,46,97,626.00 2. TELEPHONE 6,97,895.00 9,20,912.00 3. CONVEYANCE 19,52,539.00 23,27,759.00 4. STATIONERY 7,98,871.00 6,75,975.00 5. OFFICE EXPENSES 6,32,520.00 5,84,374.00 6. REPAIR & MAINTENANCE EXPENSES 7,86,437.00 9,20,912.00 YOUR HONOURS SHALL KINDLY APPRECIATE THAT THE EXPENDITURE INCURRED DURING THE YEAR ON LESSER SIDE IN COMPARISON OF IMMEDIATE PRECEDING YEAR EXCEPT IN THE CASE OF PRINTING AND STATIONERY & OFFICE EXPENSES. NO SPECIFIC DETAILS OF ANY DEFECT IN THE VOUCHES HAS BEEN GIVEN IN ASSESSMENT ORDER OR WAS COMMUNICATED TO THE ASSESSEE AND SHOW CAUSE WAS ASKED FOR MAKING THE LUMPSUM DISALLOWANCE. THE ASSESSEE SUBMITTED THAT HE HAS MAINTAINED 100% VOUCHERS FOR THESE EXPENSES BUT THE SAME WAS WRITTEN IN PARA 5.2 AT PAGE 6 OF ASSESSMENT ORDER THAT VOUCHERS ARE MAINTAINED TO THE EXTENT POSSIBLE. THIS ACTION OF LD. AO IS TOTALLY UNLAWFUL. ALL THE PAYMENT OF WAGE, TELEPHONE, CONVEYANCE, ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 8 STATIONERY, OFFICE EXPENSES AND REPAIR & MAINTENANCE EXPENSES ARE VOUCHED. COPY OF LEDGER A/C OF ABOVE EXPENSES ALONGWITH SALARY AND WAGE PAYMENT SHEETS WERE SUBMITTED BEFORE LD. AO & LD. CIT(A). LD. AO HAS NOT AT ALL DISCHARGED HIS ONUS TO PROVE THE EXPENSE INGENUINE AND NOT FOR WHOLLY AND EXCLUSIVELY FOR PURPOSE OF BUSINESS. LD. AO HIMSELF HAS ACCEPTED FOUR CRITERIA OUT OF 5 ARE FULFILLED BY THE ASSESSEE. THEREFORE DISALLOWANCE WITHOUT BRINGING THE ADVERSE MATERIAL ON RECORD IN RESPECT OF NOT INCURRING EXPENDITURE WHOLLY & EXCLUSIVELY FOR THE BUSINESS IS TOTALLY UNLAWFUL. A DETAILED REPLY WAS FILED BEFORE LD. AO DURING THE YEAR THE ASSESSEE COMPANY HAS SHOWN GP RATE @ 14.66% ON TURNOVER OF RS. 56.13 CRORE IN COMPARISON TO 15.53% ON TURNOVER OF RS. 57.29 CRORE IN PREVIOUS YEAR. LIKEWISE NP RATE IS 2.38% FOR THE AY 2012-13 WHEREAS IT WAS 3.49% IN PREVIOUS YEAR. SIR, WE SUBMIT THAT GP RATE AND NP RATE IS SLIGHTLY LOWER DURING THE YEAR IN COMPARISON TO PREVIOUS YEAR WHICH IS NEGLIGIBLE. HOWEVER REASON FOR LOW GP IS THAT DURING THE YEAR COST OF MATERIAL, LABOUR CHARGES AND ELECTRICITY CHARGES WERE HIGHER IN COMPARISON TO PREVIOUS YEAR. FURTHER GOODS WAS SOLD AT LESSER PRICE DURING THE YEAR DUE TO THROAT-CUT COMPETITION IN THE MARKET AND TO MAINTAIN TURNOVER. THE ASSESSEE IN MAINTAINING 100% VOUCHERS FOR PURCHASES, SALES, WAGES AND OTHER EXPENSES INCLUDING TELEPHONE, CONVEYANCE, STATIONERY, OFFICE EXPENSES AND REPAIR AND MAINTENANCE EXPENSES. FURTHER DAY TO DAY STOCK REGISTER IS MAINTAINED AS PER NORMS OF EXCISE DEPARTMENT. ALL THE BOOKS ARE AUDITED BY A CHARTERED ACCOUNTANT. THEREFORE WE SUBMIT THAT TRADING RESULTS SHOULD BE ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 9 ACCEPTED AS PER BOOKS OF ACCOUNT OF THE ASSESSEE AND NO DISALLOWANCE OF RS. 15 LACS AGAINST LOW G.P/LOW N.P. SHOULD BE MADE. THE CASE LAWS CITED BY LD. AO ARE DIFFERENT ON THE FACTS OF THE ASSESSEE CASE. THE CASE OF MAROLIA AND SONS V/S CIT DECIDED BY HONBLE ALLAHABAD HIGH COURT WAS IN REGARDS TO DISALLOWANCE OF INTEREST BECAUSE THERE WERE HUGE DEBITS IN THE NAME OF SHRI RAMDEO MAROLIA PARTNER AND THE DEPARTMENT WAS OF THE VIEW THAT INTEREST BEARING LOAN WAS UTILIZED FOR THE ASSESSEE FOR NON BUSINESS PURPOSES WHICH INCLUDED WITHDRAWALS BY RAMDEO MAROLIA. IN OUR CASE NO SUCH FINDING HAS BEEN GIVEN BY LD. AO IN RESPECT OF ANY EXPENDITURE. IN ANOTHER CASE OF CIT VS. SUJANI TEXTILE PVT. LTD. 151 ITR 0653 HONBLE MADRAS HIGH COURT CONSIDERED THE FACT WHERE ASSESSEE COMPANY BORROWED THE MONEY AND PAID THE INTEREST. THE SAID AMOUNT WAS ADVANCED TO A DIRECTOR AND THEREFORE NO INTEREST HAS BEEN CHARGED. IN OUR CASE NO SUCH FACT WAS BROUGHT BY LD. AO. IT IS THEREFORE SUBMITTED THAT THE DISALLOWANCE MADE BY LD. AO AND CONFIRMED BY LD. CIT(A) IS BAD IN LAW BECAUSE: 1. NO SPECIFIC INSTANCE HAS BEEN GIVEN BY LD. AO MENTIONING THE DEFECTS IN THE VOUCHERS. 2. THE EXPENSES ARE 100% VOUCHED. 3. MOST OF THE EXPENSES CLAIMED ARE NO LESSER SIDE IN COMPARISON TO IMMEDIATELY PRECEDING YEAR. IN PARA 5.6 AT PAGE 8 OF ASSESSMENT ORDER, LD. AO HAS HELD THAT SINCE 10% OF ABOVE EXPENSES AMOUNTING RS. 19,33,052/- AND THEREFORE I PROCEED FOR A LUMPSUM DISALLOWANCE OF RS. ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 10 15,00,000/-. YOUR HONOUR THE INCOME TAX ACT DOES NOT PERMIT SUCH TYPE OF LUMPSUM DISALLOWANCE. 7. THE LD DR IS HEARD WHO HAS VEHEMENTLY ARGUED THE MATTER AND RELIED UPON THE ORDER OF THE LOWER AUTHORITIES. 8. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. THE AO HAS OBSERVED THAT CERTAIN VOUCHERS WERE SELF-MADE WITHOUT ANY SUPPORTING; ON SOME VOUCHERS, DATE WAS NOT MENTIONED AND NOT PROPERLY SIGNED; ON SOME OF THE VOUCHERS, THE EXPENSE HEAD TO WHICH THE EXPENSE PERTAINS IS NOT MAINTAINED AND BESIDES THAT, THE PAYMENTS HAVE BEEN MADE IN CASH. THEREAFTER, THE AO HAS MADE A LUMP SUM DISALLOWANCE OF RS 15 LACS WHICH IS LESS THAN 10% OF THESE EXPENSES AND THE SAME HAS BEEN FOUND REASONABLE BY THE LD CIT(A). MERE FACT THAT THE VOUCHERS ARE SELF MADE WITH THE OBSERVATION THAT PROPER BILLS AND VOUCHERS QUA THE EXPENDITURE IS NOT MAINTAINED, CANNOT BE SAID TO BE A SUFFICIENT REASONING AS WHAT WAS IMPROPER IN THE VOUCHERS HAS NOT BEEN SPELT OUT. MERE FACT THAT THE EXPENDITURE HAS BEEN INCURRED IN CASH CANNOT BE SUFFICIENT REASONING TO DISALLOW THE EXPENDITURE WITHOUT BRINGING ON RECORD THE NATURE AND QUANTUM OF SUCH CASH EXPENSES AND THE CIRCUMSTANCES UNDER WHICH THE ASSESSEE CLAIMED TO HAVE INCURRED SUCH EXPENSES IN CASH. IN OUR VIEW, IT IS A CASE WHERE THE AO HAS NOTICED CERTAIN DISCREPANCIES IN THE VOUCHERS HOWEVER THE NATURE OF DISCREPANCIES AS SPELT OUT IN THE ASSESSMENT ORDER IS NOT SUFFICIENT ENOUGH TO HOLD THAT THE EXPENDITURE HAS NOT BEEN INCURRED FOR THE PURPOSES OF ASSESSEES BUSINESS. FURTHER, THE QUANTUM OF DISALLOWANCE HAS NO NEXUS WITH THE INDIVIDUAL EXPENSE HEADS OR EXPENSE ITEMS WHICH WERE NOT FOUND ACCEPTABLE TO AO. FOR ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 11 INSTANCE, THE TELEPHONE EXPENSES HAVE BEEN DISALLOWED. UNLESS IT IS A CASE WHERE THERE ARE NO TELEPHONE BILLS ON RECORD OR A FINDING THAT THE TELEPHONE FACILITY HAS NOT BEEN USED FOR BUSINESS PURPOSES AND THE PAYMENT HAS STILL BEEN MADE, ONE CANNOT UNDERSTAND AS TO WHY THERE SHOULD BE A DISALLOWANCE OF TELEPHONE EXPENSES EVEN IF THE PAYMENT IS MADE IN CASH SUBJECT TO 40A(3) LIMITATION. SIMILARLY, WAGES HAVE BEEN DISALLOWED WHEN THE TRADING RESULTS HAVE ALREADY BEEN ACCEPTED. IN OUR VIEW, IT IS CASE OF ADHOC DISALLOWANCE OF EXPENSES WHICH CANNOT BE SUSTAINED IN THE EYES OF LAW. IN THE RESULT, THE ADDITION SO MADE BY THE AO IS HEREBY DELETED. GROUND NO. 2 OF ASSESSEES APPEAL IS THUS ALLOWED. 9. REGARDING GROUND NO. 3, BRIEFLY THE FACTS OF THE CASE ARE THAT D URING THE YEAR UNDER CONSIDERATION, THE ASSESSEE HAS TAKEN UNSECURED LOANS AMOUNTING TO RS 15,34,98,000 FROM 166 PARTIES. THE ASSESSEE WAS ASKED TO FURNISH THE DETAILS OF UNSECURED LOANS (NAME, ADDRESS AND PAN) AND ALSO TO FILE CONFIRMATION FROM THESE PARTIES. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSEE FURNISHED CONFIRMATION IN RESPECT OF SOME OF THESE PARTIES AND FOR SOME OF THESE PARTIES, IT FURNISHED PAN DETAILS. THE ASSESSING OFFICER ON THE BASIS OF PAN DETAILS FURNISHED BY THE ASSESSEE, CALL FOR CONFIRMATION UNDER SECTION 133(6) AND WHERE SATISFACTORY REPLIES WERE RECEIVED, THE SAME WERE ACCEPTED. HOWEVER, IN RESPECT OF 23 PARTIES, NO INFORMATION WHATSOEVER WAS PROVIDED BY THE ASSESSEE DURING THE COURSE OF ASSESSMENT PROCEEDINGS INSPITE OF REPEATED OPPORTUNITIES TO THE ASSESSEE. ACCORDINGLY, THE AO MADE AN ADDITION OF RS 1,63,55,000 UNDER SECTION 68 OF THE ACT. DURING THE APPELLATE PROCEEDINGS, BY WAY OF ADDITIONAL EVIDENCE, THE ASSESSEE FILED CONFIRMATION IN RESPECT OF THESE 23 PARTIES WHICH WAS SENT TO AO FOR FURTHER VERIFICATION. THE AO ISSUED NOTICE U/S 133(6) TO THESE 23 ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 12 PARTIES. OUT OF THESE 23 PARTIES, 11 PARTIES EITHER NOT RESPOND OR THE NOTICE RETURNED BACK WITH POSTAL REMARKS INCOMPLETE ADDRESS/LEFT. FURTHER, IN RESPECT OF 4 PARTIES WHO HAVE RESPONDED, THE AO MADE CERTAIN SPECIFICATION OBSERVATION AND BASIS THAT, THE LD CIT(A) CONFIRMED THE PART DISALLOWANCE. IN OTHER WORDS, OUT OF 23 PARTIES TOTALLING TO RS 1,63,55,000, RELIEF WAS PROVIDED IN RESPECT OF 8 PARTIES AMOUNTING TO RS 66,00,000 AND IN RESPECT OF BALANCE 15 PARTIES AMOUNTING TO RS 97,55,000, THE ADDITION MADE BY THE AO WERE CONFIRMED. AGAINST THE ADDITION SO CONFIRMED BY THE LD CIT(A), THE ASSESSEE IS IN APPEAL BEFORE US. 10. THE RELEVANT FINDING OF THE CIT(A) IS REPRODUCED AS UNDER:- IN THE REJOINDER FILED THE ASSESSEE IS AGAIN ENLISTING WHAT THE ASSESSING OFFICER SHOULD HAVE DONE. AS ENLISTED IN PARA 5.3, ASSESSING OFFICER IN THIS CASE DURING THE ASSESSMENT PROCEEDINGS HAS CONDUCTED ENQUIRIES WITH DILIGENCE AND EVEN IN CASES WHERE ONLY PAN WERE GIVEN, LETTERS UNDER SECTION 133(6) OF THE I.T. ACT, 1961 WERE ISSUED AFTER CULLING OUT THE ADDRESSES FROM THE DATABASE AND CREDITORS ACCEPTED WHERE EVER DETAILS WERE RECEIVED FROM THE PARTIES. DURING APPELLATE PROCEEDINGS, THE AUTHORIZED REPRESENTATIVE AGAIN PLEADED LACK OF PROPER OPPORTUNITY DURING ASSESSMENT PROCEEDINGS AND IN VIEW OF ABUNDANT NATURAL JUSTICE, ANOTHER OPPORTUNITY WAS PROVIDED AND CONFIRMATIONS SENT TO THE ASSESSING OFFICER FOR VERIFICATION. AT THIS STAGE IT WAS THE DUTY OF AUTHORIZED REPRESENTATIVE TO PROVE THE CREDITORS BEFORE THE ASSESSING OFFICER, HOWEVER, THE SAME HAS NOT BEEN DONE. IN VIEW OF THE ADEQUATE OPPORTUNITY AFFORDED TO THE ASSESSEE AND HIS FAILURE TO PROVE THE CREDITOR, HENCE RS. 71,80,000/- RELATING TO PARTIES AT SL NO. 1-15 OF ASSESSING OFFICERS REMAND REPORT AND 1 TO 4 OF THE FURTHER PARTIES (RS. 25,75,000/-) WHO RESPONDED BUT COMPLETE DETAILS ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 13 WERE NOT PRODUCED, CANNOT BE ACCEPTED AND THE ADDITION MADE UNDER SECTION 68 OF THE I.T. ACT, IS CONFIRMED. GROUND OF APPEAL IS DISMISSED. 11. DURING THE COURSE OF HEARING, LD. AR SUBMITTED THAT THE DETAILS OF UNSECURED LOANS HAVE BEEN GIVEN IN ANNEXURE-F OF FORM NO 3CD BEING PART OF AUDIT REPORT OF THE ASSESSEE COMPANY. THE ASSESSEE HAS RECEIVED LOANS FROM PRIVATE PARTIES THROUGH FINANCE BROKERS FROM THE OPEN MARKET. WHEN LOANS ARE ACCEPTED THROUGH THE BROKERS THE BORROWERS DOES NOT KNOW ABOUT THE DETAILS OF LENDERS. FOR THIS WORK THE BROKERS CHARGED COMMISSION. SINCE THE ASSESSEE IS NOT DIRECTLY CONNECTED WITH THE LENDERS THEREFORE FULL ADDRESS OF SUCH LENDERS WERE NOT AVAILABLE WITH THE ASSESSEE. CONFIRMATIONS ARE ALSO OBTAINED BY THE BROKERS FROM THE LENDERS. ALL THE LOANS WERE RECEIVED THROUGH ACCOUNT PAYEE CHEQUES FROM THE LENDERS. ALL THE REPAYMENTS WERE MADE THROUGH ACCOUNT PAYEE CHEQUES. ALL THE PAYMENTS OF INTEREST WERE SUBJECT TO TDS AND THE PAYMENTS WERE ALSO MADE THROUGH ACCOUNT PAYEE CHEQUES. PAYMENT OF BROKERAGE WAS ALSO SUBJECT TO TDS AND WAS MADE THROUGH ACCOUNT PAYEE CHEQUES. ALL THE TRANSACTIONS WERE VERIFIABLE FROM THE BANK STATEMENT OF ASSESSEE. ASSESSEE COMPANY HAS DEDUCTED THE TDS IN ALL ELIGIBLE CASES AND HAVE FILED THE TDS RETURNS. PAN OF ALL THE LENDERS WERE WITH THE LD. AO AND TDS WING OF THE DEPARTMENT. IT WAS ALSO REQUESTED THAT THE ASSESSEE HAS PROVED THE IDENTITY, CREDIT WORTHINESS AND GENUINENESS OF THE TRANSACTION. IN THE LAST, IT WAS ALSO SUBMITTED BEFORE THE AO THAT FOR ANY FURTHER VERIFICATION NOTICE U/S 131 OF THE INCOME TAX ACT 1961 MAY BE ISSUED TO THE LENDERS. ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 14 12. IT WAS FURTHER SUBMITTED BY THE LD AR THAT THE ADDITIONS U/S 68 FOR RS. 97,55,000/- (RS. 1,03,30,000/-) CONFIRMED BY THE LD. CIT(A) IS AGAINST THE LAW BECAUSE THE ASSESSEE COMPANY HAS SUBMITTED ALL THE CONFIRMATION OF ALL THE CASH CREDITORS DURING APPEAL PROCEEDINGS. LD. AO DID NOT PROVIDE ANY OPPORTUNITY TO THE ASSESSEE COMPANY DURING REMAND PROCEEDINGS AND SEND THE REMAND REPORT AT HIS OWN. NO SUMMON U/S 131 WAS ISSUED TO THE CREDITORS. THE LD. AO REGARDING THE 1 ST LIST OF RS. 71,80,000/- MENTIONED THAT THESE PERSONS EITHER DID NOT RESPOND OR THE NOTICE RETURNED BACK WITH POSTAL REMARKS INCOMPLETE ADDRESS/LEFT. BUT LD. AO DID NOT MENTION THIS INFORMATION CREDITOR WISE. OTHERWISE THE ASSESSEE COULD HAVE DONE MORE ATTEMPTS TO BRING THE REQUIRED INFORMATION U/S 133(6) BEFORE LD. AO. THE LD. AO DID NOT CONSIDER THE IMPORTANT FACTS THAT IN CASE OF SHRI ENTERPRISES, THE ENTIRE LOAN OF RS. 10 LACS HAS BEEN REPAID IN THE SAME FY AND THERE WAS NO OUTSTANDING AT THE YEAR END. SIMILARLY, IN THE CASE OF SUNITA AGARWAL THE ENTIRE LOAN OF RS. 45 LACS WAS REPAID DURING THE SAME FY HAVING NIL OUTSTANDING BALANCE. NO NOTICE U/S 131 WAS ISSUED. NO ATTEMPT WAS MADE TO SERVE THE LETTERS. NO OPPORTUNITY TO THE ASSESSEE WAS GIVEN. 13. IT WAS FURTHER SUBMITTED THAT ALL THE PAYMENTS IN ALL CASES HAVE BEEN RECEIVED THROUGH BANKING CHANNEL. ALL THE REPAYMENTS HAVE ALSO BEEN THROUGH BANKING CHANNEL, CONFIRMATIONS HAVE BEEN FILED, TDS HAVE BEEN DEDUCTED. IT IS NOT THE CASE OF THE DEPARTMENT THAT THE ASSESSEE HAS PAID CASH TO CREDITORS FOR TAKING LOANS. IDENTITY OF THE CASH CREDITORS, GENUINESS OF THE TRANSACTION AND CREDITWORTHINESS OF THE CASH CREDITORS IS PROVED. ASSESSEE IS NOT REQUIRED TO PROVE THE SOURCE OF SOURCE, THEREFORE ADDITION CONFIRMED BY LD. CIT(A) FOR RS. 71,80,000/- IS BAD IN LAW. ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 15 14. IT WAS FURTHER SUBMITTED THAT IN THE 2 ND LIST OF REMAND REPORT, LD. AO HAS MENTIONED 4 CASES WHERE LD. AO RECEIVED THE DIRECT CONFIRMATIONS BUT DUE TO SOME OTHER REASONS HE DID NOT ACCEPT THE CASH CREDITORS. FOR EXAMPLE IN THE CASE OF AMITA KOOLWAL, SHE CONFIRMED THE TRANSACTION BUT AS PER LD. AO THE TRANSACTION WAS NOT REFLECTING ON 07/04/2011 IN THE BANK ACCOUNT OF SMT. AMITA KOOLWAL. IT WAS SUBMITTED THAT NO FURTHER CLARIFICATION WAS ASKED FROM AMITA KOOLWAL. NO OPPORTUNITY WAS GIVEN TO THE ASSESSEE COMPANY TO EXPLAIN THE DEFICIENCY; NO NOTICE WAS GIVEN U/S 131 TO HER. MOREOVER THE ASSESSEE COMPANY IS NOT REQUIRED TO PROVE THE SOURCE OF SOURCE. IN CASE OF SABOO ENGITECH PVT. LTD., THE CREDITORS HAS CONFIRMED THE TRANSACTION DIRECTLY TO AO BUT THE CREDITOR DID NOT PRODUCE THE COPY OF BANK STATEMENT AND LD. AO REJECTED THE CASH CREDIT. IN THIS CASE ALSO NO FURTHER CLARIFICATION WAS CALLED FOR AND NO OPPORTUNITY WAS GIVEN TO THE ASSESSEE COMPANY TO BRING THE FURTHER EVIDENCES. THE ASSESSEE COMPANY IS NOT REQUIRED TO PROVE THE SOURCE OF SOURCE. IN THE CASE OF KEYUR SHARMA, SHRI KEYUR SHARMA ALSO CONFIRMED THE TRANSACTION DIRECTLY TO AO BUT AS PER LD. AO THE AMOUNT WAS DEPOSITED JUST ONE DAY BEFORE OF GIVING LOAN. IN THIS CASE ALSO NO FURTHER EXPLANATION WAS CALLED FOR AND NO OPPORTUNITY WAS GIVEN TO ASSESSEE. NO SUMMON U/S 131 WAS ISSUED. IT IS ALSO NOT BROUGHT ON RECORD THAT WHETHER THE DEPOSIT AMOUNT WAS IN CASH OR THROUGH CLEARING. ASSESSEE COMPANY IS NOT REQUIRED TO PROVE SOURCE OF SOURCE. IN THE CASE OF LAXMI NARAYAN SABOO, THE CONFIRMATION WAS FILED BY THE DEDUCTOR, IT WAS REJECTED BECAUSE THE CREDITOR PRODUCED ONLY RELEVANT PERIODS BANK ACCOUNT. NO FURTHER EXPLANATION WAS CALLED FOR AND NO ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 16 OPPORTUNITY WAS GIVEN TO ASSESSEE IN REMAND PROCEEDINGS. NO. SUMMON U/S 131 WAS ISSUED. 15. IT WAS SUBMITTED THAT IT IS ALSO SETTLED LAW THAT DURING THE AY, THE ASSESSEE COMPANY WAS NOT REQUIRED TO PROVE THE SOURCE OF SOURCE, WE REPLY ON THE DECISION OF HONBLE RAJASTHAN HIGH COURT IN THE CASE OF ARAVALI TRADING COMPANY V/S ITO 8 DTR 199 (RAJ.). AND IN THE CASE OF LABH CHAND BOHRA V/S ITO 8 DTR 44 (RAJ.). 16. THE LD DR HAS VEHEMENTLY ARGUED THE MATTER AND RELIED UPON THE ORDER OF THE LOWER AUTHORITIES. 17. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. FIRSTLY, THE CONTENTION OF THE LD AR THAT WHEN LOANS ARE ACCEPTED THROUGH THE BROKERS, THE BORROWERS DOES NOT KNOW ABOUT THE DETAILS OF LENDERS AND SINCE, THE ASSESSEE IS NOT DIRECTLY CONNECTED WITH THE LENDERS THEREFORE FULL ADDRESS OF SUCH LENDERS WERE NOT AVAILABLE WITH THE ASSESSEE. IN OUR VIEW, THE SAID CONTENTION CANNOT BE ACCEPTED IN THE CONTEXT OF SECTION 68 OF THE ACT. WHERE AN ASSESSEE RECEIVES OR BORROWS A SUM OF MONEY, THE ONUS IS CLEARLY ON THE ASSESSEE TO PROVIDE THE NECESSARY INFORMATION AND EXPLANATION REGARDING IDENTITY, GENUINESSNESS AND CREDITWORTHINESS OF THE LENDER TO THE SATISFACTION OF THE AO. THE BROKER MAY HAVE FACILITATED THE LOAN TRANSACTION, BUT IT IS STRANGE TO NOTE THAT THE ASSESSEE DOESNT HAVE THE BASIC DETAILS OF THE PERSON IN TERMS OF FULL ADDRESS, ETC WHO HAS LEND THE MONEY TO HIM. HERE, WE HAVE A WELL ESTABLISHED COMPANY WITH A TURNOVER OF OVER RS 56 CRORES WHICH HAS RAISED FUNDS TO THE TUNE OF RS 1.63 CRORES DURING THE YEAR UNDER CONSIDERATION AND IT IS THEREFORE, NOT ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 17 A CASE OF A COMPANY WHICH IS NEWLY SET UP OR OPERATING IN AN UNORGANISED SET UP. THE CONTENTION SO RAISED THEREFORE CANNOT BE ACCEPTED. 18. COMING TO THE SPECIFIC ADDITION OF RS. 97,55,000/- U/S 68 WHICH HAS BEEN SUSTAINED BY THE LD CIT(A), WE FIND THAT THE NECESSARY DETAILS AND CONFIRMATIONS HAVE SINCE BEEN FURNISHED BY THE ASSESSEE DURING THE COURSE OF APPELLATE PROCEEDINGS. HOWEVER, IN THE REMAND PROCEEDINGS, THE AO HAS ISSUED NOTICES U/S 133(6) TO THESE PERSONS FOR NECESSARY VERIFICATION WHICH HAVE REMAINED UNCOMPLIED WITH. THE LD AR HAS SUBMITTED THAT THE ASSESSEE WAS NOT PROVIDED APPROPRIATE OPPORTUNITY DURING THE COURSE OF REMAND PROCEEDINGS AND HAD SUCH AN OPPORTUNITY BEEN PROVIDED TO IT, IT COULD HAVE TRIED TO OBTAIN THE NECESSARY CONFIRMATION/RESPONSES TO NOTICES ISSUED UNDER SECTION 133(6) OF THE ACT. FURTHER, THE ASSESSEE HAS CONTENDED THAT THE AO WAS HAVING THE NECESSARY PAN AND OTHER DETAILS OF THESE LENDERS AND THEY COULD HAVE BEEN SUMMONED U/S 131 OF THE ACT AND WE FIND THAT NO SUMMONS HAVE BEEN ISSUED U/S 131 OR THE AO HAS NOT REACHED OUT TO HIS COUNTERPARTS, UNDER WHOSE JURISDICTION THESE PERSONS ARE ASSESSED TO TAX, TO SEEK THE NECESSARY INFORMATION. REGARDING OTHER 4 CREDITORS NAMELY AMITA KOOLWAL, SABOO ENGITECH, KEYUR SHARMA AND LAXMI NARAYAN SABOO, SIMILAR SUBMISSIONS HAVE BEEN MADE REGARDING NON-GRANT OF OPPORTUNITY TO THE ASSESSEE TO EXPLAIN THE DISCREPANCIES SO OBSERVED BY THE AO DURING THE REMAND PROCEEDINGS. WE ALSO OBSERVE THAT THE ASSESSEE HAS REPAID THE MONEY TO SOME OF THESE LENDERS AND THE SAME MAY BE A REASON FOR NON-COMPLIANCE ON PART OF THESE LENDERS TO RESPOND TO THE NOTICES ISSUED BY AO U/S 133(6) OF THE ACT. IN THE INTEREST OF JUSTICE, ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 18 WE BELIEVE THAT THE ASSESSEE DESERVE ONE MORE OPPORTUNITY AND WE ACCORDINGLY SET-ASIDE THE MATTER TO THE FILE OF THE LD CIT(A) TO EXAMINE THE SAME AFRESH AFTER PROVIDING REASONABLE OPPORTUNITY TO THE ASSESSEE. 19. IN GROUND NO. 4, THE ASSESSEE HAS CHALLENGED THE ACTION OF LD CIT(A) IN DISMISSING THE GROUND OF APPEAL WHERE SHE HAS CONFIRMED ONLY PART ADDITION OF RS 97,55,000 AND HAS ALLOWED THE RELIEF IN RESPECT OF REMAINING ADDITION SO MADE BY THE AO. WE HAVE PURUSED THE ORDER OF THE LD CIT(A) AND FOUND THE SAID CONTENTION TO BE CORRECT. THE LD CIT(A) IS DIRECTED TO MAKE THE NECESSARY CHANGES/MODIFICATION IN THE ORDER PASSED BY HER. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DISPOSED OFF WITH ABOVE DIRECTIONS. ORDER PRONOUNCED IN THE OPEN COURT ON 28/02/2018 SD/- SD/- FOT; IKWY 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:- 28/02/2018 * GANESH KR. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- ACIT, CIRCLE-06, JAIPUR 3. VK;DJ VK;QDR@ CIT 4. VK;DJ VK;QDR@ CIT(A) ITA NO. 1129/JP/2016 M/S SUPERSONIC TURNERS PVT. LTD., JAIPUR VS. ACIT, JAIPUR 19 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR. 6. XKMZ QKBZY@ GUARD FILE { ITA NO. 1129/JP/2016} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR