GEETA STAR HOTELS & RESORTS P LTD., Jaipur V. DCIT, CPC-TDS, GHAZIABAD

ITA 14/JPR/2017

• Counselvise Citation: [2017] 128 COUNSELVISE.COM (IT) 2181 (ITAT-JAIPUR)
• Duration Of Justice: 3 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 17-04-2017
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: SMC
• Assessment Year: misc
• Appeal Filed On: 04-01-2017
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: POONAM RAI DCIT DHK
• Assessee Lawyers: R P JAAT ITP
• Keywords: Condonation of delay

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 HKKXPAN] YS[KK LNL; ] DS LE{K BEFORE: SHRI BHAGCHAND, ACCOUNTANT MEMBER VK;DJ VIHY LA-@ ITA NO. 14/JP/2017 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : QUARTER IV- A.Y. 2013-14 GEETA STAR HOTELS & RESORTS P. LTD., GEETA ENCLAVE, VINOBHA MARG, C-SCHEME, JAIPUR, RAJASTHAN. CUKE VS. DEPUTY COMMISSIONER OF INCOME TAX, CPC, TDS, GHAZIABAD, U.P. TAN NO.: JPRS 06903 B VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI R.P. JAAT (ITP) JKTLO DH VKSJ LS@ REVENUE BY : SMT. POONAM RAI (DCIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 13/04/2017 MN?KKS'K.KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 17/04/2017 VKNS'K@ ORDER PER: BHAGCHAND, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE EMANATES FR OM THE ORDER OF THE LD. CIT(A)-III, JAIPUR DATED 24/05/2016 FOR QUAR TER IV OF THE A.Y. 2013-14, WHEREIN THE ASSESSEE HAS RAISED FOLLOWING G ROUNDS OF APPEAL: 1. THE CIT(A)-3, JAIPUR ERRED IN FACT AND IN LAW IN CONFIRMING THE LEVY OF FEES FOR DELAY IN FILING THE TDS RETURN U/S 234E OF THE INCOME TAX ACT, 1961 (THE ACT) WITHOUT APPRECIATING THE FACTS AND CIRCUMSTANCES OF THE CASE. THE CIT(A) OUGHT TO HAVE DIRECTED TO WAIVE THE SAID FEES. ITA 14/JP/2017_ GEETA STAR HOTELS & RESORTS P LTD. VS. DCIT 2 2. THE LD. CIT(A) ERRED IN FACT AND IN LAW IN ADJUDICATING AN ISSUE OF VALIDITY OF THE IMPUGNED LEVY OF FEES U/S 234E IN THE ORDER PASSED U/S 200A OF THE ACT. THE CIT(A) OUGHT TO HAVE APPRECIATED THAT THE POWER TO COLLECT THE FEES BY THE PRESCRIBED AUTHORITY VESTED IN SUCH AUTHORITY ONLY BY WAY OF SUBSTITUTION OF CLAUSE (C) TO SECTION 200A(1) OF TH E ACT BY THE FINANCE ACT, 2015 W.E.F. 01/6/2015. SINCE, PRIOR TO SAID SUBSTATION THE ASSESSING OFFIC ER HAD NO AUTHORITY TO CHARGE THE FEES U/S 234E OF THE ACT WHILE ISSUING INTIMATION U/S 200A OF THE ACT AND HENCEFORTH LEVY OF FEES U/S 234E IN THE CASE IS WITHOUT AUTHORITY. 2. BRIEF FACTS OF THE CASE ARE THAT THERE IS A DELA Y OF 143 DAYS IN FILING THE APPEAL, FOR WHICH, THE ASSESSEE HAS FILED AN AP PLICATION FOR CONDONATION OF DELAY IN FILING THE APPEAL. I HAVE H EARD BOTH THE SIDES ON THE ISSUE OF CONDONATION OF DELAY AND AFTER HEARING THE PARTIES AND LOOKING TO THE FACT THAT THE DELAY IN FILING THE AP PEAL IS NOT INTENTIONAL AND BEYOND THE CONTROL OF THE ASSESSEE, THEREFORE THE D ELAY OF 143 DAYS IN FILING THE APPEAL IS HEREBY CONDONED BY FOLLOWING TH E DECISION OF THE HON'BLE SUPREME COURT IN THE CASE OF COLLECTOR, LAN D ACQUISITION VS. MST. KATIJI & ORS. (1987) 167 ITR 471 (SC) WHEREIN THE HO N'BLE SUPREME COURT HAS HELD AS UNDER:- MAKING A JUSTICE-ORIENTED APPROACH FROM THIS PERSPE CTIVE, THERE WAS SUFFICIENT CAUSE FOR CONDONING THE DELAY IN THE INS TITUTION OF THE APPEAL. THE FACT THAT IT WAS THE 'STATE' WHICH WAS SEEKING CONDONATION AND NOT A PRIVATE PARTY WAS ALTOGETHER IRRELEVANT. THE DOCTRINE OF EQUALITY BEFORE LAW DEMANDS THAT ALL LI TIGANTS, INCLUDING THE STATE AS A LITIGANT, ARE ACCORDED THE SAME TREA TMENT AND THE LAW IS ADMINISTERED IN AN EVEN-HANDED MANNER. THERE IS NO WARRANT FOR ITA 14/JP/2017_ GEETA STAR HOTELS & RESORTS P LTD. VS. DCIT 3 ACCORDING A STEP-MOTHERLY TREATMENT WHEN THE 'STATE ' IS THE APPLICANT PRAYING FOR CONDONATION OF DELAY. IN FACT , EXPERIENCE SHOWS THAT ON ACCOUNT OF AN IMPERSONAL MACHINERY (NO ONE IN CHARGE OF THE MATTER IS DIRECTLY HIT OR HURT BY THE JUDGMENT SOUG HT TO BE SUBJECTED TO APPEAL) AND THE INHERITED BUREAUCRATIC METHODOLO GY IMBUED WITH THE NOTE-MAKING, FILE-PUSHING, AND PASSING-ON-THE-B UCK ETHOS, DELAY ON ITS PART IS LESS DIFFICULT TO UNDERSTAND THOUGH MORE DIFFICULT TO APPROVE. IN ANY EVENT, THE STATE WHICH REPRESENTS T HE COLLECTIVE CAUSE OF THE COMMUNITY, DOES NOT DESERVE A LITIGANT NON GRATA STATUS. THE COURTS, THEREFORE, HAVE TO BE INFORMED OF THE SPIRIT AND PHILOSOPHY OF THE PROVISION IN THE COURSE OF THE IN TERPRETATION OF THE EXPRESSION 'SUFFICIENT CAUSE'. SO ALSO THE SAME APP ROACH HAS TO BE EVIDENCED IN ITS APPLICATION TO MATTERS AT HAND WIT H THE END IN VIEW TO DO EVEN-HANDED JUSTICE ON MERITS IN PREFERENCE T O THE APPROACH WHICH SCUTTLES A DECISION ON MERITS. TURNING TO THE FACTS OF THE MATTER GIVING RISE TO THE PRESENT APPEAL, WE ARE SA TISFIED THAT SUFFICIENT CAUSE EXISTS FOR THE DELAY. THE ORDER OF THE HIGH COURT DISMISSING THE APPEAL BEFORE IT AS TIME-BARRED, IS THEREFORE, SET ASIDE. DELAY IS CONDONED. 3. THIS APPEAL WAS POSTED FOR HEARING ON 28/2/2017 AN D ON THE REQUEST OF THE LD. AR OF THE ASSESSEE, IT WAS ADJOUR NED FOR 08/3/2016. GROUNDS FOR ADJOURNMENT WAS AS UNDER:- HONBLE SIRS, MOST HUMBLY SUBMITTED THAT CERTAIN INFORMATION/CLA RIFICATION IS PENDING TO BE RECEIVED FROM THE CLIENT. THEREFORE , THE CASE COULD NOT BE PREPARED. IN VIEW OF THE ABOVE, A VERY HUMBLE REQUEST IS MAD E FOR AN ADJOURNMENT. INCONVENIENCE CAUSED TO THE HONBLE BENCH IS DEEPL Y REGRETTED. SUBMITTED MOST RESPECTFULLY. ON 08/3/2017, AGAIN THERE WAS AN APPLICATION FOR ADJ OURNMENT WAS FILED BY THE LD. AR ON THE EXACTLY SAME GROUNDS, WHICH ARE AS UNDER:- HONBLE SIRS, MOST HUMBLY SUBMITTED THAT CERTAIN INFORMATION/CLA RIFICATION IS PENDING TO BE RECEIVED FROM THE CLIENT. THEREFORE , THE CASE COULD NOT BE PREPARED. ITA 14/JP/2017_ GEETA STAR HOTELS & RESORTS P LTD. VS. DCIT 4 IN VIEW OF THE ABOVE, A VERY HUMBLE REQUEST IS MAD E FOR AN ADJOURNMENT. INCONVENIENCE CAUSED TO THE HONBLE BENCH IS DEEPL Y REGRETTED. SUBMITTED MOST RESPECTFULLY. THEREFORE, THE CASE WAS ADJOURNED FOR 16/3/2017. ON 1 6/3/2017, AGAIN THERE WAS AN ADJOURNMENT APPLICATION WHEREIN THE LD AR PLEADED THAT HE IS NOT WELL AND HAVING PAIN IN THE RIGHT HAND, THE C ASE WAS ADJOURNED FOR 13/4/2017. ON 13/4/2017, GROUNDS FOR ADJOURNMENT SO UGHT WERE EXACTLY THE SAME, WHICH WERE FOR THE ADJOURNMENT SOUGHT ON TH E EARLIER DATE I.E. 28/2/2017 AND 08/3/2017. ON THE LAST HEARING I.E. O N 16/3/2017, SHRI R.P. JAAT, WHO SOUGHT THE ADJOURNMENT WAS ALSO MADE A WARE ABOUT THE FACT THAT THE ISSUE IN GROUNDS OF APPEAL RAISED, IS ALREADY COVERED BY THE DECISION OF HONBLE BOMBAY HIGH COURT ON WHICH THE L D. CIT(A) HAS RELIED UPON WHILE DECIDING THE ISSUE. TODAY AGAIN APPLICATIO N FOR ADJOURNMENT FILED, WHICH IS REJECTED FOR THE REASONS THAT THE IS SUE STAND ALREADY COVERED AGAINST THE ASSESSEE BY THE HON'BLE HIGH CO URT FOR SEEKING ADJOURNMENT FOR NON-GENUINE REASONS. THE ISSUE IS B EING DECIDED. THE ISSUE RAISED IN GROUNDS OF APPEAL IS COVERED BY THE DECISION OF HONBLE BOMBAY HIGH COURT IN THE CASE OF RASHMIKANT KUNDALI A VS. UNION OF INDIA (2015) 229 TAXMAN 596 (BOM) AND THE DECISION OF THE HONBLE JURISDICTIONAL HIGH COURT IN THE CASE OF M/S DUNDLO D SHIKSHAN SANSTHAN & ITA 14/JP/2017_ GEETA STAR HOTELS & RESORTS P LTD. VS. DCIT 5 ORS. ORDER DATED 28/07/2015. THE ISSUE HAS BEEN DEC IDED BY THE LD. CIT(A) BY HOLDING AS UNDER:- 4.3 I HAVE CAREFULLY CONSIDERED THE FACTS OF THE CASE, FINDINGS OF THE AO AND SUBMISSION OF THE APPELLANT. I HAVE GONE THROUGH TH E GROUNDS OF APPEAL AND WRITTEN SUBMISSIONS CAREFULLY. IT IS SEEN THAT THE APPELLANT HAS CONTENDED THAT PRIOR TO 01.06,2015, THERE WAS NO EN ABLING PROVISION IN SEC. 200A OF THE ACT FOR MAKING ADJUSTMENT IN RESPE CT OF THE STATEMENT FILED BY THE ASSESSEE WITH REGARD TO TAX DEDUCTED A T SOURCE BY LEVYING FEE U/S 234E OF THE ACT. THE PARLIAMENT FOR THE FIR ST TIME ENABLED THE AO TO MAKE ADJUSTMENT BY LEVYING FEE U/S 234E OF THE A CT W.E.F. 01.06.2015. IN ORDER TO COMPREHEND THE ARGUMENT OF THE APPELLAN T, IT WOULD BE APPROPRIATE TO REPRODUCE THE PROVISIONS OF SEC. 200 A AS STOOD BEFORE 01.06.2015, THE AMENDMENT MADE IN SEC. 200A BY THE FINANCE ACT, 2015 AND THE PROVISIONS OF SEC. 234E. (A) PROVISIONS OF SEC. 200A, AS THEY STOOD PRIOR TO 01.06.2015: '(I) WHEREAS STATEMENT OF TAX DEDUCTION AT SOURCE OR A C ORRECTION STATEMENT HAS BEEN MADE BY A PERSON DEDUCTING ANY SUM (HEREAFTER REFERRED TO IN THIS SECTION AS DEDUCTOR) UNDER SECTION 200, SUCH STATEM ENT SHALL BE PROCESSED IN THE FOLLOWING MANNER, NAMELY:- (A) THE SUMS DEDUCTIBLE UNDER THIS CHAPTER SHALL BE COMPUTED AFTER MAKING THE FOLLOWING ADJUSTMENTS, NAMELY; - (I) ANY ARITHMETICAL ERROR IN THE STATEMENT; OR (II) AN INCORRECT CLAIM, APPARENT FROM ANY INFORMA TION IN THE STATEMENT; (B) THE INTEREST, IF ANY, SHALL BE COMPUTED ON THE BASIS OF THE SUMS DEDUCTIBLE AS COMPUTED IN THE STATEMENT; (C) THE SUM PAYABLE BY, OR THE AMOUNT OF REFUND DUE TO, THE DEDUCTOR SHALL BE DETERMINED AFTER ADJUSTMENT OF AMOUNT COMPUTED UNDE R CLAUSE (B) AGAINST ANY AMOUNT PAID UNDER SECTION 200 AND SECTION 201, AND ANY AMOUNT PAID OTHERWISE BY WAY OF TAX OR INTEREST; ITA 14/JP/2017_ GEETA STAR HOTELS & RESORTS P LTD. VS. DCIT 6 (D) AN INTIMATION SHALL BE PREPARED OR GENERATED AN D SENT TO THE DEDUCTOR SPECIFYING THE SUM DETERMINED TO BE PAYABLE BY, OR THE AMOUNT OF REFUND DUE TO, HIM UNDER CLAUSE (C); AND (E) THE AMOUNT OF REFUND DUE TO THE DEDUCTOR IN PUR SUANCE OF THE DETERMINATION UNDER CLAUSE (C) SHALL BE GRANTED TO THE DEDUCTOR; PROVIDED THAT NO INTIMATION UNDER THIS SUB-SECTION SHALL BE SENT AFTER THE EXPIRY OF ONE YEAR FROM THE END OF THE FINANCIAL YEAR IN W HICH THE STATEMENT IS FILED. EXPLANATION - FOR THE PURPOSES OF THIS SUB-SECTION , 'AN INCORRECT CLAIM APPARENT FROM ANY INFORMATION IN THE STATEMENT' SHALL MEAN A CLAIM, ON THE BASIS OF AN ENTRY, IN THE STATEMENT- (1) OF AN ITEM, WHICH IS INCONSISTENT WITH ANOTHER ENTRY OF THE SAME OR SOME OTHER ITEM IN SUCH STATEMENT; (II) IN RESPECT OF RATE OF DEDUCTION OF TAX AT SOU RCE, WHERE SUCH RATE IS NOT IN ACCORDANCE WITH THE PROVISIONS OF THIS ACT; (2) FOR THE PURPOSES OF PROCESSING OF STATEMENTS UN DER SUB-SECTION (I), THE BOARD MAY MAKE A SCHEME FOR CENTRALIZED PROCESSING OF STA TEMENTS OF TAX DEDUCTED AT SOURCE TO EXPEDITIOUSLY DETERMINE THE TAX PAYABL E BY, OR THE REFUND DUE TO, THE DEDUCTOR AS REQUIRED UNDER THE SAID SUB-SECTION .' (B) AMENDMENT MADE SEC. 200A BY THE FINANCE ACT, 20 15: 'IN SECTION 200A OF THE INCOME-TAX ACT, IN SUB-SEC TION (I), FOR CLAUSES (C) TO (E), THE FOLLOWING CLAUSES SHALL BE SUBSTITUTED WITH EFF ECT FROM THE 1 ST DAY OF JUNE, 2015, NAMELY:- '(C) THE FEE, IF ANY, SHALL BE COMPUTED IN ACCORDA NCE WITH THE PROVISIONS OF SECTION 234E; (D) THE SUM PAYABLE BY, OR THE AMOUNT OF REFUND DUE TO, THE DEDUCTOR SHALL BE DETERMINED AFTER ADJUSTMENT OF THE AMOUNT COMPUTED UNDER CLAUSE (B) AND CLAUSE(C) AGAINST ANY AMOUNT PAID UNDER SECTION 20 0 OR SECTION 20 J OR SECTION 234E AND ANY AMOUNT PAID OTHERWISE BY WAY OF TAX OR INTEREST OR FEE: (E) AN INTIMATION SHALL BE PREPARED OR GENERATED AN D SENT TO THE DEDUCTOR SPECIFYING THE SUM DETERMINED TO BE PAYABLE BY, OR THE AMOUNT OF REFUND DUE TO, HIM UNDER CLAUSE (D); AND (F) THE AMOUNT OF REFUND, DUE TO THE DEDUCTOR IN PU RSUANCE OF THE DETERMINATION UNDER CLAUSE (D) SHALL BE GRANTED TO THE DEDUCTOR.' (C) PROVISIONS OF SEC. 234E : ITA 14/JP/2017_ GEETA STAR HOTELS & RESORTS P LTD. VS. DCIT 7 '(1) WITHOUT PREJUDICE TO THE PROVISIONS OF THE ACT , WHERE A PERSON FAILS TO DELIVER OR CAUSE TO BE DELIVERED A STATEMENT WITHIN THE TIM E PRESCRIBED IN SUBSECTION (3) OF SECTION 200 OR THE PROVISO TO SUBSECTION (3) OF SECTION 206C, HE SHALL HE LIABLE TO PAY, BY WAY OF FEE, A SUM OF TWO HUNDRED RUPEES FOR EVERY DAY DURING WHICH THE FAILURE CONTINUES. (2) THE AMOUNT OF FEE REFERRED TO IN SUB-SECTION (1 ) SHALL NOT EXCEED THE AMOUNT OF TAX DEDUCTIBLE OR COLLECTIBLE, AS THE CASE MAY BE. (3) THE AMOUNT OF FEE REFERRED TO IN SUB-SECTION (1 ) SHALL BE PAID BEFORE, DELIVERING OR CAUSING TO BE DELIVERED A STATEMENT IN ACCORDANC E, WITH SUBSECTION (3) OF SECTION 200 OR THE PROVISO TO SUB-SECTION (3) OF SE CTION 206C. (4) THE PROVISIONS OF THIS SECTION SHALL APPLY TO A STATEMENT REFERRED TO IN SUBSECTION (3) OF SECTION 200 OR THE PROVISO TO SUB -SECTION (3) OF SECTION 206C WHICH IS TO BE DELIVERED OR CAUSED TO BE DELIVERED FOR TAX DEDUCTED AT SOURCE OR TAX COLLECTED AT SOURCE, AS THE CASE MAY BE, ON OR AFTER THE 1' DAY OF JULY, 2012.' THE APPELLANT RELIED UPON VARIOUS CASE LAWS / ARGUM ENTS WHERE IT HAS BEEN HELD THAT PRIOR TO 01.06.2015, THERE WAS NO ENABLING PROVISIO N IN SEC. 200A OF THE ACT FOR MAKING ADJUSTMENT IN RESPECT OF THE STATEMENT F ILED BY THE ASSESSEE WITH REGARD TO TAX DEDUCTED AT SOURCE BY LEVYING FEE U/S 234E OF THE ACT. ONLY AFTER AMENDMENT MADE IN SEC. 200A BY THE FINANCE ACT, 201 5 W.E.F. 01.06.2015 QUOTED ABOVE, THE ASSESSING OFFICER WAS EMPOWERED T O MAKE ADJUSTMENT U/S 200A BY LEVYING FEE U/S 234E OF THE ACT. HOWEVER HONBLE RAJASTHAN HIGH COURT IN CASE OF M/S DUNDLOD SHIKSHAN SANSTHAN AND OTHERS VIDE ORDER DATED 28.07.2015 HEL D THAT EVEN PRIOR TO THESE AMENDMENTS THE IMPOSITION OF FEES U/S 234E WAS NOT ILLEGAL. WHILE DISCUSSING THIS ISSUE THEY REFERRED TO BOMBAY HIGH COURT DECIS ION WHEREIN IT WAS HELD THAT THE TIMELY PROCESSING OF RETURNS IS THE BEDROCK OF AN EFFICIENT TAX ADMINISTRATION SYSTEM. IF THE INCOME TAX RETURNS, ESPECIALLY HAVING REFUND CLAIMS, ARE NOT PROCESSED IN A TIMELY MANNER, THEN (I) A DELAY OCCURS IN THE GRANTING OF CREDIT OF TDS TO THE PERSON ON WHOSE BEHALF TAX IS DEDUCTED (THE DEDUCTEE) AND CON SEQUENTLY LEADS TO DELAY IN ISSUING REFUNDS TO THE DEDUCTEE, OR RAISING OF INFRUCTUOUS DEMANDS AGAINST THE DEDUCTEE; (II) THE CONFIDENCE OF A GENERAL TAXPAYER ON THE TAX ADMINISTRATION IS ERODED; (III) THE LATE PAYMENT OF REFUND AFFECTS THE GOVERNMENT FINANCIALL Y AS THE GOVERNMENT HAS TO PAY ITA 14/JP/2017_ GEETA STAR HOTELS & RESORTS P LTD. VS. DCIT 8 INTEREST FOR DELAY IN GRANTING THE REFUNDS; AND (IV ) THE DELAY IN RECEIPT OF REFUNDS RESULTS INTO A CASH FLOW CRUNCH, ESPECIALLY FOR BUSINESS ENTITIES LOOKING AT THIS FROM THIS PERSPECTIVE, WE ARE CLEARLY OF THE VIEW THAT S ECTION 234E OF THE ACT IS NOT PUNITIVE IN NATURE BUT A FEE WHICH IS A FIXED CHARGE OF THE VIE W THAT SECTION 234E OF THE ACT IS NOT PUNITIVE IN NATURE BUT A FEE WHICH IS A FIXED CHARG E FOR THE EXTRA SERVICE WHICH THE DEPARTMENT HAS TO PROVIDE DUE TO THE LATE FILING OF THE TDS STATEMENTS. RESPECTFULLY FOLLOWING THE ABOVE DECISION OF RAJAST HAN HIGH COURT I FIND THAT THERE IS NO VALID REASON OR JUSTIFICATION TO INTERF ERE WITH THE COMPENSATORY FEES IMPOSED FOR LATE FILING OF TDS RETURN. ACCORDINGLY THE DEMAND RAISED BY AO FOR LATE FILING FEES U/S 234E IS CONFIRMED. 4. AFTER HEARING BOTH THE SIDES, I FIND NO MERIT IN THE APPEAL OF THE ASSESSEE AND THE SAME IS DISMISSED. 5. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DIS MISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 17/04/2017. SD/- HKKXPAN (BHAGCHAND) YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 17 TH APRIL, 2017 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- GEETA STAR HOTELS & RESORTS P. LTD., JAIPUR. 2. IZR;FKHZ @ THE RESPONDENT- THE DCIT, CPC, TDS, GHAZIABAD, U.P.. 3. VK;DJ VK;QDR @ CIT 4. VK;DJ VK;QDRVIHY @ THE CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ @ DR, ITAT, JAIPUR 6. XKMZ QKBZY @ GUARD FILE (ITA NO. 14/JP/2017) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR