SHANTI EDUCATION SOCIETY, Jaipur V. DCIT, Jaipur

ITA 18/JPR/2014

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 5169 (ITAT-JAIPUR)
• Duration Of Justice: 2 year(s) 5 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-06-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2012-2013
• Appeal Filed On: 06-01-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ROSHANTA MEENA JCIT DHK
• Keywords: Additional evidence; Non-deduction of tax
• Section: 201(1); 54; 10; 154; 139

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 DQY HKKJR] U;KF;D LNL; ,OA JH FOE FLAG ;KNO] YS [KK LNL; DS LE{K BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YAD AV, AM VK;DJ VIHY LA-@ ITA NO.18 /JP/14 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2012-13 SHANTI EDUCATION SOCIETY, ISI-6 RIICO INSTITUTIONAL AREA, GONER ROAD, SITAPURA, JAIPUR CUKE VS. THE DCIT (TDS), JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. AACTS 1602 A VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI RAJEEV SOGANI (C.A.) & SHRI ROHAN SOGANI (CA) JKTLO DH VKSJ LS@ REVENUE BY :ROSHANTA MEENA (JCIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 13.05.2016 ?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 30/06/2016. VKNS'K@ ORDER PER SHRI VIKRAM SINGH YADAV, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER OF LD. CIT(A)-III, JAIPUR DATED 01.10.2013 WHEREIN THE ASSESSEE HAS TA KEN FOLLOWING GROUNDS OF APPEAL: 1. IN THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. CIT(A) HAS ERRED IN CONFIRMING THE ACTION OF THE LD. AO IN TRE ATING THE ASSESSEE AS ASSESSEE IN DEFAULT U/S 201(1) FOR THE ALLEGED FAI LURE TO DEDUCT TAX AT SOURCE ON PAYMENT MADE TO RIICO AND THEREBY CONFIRM ING THE ACTION OF CHARGING INTEREST OF RS. 23,70,599/- U/S 201(1A) OF THE IT ACT, 1961. THE ACTION OF THE LD. CIT (A) IS ILLEGAL, UNJUSTIFIED, ARBITRARY AND AGAINST THE FACTS OF THE CASE. RELIEF MAY PLEASE BE GRANTED BY QUASHING THE DEMAND OF RS. 23,70,599/- ALLEGEDLY RAISED. ITA NO. 18/JP/14 SHANTI EDUCATION SOCIETY, JAIPUR VS. DCIT (TDS), J AIPUR 2 2. IN THE FACTS AND CIRCUMSTANCES OF THE CASE AND I N LAW, THE LD. CIT(A) HAS ERRED IN CONFIRMING THE ACTION OF THE LD. AO IN TRE ATING THE ASSESSEE AS ASSESSEE IN DEFAULT U/S 201(1) FOR THE ALLEGED DEFA ULT IN DEDUCTION OF TAX AT SOURCE AMOUNTING TO RS 86,500 IN RESPECT OF PAYM ENT TO RAJASTHAN TECHNICAL UNIVERSITY, KOTA AND CHARGING INTEREST O F RS 10,555/-U/S 201(1A) OF THE IT ACT, 1961. 2. REGARDING GROUND NO.1, THE BRIEF FACTS OF THE CA SE ARE THAT THE ASSESSEE SOCIETY HAD ACQUIRED INDUSTRIAL PLOTS IS-2027 TO IS -2031 CONSISTING OF TOTAL AREA OF 131028.63 SQ.METERS AT RAMCHANDRAPURA INDUSTRIAL AREA, SITAPURA EXTEN. JAIPUR FROM RIICO FOR A TOTAL CONSIDERATION OF RS.49,34,82,560/-. FOR ACQUIRING THE SAID LAND A LEASE AGREEMENT WITH RIIC O WAS EXECUTED DATED 26/07/2011 FOR A LEASE PERIOD OF 99 YEARS. THE APPE LLANT SOCIETY PAID TOTAL AMOUNT OF RS. 16,60,27,673/- ON ACCOUNT OF LEASE RE NT PAYMENT, DEVELOPMENT CHARGES AND INTEREST ON DEVELOPMENT CHARGES ETC. A S PER LD. AO ON THESE PAYMENT, TDS WAS TO BE DEDUCTED U/S 194-I OF INCOME TAX ACT, 1961. AS NO TDS WAS DEDUCTED , THEREFORE, THE LD. AO RAISED DEMAND OF RS. 1,66,02,767/- U/S 201(1) AND RS. 21,04,969/- U/S 201(1A) OF THE I.T A CT, 1961. SUBSEQUENTLY, THE DEMAND SO RAISED WAS AMENDED BY WAY OF ORDER U/S 1 54 OF INCOME TAX ACT 1961 BY ACCEPTING THE ASSESSEE SOCIETYS CONTENTIO N THAT THE DEDUCTEE HAD PAID THE DUE TAX ON SUCH RECEIPTS AND, THEREFORE TH E DEDUCTOR SHOULD NOT BE TREATED AS ASSESSEE IN DEFAULT IN TERMS OF SECTION 201(1A) OF THE I.T. ACT 1961. THE DEMAND RAISED U/S 201(1A) WAS HOWEVER DETERMINE D AT RS. 23,70,599/-. 2.1 LR AR SUBMITTED BEFORE THE ASSESSING OFFICER TH AT THE LEASE AGREEMENT EXECUTED WITH RIICO FOR A PERIOD OF 99 YEARS WAS TO ACQUIRE THE OWNERSHIP RIGHTS IN THE INDUSTRIAL LAND. THE PAYMENT SO MADE WAS NOT FOR MERELY USE OF THE LAND BUT LARGER INTEREST COMPRISING BUNDLE OF RIGHTS WAS ACQUIRED AND , THEREFORE, IT WAS NOT RENT AND WAS NOT LIABLE FOR TDS U/S 194-I. THE LD. AO DID ITA NO. 18/JP/14 SHANTI EDUCATION SOCIETY, JAIPUR VS. DCIT (TDS), J AIPUR 3 NOT AGREE WITH THE CONTENTIONS OF THE ASSESSEE SOCI ETY. HE MAINLY REFERRED TO THE DIFFERENT REGULATORY CLAUSES OF THE LEASE DEED AND HELD THAT THERE WAS NO SALE OF LAND FROM RIICO TO ASSESSEE SOCIETY. IT WAS ONLY A LEASE. THE LD. AO ALSO REFERRED TO THE DEFINITION OF RENT PROVIDED IN SECT ION 194-I AND HELD THAT THE DEFINITION OF RENT PROVIDED IN SECTION 194-I IS WI DE ENOUGH TO INCLUDE THE LEASE. IN THE RESULT THE LD. AO TREATED THE ASSESSEE SOC IETY AS ASSESSEE IN DEFAULT FOR DEDUCTION OF TAX AT SOURCE ON PAYMENT MADE TO RIICO . THE LD. CIT(A) UPHELD THE ORDER OF THE LD. AO FOR THE FOLLOWING REASONS:- (I) THE CLAUSES OF THE LEASE AGREEMENT DENOTE THAT LAND WAS GIVEN TO THE ASSESSEE ON LEASE AND WAS NOT TRANSFERRED BY SALE. ALTHOUGH THE ASSESSEE ACQUIRED BENEFIT OF ENDURING NATURE FOR 9 9 YEARS AND RIGHTLY CAPITALIZED THE EXPENDITURE, YET THE PAYMENT WAS IN THE NATURE OF RENT LIABLE TO TDS. (II) RIICO ITSELF WAS NOT OWNER OF THE SAID LAND AS THE GOVERNMENT HAD ALLOTTED THE LAND TO RIICO ON LEASEHOLD BASIS FOR A PERIOD OF 99 YEARS IN TERMS OF THE RAJASTHAN INDUSTRIAL AREA ALLOTMENT RU LE 1959 (III) THE LD. CIT(A) FURTHER PLACED RELIANCE ON THE DECISION OF HONBLE ITAT CHENNAI BENCH IN THE CASE OF FOXCONN INDIA DEVELOPE R (P) LTD. VS. INCOME TAX OFFICER, TDS WARD II(3) CHENNAI (2012) 53 SOT 2 13. 2.2 AT THE OUTSET OF THE HEARING, THE LD. AR OF THE ASSESSEE PRAYED THAT SIMILAR ISSUE HAS BEEN DECIDED IN FAVOUR OF THE ASS ESSEE BY THE COORDINATE BENCH VIDE ITS ORDER DATED 16-11-2015 IN THE CASE O F M/S. GUPTA FABTEX (P) LTD. VS. DCIT (TDS), JAIPUR IN ITA NO. 647 & 648/JP/201 3 FOR THE ASSESSMENT YEAR 2011-12 AND 2012-13. 2.3 THE LD. DR RELIED ON THE ORDERS OF THE AUTHORIT IES BELOW. 2.4 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. IT EMERGES FROM THE RECORD THAT ON SIMIL AR ISSUE THE COORDINATE ITA NO. 18/JP/14 SHANTI EDUCATION SOCIETY, JAIPUR VS. DCIT (TDS), J AIPUR 4 BENCH IN THE CASE OF M/S. GUPTA FABTEX (P) LTD. VS. DCIT (TDS) HAS DECIDED THE ISSUE IN FAVOUR OF THE ASSESSEE BY FOLLOWING OBSERV ATIONS. EVEN IF THE AFORESAID DECISION OF ITAT CHENNAI BEN CH IN THE CASE OF FOXCONN INDIA DEVELOPERS PVT. LTD. (SUPRA) IS TAKEN TO BE AGAINST THE ASSESSEE ON THE ISSUE UNDER CONSIDERATION , WE ARE BOUND TO FOLLOW THE VIEW WHICH IS IN FAVOUR OF THE ASSESSEE AS PER THE RATIO LAID DOWN IN CIT VS VEGETABLE PRODUCTS 88 ITR 192 ( SC). BESIDES THE ABOVE LEASE DOCUMENT HAS USED THE 'DEVE LOPMENT CHARGES' AND 'ECONOMIC RENT' TO BE PAYABLE BY THE A SSESSEE. AS THE DOCUMENT HAS USED TWO DIFFERENT PHRASES TO CONN OTE DIFFERENT OBLIGATION THEREFORE IN OUR VIEW DEVELOPMENT CHAR GES CAN'NOT BE READ AS RENT WITHIN THE PURVIEW OF THE SECTION 194 I. FURTHER LEASE DOCUMENT HAS PROVIDED THE CONSEQUENCES OF NON-PAYM ENT OF THE DEVELOPMENT CHARGES BY THE ASSESSEE, IF THE ASSESSE E FAILED TO PAY THE DEVELOPMENT CHARGES, AS MENTIONED IN THE AGREEM ENT, THE POSSESSION WAS LIABLE TO BE TAKEN OVER BY THE RIICO , THEREFORE THE DEVELOPMENT CHARGES CAN NOT BE CONSIDERED AS RENT. 2.2 IN VIEW OF THE SIMILAR FACTS AND CIRCUMSTANCES OF THE ASSESSEE'S CASE AND RESPECTFULLY FOLLOWING THE DECISION OF COORDINATE B ENCH IN THE CASE OF M/S. GUPTA FABTEX (P) LTD. (SUPRA), THE APPEAL OF THE AS SESSEE IS ALLOWED. 2.3 REGARDING GROUND NO.2, BRIEFLY THE FACTS OF TH E CASE ARE THAT DURING THE YEAR UNDER CONSIDERATION, THE APPELLANT HAS MADE PA YMENT OF RS.8,65,000/- TO M/S RAJASTHAN TECHNICAL UNIVERSITY (RTU) ON ACCOUNT OF AFFILIATION FEE ON WHICH TDS WAS NOT DEDUCTED. THE AO ACCORDINGLY RAI SED DEMAND OF RS. 97055/- U/S 201(1)/201(1A) OF THE IT ACT. AS PER A O, SUCH PAYMENT WAS IN THE NATURE OF PROFESSIONAL FEE AND THAT THE RTU IS FORM ED BY WAY OF A STATE ACT AND NOT BY WAY OF CENTRAL ACT AND THEREFORE IT WAS NO T COVERED U/S 196 OF IT ACT. THE AO ALSO NOTED THAT THE ASSESSEE HAS FAILED TO PRODUCE ANY EVIDENCE WHICH MAY PROVE THAT RTU WAS EXEMPT FROM INCOME TAX AND THAT BEFORE MAKING ITA NO. 18/JP/14 SHANTI EDUCATION SOCIETY, JAIPUR VS. DCIT (TDS), J AIPUR 5 SUCH PAYMENT THE APPELLANT WAS TO OBTAIN NECESSARY DOCUMENT FROM THE DEDUCTOR IN SUPPORT OF THE FACT THAT SUCH ENTITY WA S EXEMPT FROM INCOME TAX. ON THE OTHER HAND THE APPELLANT CASE IS THAT THE PA YMENT MADE TO M/S RTU ARE NOT IN THE NATURE OF PROFESSIONAL FEE IS AS MU CH AS RTU DOES NOT PROVIDE ANY OF THE SERVICES REFERRED IN SECTION 194J AND O NLY REGULATORY ROLE WAS DISCHARGED FOR WHICH SUCH PAYMENT WAS RECEIVED. I T IS ALSO STATED THAT RTU IS WHOLLY FINANCED BY GOVT. OF RAJASTHAN AND THEREFORE THE INCOME OF RTU IS EXEMPT U/S 10(23C)(IIIAB). THE APPELLANT HAS ALS O FILED COPY OF COMPUTATION OF TOTAL INCOME AND ACKNOWLEDGEMENT OF INCOME TAX R ETURN FOR A.Y. 2008-09 WHEREIN INCOME IS SHOWN AS EXEMPT U/S 10(23C)(IIIAB ). THE APPELLANT ALSO FILED A COPY OF REPORT OF THE OFFICE OF AG IN WHICH AT PA GE NO.30 AT PARA 9, IT IS MENTIONED THAT RTU IS EXEMPT U/S 10(23C)(IIIAB). 2.4 THE LD CIT(A) HAS GIVEN HIS FINDINGS AS UNDER: FIRST OF ALL THE ISSUE AS TO WHETHER ON THE PAYMEN TS MADE TO RTU, TDS WAS TO BE DEDUCTED OR NOT IS TO BE DECIDED. IT MAY BE NOTED THAT THE APPELLANT SOCIETY IS A UNIVERSITY AND FOR ACADEMIC REASONS AFFILIATED TO RTU. THEREFORE THE PAYMENT MADE TO RTU IS BASICALL Y OF SOME CONTRACTUAL NATURE IN AS MUCH AS FOR AFFILIATION WO RK, THE RTU HAS TO DISCHARGE CERTAIN FUNCTIONS FOR WHICH SUCH PAYMENTS ARE MADE. THEREFORE TDS WAS TO BE DEDUCTED ON SUCH PAYMENT. NOW THE OTHER ISSUE IS TO BE CONSIDERED AS TO WHETHER THE INCOME OF THE RTU IS EXEMPT U/S 10(23C)(IIIAB) OF THE IT ACT OR NOT. IT MAY BE NOTED THAT THERE IS NO DISPUTE ON THE FACT THAT PAYMENT OF RS. 8,65,000/- WAS MADE TO M/S RTU AND WHEN THE PAYMENT WAS MADE WHICH WERE OF CONTRA CTUAL NATURE, THERE WAS NO VALID BASIS FOR NON-DEDUCTION OF TAX I N AS MUCH AS M/S RTU WAS NOT COVERED U/S 196 AS ALSO THAT THERE WAS NO E VIDENCE TO PROVE THAT RTU WAS COVERED U/S 10(23C)(IIIAB). HOWEVER DURING THE APPELLATE PROCEEDINGS AS AN ADDITIONAL EVIDENCE THE APPELLA NT FILED XEROX COPY OF INCOME TAX RETURN FOR A.Y. 2008-09 AS ALSO SOME FIN DING/OBSERVATION OF AG AUDIT. IN THE XEROX COPY OF INCOME TAX RETURN FOR A.Y. 2008-09, M/S RTU HAS CLAIMED ITS INCOME AS EXEMPT U/S 10(23C)( IIIAB). HOWEVER, THE APPEAL UNDER CONSIDERATION IS IN RESPECT OF A.Y. 20 12-13 AND SUCH COPY OF ITA NO. 18/JP/14 SHANTI EDUCATION SOCIETY, JAIPUR VS. DCIT (TDS), J AIPUR 6 INCOME TAX RETURN FOR A.Y. 2008-09 MAY NOT PROVE TH AT ALL CONDITIONS LAID DOWN U/S 10(23C)(IIIAB) ARE FULFILLED BY M/S RTU. IN FACT SUCH RETURN OF SUCH A.Y. 2008-09, IT MAY BE THE CLAIM OF M/S RTU T O BE COVERED U/S 10(23C)(IIIAB) BUT THERE IS NOTHING ON RECORD WHICH MAY INDICATE THAT SUCH STATUS OF M/S RTU HAS BEEN ACCEPTED BY THE DEP ARTMENT OR NOT. AS REGARDS OTHER ADDITIONAL EVIDENCE IN SUPPORT OF EXE MPT INCOME OF M/S RTU BEING FINDING OF AUDITORS OF AG DEPARTMENT IT M AY BE MENTIONED THAT THEIR FINDINGS MAY NOT BE A VALID BASIS FOR TR EATING THE INCOME OF M/S RTU TO BE EXEMPT U/S 10(23C)(IIIAB) OF THE ACT. THE IMPORTANT POINT TO BE NOTED IS THAT THE PAYMENT WAS MADE DURING A.Y . 2012-13 AND THE DOCUMENT TO BE RELIED UPON FOR CLAIM OF EXEMPTED IN COME OF M/S RTU SHOULD ALSO BE PERTAINING TO THAT PERIOD ONLY. THE REFORE PRIMA FACIE WHEN THE PAYMENT WAS MADE TO M/S RTU, THE APPELLAN T WAS REQUIRED TO DEDUCT TAX AND AS THE APPELLANT FAILED TO DEDUCT TA X ON SUCH PAYMENT THEREFORE SUCH DEMAND AMOUNTING TO RS., 97055/- AS RIGHTLY RAISED. THE GROUND OF APPEAL IN RESPECT OF RAISING OF SUCH DEM AND ON ACCOUNT OF NON-DEDUCTION OF TAX IS ACCORDINGLY DISMISSED. 2.5 DURING THE COURSE OF HEARING, THE LD AR REITERA TED ITS SUBMISSIONS MADE BEFORE THE LOWER AUTHORITIES AND SUBMITTED THAT RTU IS NOT RENDERING ANY PROFESSIONAL SERVICES. RTU IS JUST A REGULATOR FOR TECHNICAL COLLEGES AND PROVISIONS OF SECTION 194J ARE NOT APPLICABLE ON PA YMENT TO RTU. LD AR FURTHER DRAWN REFERENCE TO CBDT CIRCULAR NO 4/2002 DATED 16 .7.2002 TO SUPPORT HIS CONTENTION THAT THE TDS PROVISIONS ARE NOT APPLICAB LE AS THE INCOME OF THE ASSESSEE IS EXEMPT UNDER SECTION 10(23C)(IIIAB) OF THE ACT. 2.5 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSE D THE MATERIAL AVAILABLE ON RECORD. THE CBDT CIRCULAR NO 4/2002 DATED 16.7. 2002 HAS BEEN ISSUED IN THE CONTEXT OF SELF-DECLARATION BY ENTITIES/INSTITU TIONS WHOSE INCOME IS EXEMPT UNDER SECTION 10 OF THE ACT. IN THE SAID CIRCULAR, THE CBDT HAS CLARIFIED THAT IN CASE OF THOSE FUNDS OR AUTHORITIES OR BOARDS OR BO DIES, BY WHATEVER NAME CALLED, WHOSE INCOME IS UNCONDITIONALLY EXEMPTION U /S 10 OF THE IT ACT AND WHO ARE STATUTORILY NOT REQUIRED TO FILE RETURN OF INCOME AS PER SECTION 139 OF ITA NO. 18/JP/14 SHANTI EDUCATION SOCIETY, JAIPUR VS. DCIT (TDS), J AIPUR 7 THE INCOME TAX ACT, , THERE WOULD BE NO REQUIREMENT FOR TAX DEDUCTION AT SOURCE SINCE THEIR INCOME IS ANYWAY EXEMPT UNDER TH E INCOME TAX ACT. THE INSTITUTIONS WHOSE INCOME IS UNCONDITIONALLY EXEMPT U/S 10 AND WHO ARE STATUTORILY NOT REQUIRED TO FILE RETURN OF INCOME A S PER THE PROVISIONS OF SECTION 139 INCLUDES: PRIME MINISTERS NATIONAL RELIEF FUND REFERRED TO IN SUB-CLAUSE(I) PRIME MINISTERS FUND (PROMOTION OF FOLK ART) REFERRED TO IN SUB-CLAUSE (II),M PRIME MINISTERS AID TO STUDENTS FUND REFERRED TO IN SUB- CLAUSE (III), NATIONAL FOUNDATION FOR COMMUNAL HARMONY REFERRED TO IN SUB- CLAUSE (IIIA), ANY UNIVERSITY OR OTHER EDUCATIONAL INSTITUTION REFERRE D TO IN SUB-CLAUSE (IIIAB) AND ANY HOSPITAL OR OTHER INSTITUTION FOR THE RECEIPTIO N AND TREATMENT OF PERSONS AS REFERRED TO IN SUB-CLAUSE (IIIAC) OF CLAUSE 23C). THE APPELLANT HAS CLAIMED THAT THE INCOME OF RTU IS EXEMPT UNDER SECTION 10(23C)(IIIAB) OF THE ACT. WHERE THE INCOME OF RT U IS EXEMPT, IN LIGHT OF CBDT CIRCULAR, THERE IS NO REQUIREMENT TO DEDUCT TAX AT SOURCE. IN LIGHT OF ABOVE, THE AO IS DIRECTED TO VERIFY FROM THE CONCERNED AO OF R TU AS WELL AS INDEPENDENTLY FROM RTU WHETHER THE INCOME OF RTU IS EXEMPT UNDER SECTION 10(23C)(IIIAB) OF THE ACT. IF THE AO FINDS THE SAME TO BE IN ORDER, THE AO IS DIRECTED NOT TO TREAT THE ASSESSEE IN DEFAULT U/S 201(1) OF THE ACT AND T HEREBY NOT TO RECOVER ANY TAX AND INTEREST U/S 201(1A) ON PAYMENTS TO RTU. IN THE RESULT THE APPEAL FILED BY THE ASSESSEE IS P ARTLY ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 30/06 /2016. SD/- SD/- ( KUL BHARAT ) (VIKRAM SINGH YADAV) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER JAIPUR DATED:- 30/ 06/2016 ITA NO. 18/JP/14 SHANTI EDUCATION SOCIETY, JAIPUR VS. DCIT (TDS), J AIPUR 8 PILLAI VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SHANTI EDUCATION SOCIEITY, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- THE DCIT, TDS, JAIPUR 3. VK;DJ VK;QDR@ CIT TDS, JAIPUR 4. VK;DJ VK;QDRVIHY@ THE CIT(A)-III, JAIPUR 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO. 18/JP/2014) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR