DCIT, Jaipur V. M/S OM METALS INFRA PROJECTS LTD., Jaipur

ITA 1133/JPR/2016

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 1924 (ITAT-JAIPUR)
• Duration Of Justice: 10 month(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-11-2017
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 30-05-2017
• Assessment Year: 2013-2014
• Appeal Filed On: 26-12-2016
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: VRINDERA MEHTA
• Assessee Lawyers: B B MAHESHWARI
• Keywords: Earning of tax free income
• Section: 14A

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S, JAIPUR JH FOT; IKY JKO] U;KF;D LNL; ,OA JH HKKXPAN] YS[KK L NL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM & SHRI BHAGCHAND, A M VK;DJ VIHY LA- @ ITA NO. 1133/JP/2016 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2013-14 THE DCIT, CIRCILE-2, JAIPUR. CUKE VS. M/S OM METAL INFRAPROJECT LTD., OM TOWER, M.I. ROAD, CHURCH ROAD, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AAACO8245J VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDEN T FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI B.B. MAHESHWARI (C.A.) JKTLO DH VKSJ LS @ REVENUE BY : SHRI VRINDERA MEHTA (CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 14/11/2017 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT: 16/11/2017 VKNS'K@ ORDER PER: VIJAY PAL RAO, J.M. THIS APPEAL BY THE REVENUE IS DIRECTED AGAINST THE ORDER OF DATED 18.10.2016 OF CIT (A)-I, JAIPUR FOR A.Y. 2013-14. T HE REVENUE HAS RAISED THE FOLLOWING GROUNDS ARE AS UNDER:- 1. WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES O F THE CASE AND IN LAW THE LD. CIT(A) HAS ERRED IN DELETING THE ADDITION OF RS. 15,03,442/- ON EMPLOYEES CONTRIBUTION TO PF WHICH WAS DEPOSITED BEYOND THE PRESCRIBED TIME LIMIT PROVIDED IN THE RESPECTIVE ACTS. 2. WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. CIT(A) HAS ERRED IN DELETING THE ENT IRE ADDITION OF ITA NO.1133/JP/2016 DCIT VS. M/S OM METAL INFRAPROJECT LTD, JAIPUR. 2 RS. 2,80,75,585/- MADE BY THE AO UNDER SECTION 14A OF THE I.T. ACT, 1961 R.W. CLAUSES (II) & (III) OF RULE 8D WHIC H WAS IN CONSONANCE WITH CBDT CIRCULAR 5/2014 DATED 11.02.20 14. 3. WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES O F THE CASE AND IN LAW THE LD. CIT(A) HAS ERRED BY RELYING UPON THE DECISION OF HONBLE RAJASTHAN HIGH COURT IN THE CASES OF CIT VS . JVVNL {2014} 99 DTR 131 (RAJ.) AND CIT V/S SBBJ ON THE VE RY SAME ISSUE WHEREAS, THE DEPARTMENT HAS FILED SLP AGAINST THESE ORDERS. THE APPELLANT CRAVES THE INDULGENCE TO MODIFY, ALTE R, AND ADD ANY OTHER GROUND OF APPEAL GIVEN ABOVE. 2. GROUND NO. 1 IS REGARDING DISALLOWANCE MADE BY THE AO IN RESPECT OF THE EMPLOYEES CONTRIBUTION TO PF WHICH WAS DELETED BY THE LD. CIT(A). 3. WE HAVE HEARD THE LD. DR AS WELL AS LD. AR AND C ONSIDERED THE RELEVANT MATERIAL ON RECORD. THE ASSESSING OFFICER DISALLOWED A SUM OF RS. 15,03,442/- ON ACCOUNT OF THE CONTRIBUTION PF AND ESI ON THE GROUND THAT THE ASSESSEE HAS NOT DEPOSITED THE EMPL OYEES CONTRIBUTION WITHIN STIPULATED TIME PRESCRIBED IN RESPECTIVE AC TS. THE LD. CIT(A) NOTED THAT THE AMOUNT HAS BEEN DEPOSITED BY THE ASS ESSEE BEFORE THE DUE DATE OF FILING THE RETURN OF INCOME AND THEREFO RE THE MATTER IS COVERED BY THE DECISION OF HONBLE JURISDICTION HIG H COURT IN CASE OF CIT VS. SBBJ 236 ITR 17 AS WELL AS IN ASSESSEES OWN C ASE FOR THE A.Y. ITA NO.1133/JP/2016 DCIT VS. M/S OM METAL INFRAPROJECT LTD, JAIPUR. 3 2011-12 HAS DECIDED THIS ISSUE IN FAVOUR OF THE ASS ESSEE VIDE ORDER DATED 22 ND AUGUST, 2017 IN ITA NO. 202/2017 IN PARA 4.2 IS AS UNDER:- 4.2 THE ISSUE NO. 2, THE SAME IS NOW COVERED BY TH E DECISION OF THIS COURT IN CIT VS. STATE BANK OF BIKANER & JAIPU R 92014) 363 ITR ITR 70 AGAINST WHICH SLP IS PREFERRED THEREFOR E, IN VIEW OF THE EARLIER DECISION TAKEN BY THIS COURT, THE ISSUE IS ANSWERED IN FAVOUR OF THE ASSESSEE SUBJECT TO SLP PENDING BEFOR E THE SUPREME COURT. HENCE, WE FIND THAT THIS ISSUE IS COVERED BY THE DE CISION OF HONBLE JURISDICTION HIGH COURT IN CASE OF CIT VS. SBBJ (SU PRA) AS WELL AS THE DECISION IN ASSESSEES OWN CASE (SUPRA). ACCORDINGL Y WE DO NOT FIND ANY ERROR OR ILLEGALITY IN THE IMPUGNED ORDERS OF THE L D. CIT(A) QUA THIS ISSUE. 4. GROUND NO. 2 IS REGARDING DISALLOWANCE MADE BY T HE AO U/S 14A R.W. RULE 8D WHICH WAS DELETED BY THE LD. CIT(A). 5. WE HAVE HEARD THE LD. DR AS WELL AS LD. AR AND C ONSIDERED THE RELEVANT MATERIAL ON RECORD. THE ASSESSING OFFICER MADE THE DISALLOWANCE ON ACCOUNT OF INTEREST EXPENDITURE U/S 14A R.W. RULE 8D. THE ASSESSEE CHALLENGED THE ACTION OF THE AO BEFORE THE LD. CIT(A) AND CONTENDED THAT THE ASSESSEES OWN FUND ARE SUFFICIE NT TO MAKE THIS INVESTMENTS RESULTING EXEMPT INCOME. THE LD. CIT(A) DELETED THE ITA NO.1133/JP/2016 DCIT VS. M/S OM METAL INFRAPROJECT LTD, JAIPUR. 4 ADDITION MADE BY THE AO BY FOLLOWING THE DECISIONS OF THIS TRIBUNAL IN ASSESSEES OWN CASE FOR THE ASSESSMENT YEARS 2009-1 0 TO 2012-13 DATED 28.10.2014, 22.12.2014 & 04.01.2016. THE LD. CIT(A) ALSO DELETED THE ADDITION ON ACCOUNT OF INDIRECT ADMINIS TRATIVE EXPENSES BEING 0.5% OF THE AVERAGE INVESTMENT. WE FIND THAT THESE ISSUES WERE CONSIDERED BY THIS TRIBUNAL IN ASSESSEES OWN CASE AND THEREAFTER THE HONBLE JURISDICTION HIGH COURT IN ASSESSEES OWN C ASE DECIDED THIS ISSUE IN ITA NO. 202/2017 VIDE ORDER DATED 22 ND AUGUST, 2017 IN PARA 4.3 IS AS UNDER:- 4.3 THE ISSUE NO. 3 IS REGARDING 14A. NOW THE ISSU E IS GOVERNED BY THE DECISION OF SUPREME COURT THE CASE OF GODREJ & BOYCE MANUFACTUR ING COMPANY LIMITED VS. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI & ANR. RE PORTED IN 394 ITR 449 WHEREIN IT HAS BEEN HELD AS UNDER:- 36. SECTION 14A AS ORIGINALLY ENACTED BY THE FINAN CE ACT OF 2001 WITH EFFECT FROM 1.4.1962 IS IN THE SAME FORM AND LANGUAGE AS CURREN TLY APPEARING IN SUB-SECTION (1) OF SECTION 14A OF THE ACT. SECTIONS 14A (2) AND (3) OF THE ACT WERE INTRODUCED BY THE FINANCE ACT OF 2006 WITH EFFECT FROM 1.4.2007. THE FINDING OF THE BOMBAY HIGH COURT IN THE IMPUGNED ORDER THAT SUB-SECTIONS (2) AND (3) OF SECTION 14A IS RETROSPECTIVE HAS BEEN CHALLENGED BY THE REVENUE IN ANOTHER APPEA L WHICH IS PRESENTLY PENDING BEFORE THIS COURT. THE SAID QUESTION, THEREFORE, NE ED NOT AND CANNOT BE GONE INTO. NEVERTHELESS, IRRESPECTIVE OF THE AFORESAID QUESTIO N, WHAT CANNOT BE DENIED IS THAT THE REQUIREMENT FOR ATTRACTING THE PROVISIONS OF SE CTION 14A(1) OF THE ACT IS PROOF OF THE FACT THAT THE EXPENDITURE SOUGHT TO BE DISALLOW ED/DEDUCTED HAD ACTUALLY BEEN INCURRED IN EARNING THE DIVIDEND INCOME. INSOFAR AS THE APPELLANT-ASSESSEE IS CONCERNED, THE ISSUES STAND CONCLUDED IN ITS FAVOUR IN RESPECT OF THE ASSESSMENT YEARS 1998-1999, 1999-2000 AND 2001-2002. EARLIER T O THE INTRODUCTION OF SUB- SECTIONS (2) AND (3) OF SECTION 14A OF THE ACT, SUC H A DETERMINATION WAS REQUIRED TO BE MADE BY THE ASSESSING OFFICER IN HIS BEST JUDGME NT. IN ALL THE AFORESAID ASSESSMENT YEARS REFERRED TO ABOVE IT WAS HELD THAT THE REVENUE HAD FAILED TO ESTABLISH ANY NEXUS BETWEEN THE EXPENDITURE DISALLO WED AND THE EARNING OF THE ITA NO.1133/JP/2016 DCIT VS. M/S OM METAL INFRAPROJECT LTD, JAIPUR. 5 DIVIDEND INCOME IN QUESTION. IN THE APPEALS ARISING OUT OF THE ASSESSMENTS MADE FOR SOME OF THE ASSESSMENT YEAR THE AFORESAID QUESTION WAS SPECIFICALLY LOOKED INTO FROM THE STANDPOINT OF THE REQUIREMENTS OF THE PROVISION S OF SUB-SECTION (2) AND (3) OF SECTION 14A OF THE ACT WHICH HAD BY THEN BEEN BROUG HT INTO FORCE. IT IS ON SUCH CONSDIERQATION THAT FINDINGS HAVE BEEN RECORDED THA T THE EXPENDITURE IN QUESTION BORE NO RELATION TO THE EARNING OF THE DIVIDEND INC OME AND HENCE THE ASSESSEE WAS ENTITLED TO THE BENEFIT OF FULL EXEMPTION CLAIMED O N ACCOUNT OF DIVIDEND INCOME. 37. WE DO NOT SEE HOW IN THE AFORESAID FACT SITUATI ON A DIFFERENT VIEW COULD HAVE BEEN TAKEN FOR THE ASSESSMENT YEAR 2002-2003. SUB-S ECTIONS (2) AND (3) OF SECTION 14A OF THE ACT READ WITH THE RULE 8D OF THE RULES M ERELY PRESCRIBE A FORMULA FOR DETERMINATION OF EXPENDITURE INCURRED IN RELATION T O INCOME WHICH DOES NOT FORM PART OF THE TOTAL INCOME UNDER THE ACT IN A SITUATION WH ERE THE ASSESSING. WHETHER SATISFIED WITH THE CLAIM OF THE ASSESSEE. WHETHER S UCH DETERMINATION IS TO BE MADE ON APPLICATION OF THE FORMULA PRESCRIBED UNDER RULE 8D OR IN THE BEST JUDGMENT OF THE ASSESSING OFFICER, WHAT THE LAW POSTULATES IS THE R EQUIREMENT OF A SATISFACTION IN THE ASSESSING OFFICER THAT HAVING REGARD TO THE ACCOUNT S OF THE ASSESSEE, AS PLACED BEFORE HIM, IT IS NOT POSSIBLE TO GENERATE THE REQU ISITE SATISFACTION WITH REGARD TO THE CORRECTNESS OF THE CLAIM OF THE ASSESSEE. IT IS ONL Y THEREAFTER THAT THE PROVISIONS OF SECTION 14A(2) AND (3) READ WITH RULE 8D OF THE RUL ES OR A BEST JUDGMENT DETERMINATION, AS EARLIER PREVAILING, WOULD BECOME APPLICABLE. 38. IN THE PRESENT CASE, WE DO NOT FIND ANY MENTION OF THE REASONS WHICH HAD PREVAILED UPON THE ASSESSING OFFICER, WHILE DEALING WITH THE ASSESSMENT YEAR 2002- 03, TO HOLD THAT THE CLAIMS OF THE ASSESSEE THAT NO EXPENDITURE WAS INCURRED TO EARN THE DIVIDEND INCOME CANNOT BE ACCEPTED AND WHY THE ORDERS OF THE TRIBUNAL FOR THE EARLIER ASSESSMENT YEARS WERE NOT ACCEPTABLE TO THE ASSESSING OFFICER, PARTICULARLY, IN THE ABSENCE OF ANY FACT OR CHANGE OF CIRCUMSTANCES. NEITHER ANY BASIS HAS BEEN DISCLOSED ESTABLISHING A REASONABLE NEXUS BETWEEN T HE EXPENDITURE DISALLOWED AND THE DIVIDEND INCOME RECEIVED. THAT ANY PART OF THE BORROWING OF THE ASSESSEE HAD BEEN DIVERTED TO EARN TAX FREE INCOME DESPITE THE A VAILABILITY SURPLUS OR INTEREST FREE FUNDS AVAILABLE (RS. 270.51 CRORES AS ON 1.4.2001 A ND RS. 280.64 CRORES AS ON 31.3.2002) REMAINS UNPROVED BY ANY MATERIAL WHATSOE VER. WHILE IT IS TRUE THAT THE PRINCIPLE OF RES JUDICATA WOULD NOT APPLY TO ASSESS MENT PROCEEDINGS UNDER THE ACT, THE NEED FOR CONSISTENCY AND CERTAINTY AND EXISTENC E OF STRONG AND COMPELLING REASONS FOR A DEPARTURE FROM A SETTLED POSITION HAS TO BE SPELT OUT WHICH CONSPICUOUSLY IS ABSENT IN THE PRESENT CASE. IN THI S REGARD WE MAY REMIND OURSELVES OF WHAT HAS BEEN OBSERVED BY THIS COURT IN RADHASOA MI SATSANG V. COMMISSIONER OF INCOME TAX (1992) 193 ITR (SC) 321 [AT PAGE 329]. WE ARE AWARE OF THE FACT THAT STRICTLY SPEAKING RES JUDICATA DOES NOT APPLY TO INCOME TAX PROCEEDINGS. AGAIN, EACH ASSESSMENT YEAR BEING A UNIT, WHAT IS DECIDED IN ONE ITA NO.1133/JP/2016 DCIT VS. M/S OM METAL INFRAPROJECT LTD, JAIPUR. 6 YEAR MAY NOT APPLY IN THE FOLLOWING YEAR BUT WHERE A FUNDAMENTAL ASPECT PERMEATING THROUGH THE DIFFERENT ASSESSMENT YEARS H AS BEEN FOUND AS A FACT ONE WAY OR THE OTHER AND PARTIES HAVE ALLOWED THAT POSITION TO BE SUSTAINED BY NOT CHALLENGING THE ORDER, IT WOULD NOT BE AT ALL APPRO PRIATE TO ALLOW THE POSITION TO BE CHANGED IN A SUBSEQUENT YEARS. IT IS PERTINENT TO NOTE THAT EVEN THE HONBLE SUPRE ME COURT IN CASE OF GODREG AND BOYEE MANAGING COMPANY LIMITED VS. DCIT 394 ITR 449 WHICH HAS BEEN REPRODUCED BY THE HONBLE JURISDICTI ON HIGH COURT IN ASSESSEE OWN CASE HAS OBSERVED THAT THE RES JUDICAT A DOES NOT APPLY TO INCOME TAX PROCEEDINGS HOWEVER, WHERE A FUNDAMEN TAL ASPECT PERMEATING THROUGH THE DIFFERENT ASSESSMENT YEARS THEN CONSISTENCY OF THE POSITION TAKEN BY THE PARTIES TO BE MAINTAINED. THE ISSUE OF INCURRING ANY EXPENDITURE IN RESPECT OF THE INCOME NOT FORMING PART OF THE TOTAL INCOME IS A FACTUAL ASPECT HAS TO BE EXA MINED INDEPENDENTLY IN EACH ASSESSMENT PARTICULARLY WHEN THERE IS VARIA TION IN THE NATURE OF EXPENDITURE AS WELL AS THE CHANGE IN THE INVESTMENT MADE BY THE ASSESSEE. WE FIND THAT NEITHER THE ASSESSING OFFICE R NOR THE LD. CIT(A) HAS EXAMINED THE RELEVANT FACTS FOR ADJUDICATING TH IS ISSUE OF DISALLOWANCE OF U/S 14A R.W.R 8D. NEITHER THE NATUR E OF EXPENDITURE NOR THE FRESH INVESTMENT DURING THE YEAR HAS BEEN SPECI FICALLY EXAMINED AND CONSIDERED BY THE AUTHORITIES BELOW. HOWEVER, T HE ASSESSEE HAS MADE A FRESH INVESTMENT DURING THE YEAR AS IT IS AP PARENT FROM THE ITA NO.1133/JP/2016 DCIT VS. M/S OM METAL INFRAPROJECT LTD, JAIPUR. 7 OPENING BALANCE AS ON 01.04.2012 AND CLOSING BALANC E ON 31.03.2013. THEN SOURCES OF ADDITIONAL FUND REQUIRED FOR INVEST MENT DURING THE YEAR HAS TO BE EXAMINED BY CONSIDERING THE ASSESSEES OW N INTEREST FREE FUND AS WELL AS THE BORROWINGS BY THE ASSESSEE WHIC H COULD BE USED FOR INVESTMENT. FURTHER, THERE IS A MOVEMENT IN THE INV ESTMENT PORTFOLIO OF THE ASSESSEE DURING THE YEAR UNDER CONSIDERATION TH EN IT IS NECESSARY THAT THE ASSESSEE TOOK THE DECISION OF SELLING AS W ELL AS FRESH INVESTMENT. THE ASSESSEE IS A COMPANY AND THEREFORE THE DECISION OF MAKING THE INVESTMENT OF HUGE AMOUNT IS TAKEN AT TH E HIGHEST LEVEL OF THE MANAGEMENT AND THUS IT CANNOT BE ACCEPTED THAT THERE IS NO EXPENDITURE INCURRED BY THE ASSESSEE FOR EARNING TH E EXEMPT INCOME FROM THE INVESTMENT MADE DURING THE YEAR. ALL THESE RELEVANT ASPECTS ARE REQUIRED TO BE VERIFIED AND EXAMINED FOR THE PURPOSE OF ASCERTAINING THE FACT WHETHER THE ASSESSEE HAS INC URRED THE EXPENDITURE FOR EARNING THE INCOME AS WELL AS QUAN TUM OF EXPENDITURE WHICH CAN BE ATTRIBUTABLE FOR EARNING THE EXEMPT I NCOME CLAIMED BY THE ASSESSEE AGAINST THE TAXABLE INCOME. THUS THE D ECISIONS OF THE EARLIER YEARS IN ASSESSEES OWN CASE CAN BE APPLIED ONLY ON THE PRINCIPAL THAT WHEN THE ASSESSEES OWN FUND IS SUFFICIENT THE N NO DISALLOWANCE CAN BE MADE ON ACCOUNT OF INTEREST EXPENDITURE U/S 14A. SIMILARLY IF THE ITA NO.1133/JP/2016 DCIT VS. M/S OM METAL INFRAPROJECT LTD, JAIPUR. 8 ASSESSEE HAS NOT INCURRED ANY EXPENDITURE ON ACCO UNT OF ADMINISTRATIVE EXPENDITURE WHICH CAN BE ALLOCATED TO THE EXEMPT INCOME THEN IN THE ABSENCE OF FINDING OF THE AO TO IDENTIFY A PARTICULAR EXPENDITURE WHICH COULD BE ALLOCATED FOR EARNING T HE EXEMPT INCOME NO DISALLOWANCE IS CALLED FOR. HOWEVER, THIS PRINCI PAL CAN BE APPLIED ONLY WHEN THE RELEVANT FACTS ARE BROUGHT ON RECORD AND T O BE CONSIDERED FOR ASCERTAINING THE FACTS OF INCURRING THE EXPENDITURE IN RESPECT OF EARNING THE EXEMPT INCOME. NEITHER THE REVENUE NOR THE ASSE SSEE HAS FILED ANY MATERIAL ON RECORD BEFORE US TO GIVE A CONCLUSIVE F INDING ON THE AVAILABILITY OF THE ASSESSEES OWN FUND TO MEET THE REQUIREMENTS OF THE FRESH INVESTMENT MADE BY THE ASSESSEE DURING THE YE AR AS WELL AS THE EXPENDITURE CLAIMED BY THE ASSESSEE WHICH CAN BE AT TRIBUTABLE TO EARNING THE EXEMPT INCOME. SINCE, THERE IS FRESH IN VESTMENT DURING THE YEAR TO THE TUNE OF MORE THAN RS. 14 CRORES, THEREF ORE, THE DECISION FOR THE EARLIER YEARS CANNOT BE APPLIED WITHOUT CONSIDE RING THE RELEVANT FACTS. HENCE, IN THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN THE INTEREST OF JUSTICE WE SET ASIDE THIS ISSUE TO THE RECORD OF THE ASSESSING OFFICER FOR FRESH ADJUDICATION IN LIGHT OF THE ABOV E OBSERVATION. NEEDLESS TO SAY THE ASSESSEE BE GIVEN AN OPPORTUNITY OF HEAR ING BEFORE PASSING THE FRESH ORDER. ITA NO.1133/JP/2016 DCIT VS. M/S OM METAL INFRAPROJECT LTD, JAIPUR. 9 IN THE RESULT, THE APPEAL OF THE REVENUE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 16/11/2017 SD/- SD/- HKKXPAN FOT; IKY JKO (BHAGCHAND) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 16/11/2017. * SANTOSH. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- THE DCIT, CIRCLE-2, JAIPUR. 2. IZR;FKHZ@ THE RESPONDENT- M/S OM METAL INFRAPROJECT LTD., OM TOWER, M.I. ROAD, CHURCH ROAD, 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. 1133/JP/2016} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR