DCIT, Jaipur V. RAJASTHAN RAJYA SAHKARI UPHBHKTA SANGH LTD, Jaipur

ITA 203/JPR/2015

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 5396 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 2 month(s) 6 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 05-05-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2010-2011
• Appeal Filed On: 27-02-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: KAILASH MANGAL J
• Assessee Lawyers: ROHIT BADAYA CA DHK
• Keywords: Depreciation; Onus to prove
• Section: 43B; 40A(3); 143(3)

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 DQY HKKJR] U;KF;D LNL; ,OA JH VH-VKJ-EHUK] YS[KK LNL; DS LE{K BEFORE: SHRI KUL BHARAT, JM & SHRI T.R. MEENA, AM VK;DJ VIHY LA-@ ITA NO. 203/JP/2015 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2010-11 THE DCIT CIRCLE- 6 JAIPUR CUKE VS. M/S. RAJASTHAN RAJYA SAHAKARI UPBHOKTA SANGH LTD., SAHKAR BHAWAN, BHAWANI SINGH ROAD, JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: AABFR 3362 D VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT JKTLO DH VKSJ LS@ REVENUE BY : SHRI KAILASH MANGAL, JCIT-DR FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY :SHRI ROHIT BADAYA, CA LQUOKBZ DH RKJH[K@ DATE OF HEARING : 22/04/2016 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 05 /05/2016 VKNS'K@ ORDER PER KUL BHARAT, JM THIS APPEAL OF THE REVENUE IS DIRECTED AGAINST THE ORDER OF THE LD. CIT(A)-2, JAIPUR DATED 29-12-2014 PERTAINING TO AS SESSMENT YEAR 2011- 11. THE REVENUE HAS RAISED FOLLOWING GROUNDS OF AP PEAL. (I) WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION OF RS. 4,59,816/- MADE BY THE AO BY DISALL OWING DEPRECIATION ON BUILDING IN SPITE OF THE FACT THE A SSESSEE FAILED TO DISCHARGE ITS ONUS TO PROVE THAT THE BUIL DING WAS USED FOR BUSINESS PURPOSES. ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 2 (II) WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW, THE LD. CIT(A) WAS JUSTIFIED IN DELETIN G THE ADDITION OF RS. 61,671/- MADE BY THE AO ON ACCOUNT OF CAPITAL GAIN ON THE ASSETS OF BHARATPUR AND KOTA BR ANCH SOLD DURING THE YEAR (III)(A) WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW, THE LD. CIT(A) WAS JUSTIFIED IN DELETIN G THE ADDITION OF RS. 53,58,712/- MADE FOR DEPOSITING THE EMPLOYEES CONTRIBUTION TO PF AND ESI BEYOND THE PRESCRIBED TIME LIMIT PROVIDED IN THE RESPECTIVE AC TS. (B) WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE C ASE AND IN LAW, THE LD. CIT(A) HAS ERRED IN HOLDING THA T EMPLOYEES CONTRIBUTION TO PF & ESI ARE GOVERNED BY THE PROVISION OF SECTION 43B AND NOT BY SECTION 36(1)(V A) R.W.S. 2(24)(X) OF THE I.T. ACT (IV) WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. CIT(A) HAS ERRED IN DELETING THE ADDITION OF RS. 46,019/- MADE BY THE AO ON ACCOUNT OF PENAL ESI PAYMENT. 2.1 BRIEFLY STATED THE FACTS OF THE CASE OF THE ASS ESSEE WAS PICKED UP FOR SCRUTINY ASSESSMENT AND THE ASSESSMENT WAS MADE U/S 143(3) OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO ACT FOR SHORT) VIDE ORDER DATED 18-03-2013. WHILE FRAMING ASSESSMENT, T HE AO MADE DISALLOWANCES UNDER THESE HEADS. (I) RS. 3,49,038/- U/S 40A(3) OF THE ACT (BEING CA SH PAYMENTS IN EXCESS OF RS. 20,000/- ON CERTAIN OCCAS IONS BY THE ASSESSEE). ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 3 (II) DEPRECIATION OF RS. 4,59,816/- FOR BUILDING AT CHANDPOLE TOPKHANA (III) RS. 61,671/- IN RESPECT OF CAPITAL GAIN TA X (IV) DELAY PAYMENT OF PF CONTRIBUTION OF RS. 53,5 8,712/- (V) ESI PENALTY OF RS. 46,019/- 2.2 THE ASSESSEE PREFERRED FIRST APPEAL BEFORE THE LD. CIT(A) AGAINST THE ABOVE DISALLOWANCES WHO AFTER CONSIDERING THE SUBMI SSIONS PARTLY ALLOWED THE APPEAL OF THE ASSESSEE BY SUSTAINING TH E DISALLOWANCE OF RS. 3,49,038 AND THUS DELETED THE OTHER DISALLOWANCES. 2.3 AGGRIEVED BY THE ORDER OF THE LD. CIT(A), THE R EVENUE IS IN PRESENT APPEAL BEFORE US. 2.4 THE FIRST GROUND OF THE REVENUE RELATES TO DELE TION OF ADDITION OF RS. 4,59,816/- MADE BY THE AO IN RESPECT OF DEPREC IATION. 2.5 THE LD. DR SUPPORTED THE ORDER OF THE AO AND SU BMITTED THAT THE LD. CIT(A) WAS NOT JUSTIFIED IN DELETING THE ADDITI ON. 2.6 THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE AO WAS NOT JUSTIFIED IN MAKING THE DISALLOWANCE AS BUILDING AT CHANDPOLE TOPKHANA WAS DULY UTILIZED FOR BUSINESS PURPOSES. THE RELEVA NT DETAILS AND MATERIAL WAS PLACED BEFORE THE AO. HE PLACED RELIANCE ON THE ORDER OF THE LD. CIT(A). ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 4 2.7 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. THE ONLY BASIS FOR DISALLOWANC E BY THE AO WAS THAT THE BUILDING IN QUESTION WAS NOT UTILIZED FOR BUSIN ESS PURPOSES. HOWEVER, THE LD. CIT(A) HAS GIVEN FINDING ON FACT AT PARA 3. 3 IN HIS ORDER AS UNDER:- 3.3 I HAVE PERUSED THE FACTS OF THE CASE, THE ASSESSMENT ORDER AND THE SUBMISSIONS OF THE APPELLA NT. THE ASSESSING OFFICER HAS DISALLOWED DEPRECIATION ON BU ILDING AT CHANDPOLE TOPKHANA ON THE GROUND THAT EVIDENCES HAV E NOT BEEN SUBMITTED FOR PURCHASE OF BUILDING AND THAT THE SAL E REGISTER SUBMITTED BY THE APPELLANT REGARDING THE BUSINESS C ARRIED OUT BY IT FROM THIS PREMISES DOES NOT CONTAIN THE NAME OF THE PREMISES. THE APPELLANT HAS SUBMITTED THE PURCHASE DEED SHOWING T HE PURCHASE OF THIS BUILDING. THE SALE REGISTER SUBMITTED BY THE A PPELLANT CLEARLY SHOWS THAT IT PERTAINS TO THE CHANDPOLE BAZAR, TOPK HANA KA RASTA, BUILDING. THEREFORE, THE APPELLANT HAS DISCHARGED ITS ONUS REGARDING OWNERSHIP OF BUILDING AS WELL AS EVIDENCE OF IT BEING PUT TO USE FOR ITS BUSINESS DURING THE YEAR. IN VIEW OF THE ABOVE, THE ASSESSING OFFICER IS DIRECTED TO DELETE ADDITION ON ACCOUNT OF DISALLOWANCES OF DEPRECIATION ON THE ABOVE BUILDING . THIS FINDING OF FACT IS NOT CONTROVERTED BY THE REV ENUE BY PLACING ANY MATERIAL ON RECORD SINCE THE LD. CIT(A) HAS GIVEN A FINDING THAT THE BUSINESS WAS CARRIED OUT BY THE ASSESSEE FROM THIS PREMISES. THE LD. COUNSEL FOR THE ASSESSEE DREW OUR ATTENTION AT PAGE S 41 TO 53 OF THE PAPER BOOK IN SUPPORT OF HIS CONTENTION WITH REGARD TO OW NERSHIP OF THE BUILDING AND USAGE OF THE SAME FOR BUSINESS PURPOSES. THE RE VENUE HAS NOT CONTROVERTED THE AUTHENTICITY OF THESE DOCUMENTS. T HEREFORE, WE DO NOT ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 5 SEE ANY REASON TO DISTURB THE FINDINGS OF THE LD. C IT(A) ON THIS ISSUE WHICH IS UPHELD. THE GROUND NO. 1 RAISED BY THE REV ENUE IS DISMISSED. 3.1 THE GROUND NO. 2 OF THE REVENUE IS WITH REGARD TO DELETION OF ADDITION OF RS. 61,671/-. 3.2 THE LD. DR SUPPORTED THE ORDER OF THE AO. 3.3 ON THE CONTRARY, THE LD. COUNSEL FOR THE ASSESS EE RELIED ON THE FINDINGS OF THE LD. CIT(A). THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE AO HAS FAILED TO APPRECIATE THE FACT THAT THE A SSETS IN QUESTION FORMED ITS PART OF BLOCK OF ASSETS AND SAME WERE REDUCED F ROM THE BLOCK OF ASSETS AS PER PROVISIONS OF LAW. 3.4 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. WE FIND THAT THE LD. CIT(A) IN PARA 4.3 OF HIS ORDER HAS GIVEN A FINDING OF FACT AS UNDER:- 4.3 I HAVE PERUSED THE FACTS OF THE CASE, THE ASSESSMENT ORDER AND THE SUBMISSIONS OF THE APPELLA NT. THE ASSESSEE HAS SOLD FURNITURE AND FIXTURE, REFRIGERAT OR AND SALES COUNTER FOR A SALE CONSIDERATION OF RS. 67,67 1/-. THE ASSESSING OFFICER HAS ADDED THE ENTIRE SALE CONSID ERATION AS CAPITAL GAINS. THE APPELLANT HAS EXPLAINED THAT THE SE ASSETS FORM A PART OF ITS BLOCK OF ASSETS AND HAVE BEEN RE DUCED FROM THE BLOCK OF ASSETS AS PER THE PROVISIONS OF LAW. I HAVE PERUSED THE FIXED ASSETS SCHEDULE AND FIND THAT THE APPELLANT HAS REDUCED THE SALE CONSIDERATION FROM THE BLOCK O F ASSETS AFTER WHICH THE BLOCK OF ASSETS HAVE NOT REDUCED TO RS. NIL. THEREFORE, THE ADDITION MADE BY THE ASSESSING OFFIC ER IS NOT ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 6 IN ACCORDANCE WITH THE PROVISIONS OF LAW AND IS DIR ECTED TO BE DELETED. THIS GROUND IS ALLOWED. THE REVENUE HAS NOT CONTROVERTED THE FACT THAT THE ASSETS IN QUESTION FORMED PART OF THE BLOCK OF ASSETS OF THE ASSESSEE. THEREFORE, WE DO NOT SEE ANY REASON TO INTERFERE WITH THE FINDINGS OF TH E LD. CIT(A) WHICH IS HEREBY UPHELD. THE GROUND NO. 2 RAISED BY THE REVEN UE IS DISMISSED. 4.1 APROPOS GROUND NO. 3(A) AND (B), THE LD. DR SUP PORTED THE ORDER OF THE AO AND SUBMITTED THAT THE LD. CIT(A) WAS NOT JUSTIFIED IN DELETING THE DISALLOWANCE OF RS. 53,58,712/-. 4.2 ON THE CONTRARY, THE LD. COUNSEL FOR THE ASSESS EE SUBMITTED THAT THE PF CONTRIBUTION WAS PAID BY THE ASSESSEE BEFORE DUE DATE OF FILING OF RETURN OF INCOME U/S 139(1) OF THE ACT. 4.3 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. WE FIND THAT THE LD. CIT(A) IN PARA 5.2 AND 5.3 OF HIS ORDER OBSERVED AS UNDER:- 5.2 THE RELEVANT EXTRACT OF THE SUBMISSION OF THE APPELLANT IS AS UNDER:- THE ASSESSING OFFICER HAS MADE ADDITION OF RS. 53,58,712/- ON ACCOUNT OF LATE DEPOSIT OF PF. THE PF DEPOSITED AS UNDER:- MONTH EMPLOYEE CONTRIBUTION DUE DATE DATE OF PAYME NT APRIL 09 356740 15-05-2009 15-09-2009 MAY 09 378424 15-06-2009 15-09-2009 ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 7 JUNE 09 485374 15-07-2009 03-09-2009 JULY 09 603910 15-08-2009 29-01-2010 AUG. 09 414484 15-09-2009 29-01-2010 SEP. 09 613045 15-10-2009 29-01-2010 OCT. 09 403729 15-11-2009 29-01-2010 NOV. 09 408990 15-12-2009 29-01-2010 DEC. 09 397535 15-01-2010 29-01-2010 JAN. 10 466689 15-02-2010 23-02-2010 FEB. 10 395472 15-03-2010 05-04-2010 MARCH 10 434020 15-04-2010 08-05-2010 THE ASSESSEE HAS MADE PAYMENT BEFORE DUE DATE OF RE TURN FILING UNDER INCOME-TAX ACT. THIS ISSUE IS COVERED BY HON'BLE ITAT AND CIT (APPEALS) JUDGEMENT FOR A.Y. 2007-08 I N ASSESSEE'S OWN CASE. 5.3 I HAVE PERUSED THE FACTS OF THE CASE, THE ASSES SMENT ORDER AND THE SUBMISSIONS OF THE APPELLANT. ADMITTE DLY, CONTRIBUTION TO PF HAS BEEN PAID BY THE APPELLANT, IN ALL INSTANCES, BEFORE THE DUE DATE OF FILING THE RETURN OF INCOME U/S 139(1). THIS FACT IS THEREFORE, NOT IN DISPUTE. IN VIEW OF THE J UDGEMENTS OF RAJASTHAN HIGH COURT IN THE CASE OF JAIPUR VIDHYUT VITHRAN NIGAM LTD. 265 LD. CTR 62 (RAJ.), CIT VS. STATE BANK OF B IKANER & JAIPUR (2014), 99 DTR 131 (RAJ.) AND OTHER CASE LAWS ON TH IS ISSUE, THE CLAIM OF THE APPELLANT IS ALLOWABLE. ACCORDINGLY, T HIS DISALLOWANCE MADE BY THE ASSESSING OFFICER IS, DIRECTED TO BE DE LETED. THIS GROUND IS ALLOWED. THE REVENUE HAS NOT CONTROVERTED THE FACT THAT PF C ONTRIBUTION WAS MADE BEFORE DUE DATE OF FILING OF THE RETURN. MOREOVER, THE ISSUE IS NO MORE RES INTEGRA AND IT HAS BEEN DECIDED BY HON'BLE JURI SDICTIONAL HIGH COURT IN THE CASE OF JAIPUR VIDHYUT VITHRAN NIGAM LTD., 2 65 ITR 62, IN FAVOUR OF THE ASSESSEE. RESPECTFULLY FOLLOWING THE RATIO O F HON'BLE JURISDICTIONAL HIGH COURT IN THE CASE OF VIDHYUT VITHRAN NIGAM LTD . (SUPRA), WE DO NOT ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 8 SEE ANY REASON TO INTERFERE WITH THE ORDER OF THE L D. CIT(A) WHICH IS UPHELD. THE GROUND NO. (III) (A) AND (B) OF THE REV ENUE IS DISMISSED. 5.1 GROUND NO. (IV) OF THE REVENUE IS REGARDING DEL ETION OF ADDITION OF RS. 46,019/- MADE BY THE AO ON ACCOUNT OF PENAL ES I PAYMENT. BRIEF FACTS OF THE CASE ARE THAT THE AO OBSERVED FROM THE PROFIT AND LOSS ACCOUNT OF THE ASSESSEE THAT AN AMOUNT OF RS. 46,019/- WAS PAID AS ESI PENALTY. THE AO ASKED THE ASSESSEE TO CLARIFY AS TO WHY THIS AMOUNT OF RS. 46,019/- SHOULD NOT BE DISALLOWED. THE REPLY OF THE ASSESSEE WAS NOT FOUND SATISFACTORY BY THE AO WHO DISALLOWED THE PAY MENT OF RS. 46,019/- AND ADDED THE SAME TO THE INCOME OF THE ASSESSEE. 5.2 AGGRIEVED, THE ASSESSEE PREFERRED FIRST APPEAL BEFORE THE LD. CIT(A) WHO ALLOWED THE CLAIM OF THE ASSESSEE BY OBSERVING AT PARA 5.2 AND 5.3 OF HIS ORDER AS UNDER:- 5.2 THE RELEVANT EXTRACT OF THE SUBMISSION OF THE APPELLANT IS AS UNDER:- ASSESSEE HAS PAID A SUM OF RS. 46,019/- AS ESI CONTRIBUTION AND CLAIM THE SAME AS EXPENDITURE, ASSESSING OFFICER TREATED THE SAME AS PENALTY AND DISALLOWED THE EXPENSES. WHEREAS THE FACT IS THAT THE ASSESSEE HAS PAID A SU M OF RS. 45,019/- (RS.29,706 AND RS. 16317) WHICH WAS PAID AS ESI PAYMENT ON THE DISPOSAL OF APPEAL MADE BEFORE THE HON'BLE COURT ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 9 THE ASSESSEE HAS NOT CONSIDERED THE COUNTER MAINTENANCE ALLOWANCE AND THE OVERTIME FOR ESI LIABILITY PAYMENT. THE HON'BLE COURT HAS GIVEN DIRECTION TO CONSIDER THE COUNTER MAINTENANCE ALLOWANCE AND THE OVERTIME FOR ESI PAYMENT. THEREFORE, THE ASSESSEE PAID THE ESI AMOUNT. THIS AMOUNT DOES NOT INVOLVE THE PENALTY AMOUNT( ANNEXED COPY OF VOUCHER OF HON'BLE COURT JUDGMENT , COPY O F OFFICE ORDER AT PAGE NO. 94-112) 5.3 I HAVE PERUSED THE FACTS OF THE CASE, THE ASSESSMENT ORDER AND THE SUBMISSIONS OF THE APPELLANT. THE APPELLANT HAS STATED THAT PAYMENT OF RS. 46,019/- TOWARDS ESI HAS NOT BEEN MADE TOWARDS PENALTY BUT ARISES OUT OF COUNTER MAINTENANCE ALLOWANCE AND OVERTIME ALLOWANCE BEING CONSIDERED FOR ESI AS PER THE ORDERS OF THE HIGH COURT. THE APPELLANT HAS SUBMITTED THE COPY OF JUDGEMENTS OF T HE HIGH COURT AND COPIES OF VOUCHERS AND CHALLANS IN SUPPORT OF ITS CONTENTION. ON PERUSAL OF THE SAME, I DO NOT FIND THAT ANY ELEMENT OF PENALTY IS INVOLVED IN THIS EXPENDITURE. IN VIEW OF THE ABOVE, THE DISALLOWANCE MADE BY THE ASSESSING OFFICER IS DIRECTED TO BE DELETED. THIS GROUND IS ALLOWED. 5.3 THE LD. DR RELIED ON THE ORDER OF THE AO WHEREA S THE LD. AR OF THE ASSESSEE RELIED ON THE ORDER OF LD. CIT(A). 5.4 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. WE FIND THAT THE ISSUE IN QUES TION PERTAINS TO COUNTER MAINTENANCE ALLOWANCE AND OVERTIME ALLOWANCE BEING CONSIDERED FOR ESI AS PER THE ORDERS OF THE HON'BLE HIGH COURT , HENCE THE AMOUNT OF RS. 46,019/- TAKEN BY THE AO IN HIS ASSESSMENT ORDE R IS NOT A PENALTY. IN ITA NO. 203/JP/2015 THE DCIT, CIRCLE- 6,JAIPUR VS. RAJASTHAN RAJYA SAHA KARI UPBHOKTA SANGH LTD. ,JAIPUR . 10 VIEW OF THE ABOVE DELIBERATIONS, WE FIND NO INFIRMI TY IN THE ORDER OF THE LD. CIT(A) WHICH IS SUSTAINED ON THIS ISSUE. THE GR OUND NO. (IV) OF THE REVENUE IS DISMISSED. 6.0 IN THE RESULT, THE APPEAL OF THE REVENUE IS DIS MISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 05/05/20 16. SD/- SD/- VH-VKJ-EHUK DQY HKKJR (T.R. MEENA) (KUL BHARAT) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 05/5/ 2016 *MISHRA VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- THE DCIT , CIRCLE- 6, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- M/S. RAJASTHAN RAJYA SAHKARI UPBHO KTA SANGH LTD. , JAIPUR 3. VK;DJ VK;QDRVIHY ) @ CIT(A), 4. VK;DJ VK;QDR@ CIT, 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO.203/JP/2015) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR