POPULAR PRINTERS, Jaipur V. ITO, Jaipur

ITA 226/JPR/2016

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 5112 (ITAT-JAIPUR)
• Duration Of Justice: 4 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-07-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2010-2011
• Appeal Filed On: 09-03-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: R A VERMA CIT DR DHK
• Assessee Lawyers: SL GUPTA
• Keywords: Rejection of books of accounts; Depreciation
• Section: 142(1); 145; 144

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 HKKXPUN] YS[KK LNL; DS LE{K BEFORE: SHRI BHAGCHAND, ACCOUNTANT MEMBER VK;DJ VIHY LA-@ ITA NO. 226/JP/2016 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2010-11 M/S. POPULAR PRINTERS FATEH TIBA MARG MOOTI DOONGRI ROAD, JAIPUR CUKE VS. THE ITO WARD- 5 (2) JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: AABFP 4426 A VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY: SHRI S.L. GUPTA, CA JKTLO DH VKSJ LS@ REVENUE BY :SHRI R.A. VERMA, ADDL. CIT-. DR LQUOKBZ DH RKJH[K@ DATE OF HEARING : 13/07/2016 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 25 /07/2016 VKNS'K@ ORDER PER BHAGCHAND, AM THE ASSESSEE HAS FILED AN APPEAL AGAINST THE ORDER OF THE LD. CIT(A)-5, JAIPUR DATED 12-01-2016 FOR THE ASSESSMEN T YEAR 2010-11 RAISING THEREIN FOLLOWING GROUND:- THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) IS WRONG, UNJUST AND ERRED IN LAW IN UPHOLDING THE REJECTING BOOK RESULTS OF THE APPELLANT BY RESO RT TO THE PROVISION OF SECTION 145(3) OF THE I.T. ACT. THE LD . CIT(A) IS FURTHER WRONG AND HAS ERRED IN LAW IN UPHOLDING TRA DING ADDITION OF RS. 2.50 LACS MADE BY AO ARBITRARILY. ITA NO. 226/JP/2016 M/S. POPULAR PRINTERS VS. ITO, WARD- 5 (2), JAIPUR . 2 2.1 BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE F ILED ITS RETURN OF INCOME ELECTRONICALLY ON 4-10-2010 DECLARING TOTAL INCOME OF RS. 14,97,440/-. THE RETURN WAS PROCESSED U/S 143(1) OF THE ACT AT RETURNED INCOME ON 25-05-2011. THE CASE OF THE ASSESSEE WAS SELECTED FOR SCRUTINY AND NOTICE U/S 143(2) OF THE ACT WAS ISSUED ON 26-0 8-2011 AND THE SAME WAS SERVED ON THE ASSESSEE ON 6-09-2011. ON CHANGE OF INCUMBENT, AGAIN NOTICE U/S 142(1) OF THE ACT ALONGWITH QUERY LETTER WAS ISSUE ON 5-06- 2012 AND 10-07-2012. IN COMPLIANCE THE CASE OF THE ASSESSEE WAS ATTENDED BY THE LD. AR OF THE ASSESSEE AND SUBMITTE D THE NECESSARY DETAILS. THE AO OBSERVED THAT THE ASSESSEE IS DERIV ING INCOME FROM PRINTING PRESS. THE ASSESSEE HAS MAINTAINED REGULAR BOOKS OF ACCOUNT I.E. LEDGER, CASH BOOK, JOURNAL, AND BANK BOOK ALONGWITH VOUCHERS FOR EXPENSES. THE BOOKS OF ACCOUNT WERE DULY AUDITED U/ S 44AB OF THE ACT AND AUDIT REPORT IN FORM NO. 3CB AND 3CD WERE FURNI SHED. THE ASSESSEE PRODUCED THE BOOKS OF ACCOUNT BEFORE THE AO DURING ASSESSMENT PROCEEDINGS WHICH WERE EXAMINED ON TEST CHECK BASIS . THE AO NOTICED THAT THE ASSESSEE HAS DECLARED FOLLOWING TRADING RE SULTS IN COMPARISON TO THE PRECEDING YEARS. A.Y. 2008-09 2009-10 2010-11 GROSS SALES (RS.) 5,24,13,970 10,37,40,593 10,39,59,870 GROSS PROFIT (RS. 1,10,04,017 1,78,76,693 1,79,71,027 GROSS PROFIT RATE 20.99% 17.23% 17.29% ITA NO. 226/JP/2016 M/S. POPULAR PRINTERS VS. ITO, WARD- 5 (2), JAIPUR . 3 THE AO OBSERVED THAT THE TURNOVER AND THE GROSS PR OFIT RATE OF THE ASSESSEE HAS INCREASED MARGINALLY DURING THE YEAR U NDER CONSIDERATION IN COMPARISON TO THE PRECEDING YEAR. THE AO OBSERVED T HAT THE ASSESSEE HAD NOT MAINTAINED THE STOCK REGISTER OR THE QUANTITATI VE DETAILS OR QUANTITATIVE DETAILS IN RESPECT OF SALES AND PURCHASES. THE ASS ESSEE HAD ALSO NOT MAINTAINED QUANTITATIVE DETAILS OF OPENING AD CLOSI NG STOCK. THE AO THUS RELIED ON FOLLOWING CASE LAWS AS TO INVOKING OF THE PROVISION OF SECTION 145 OF THE ACT FOR REJECTING THE BOOKS OF ACCOUNT O F THE ASSESSEE. (I) CIT VS. BRITISH PAINT INDIA LTD., 188 ITR 44 (SC( (II) S.N. NAMASIVAYAM CHETTIAR VS. CIT , 38 ITR 57 9 (SC) THE AO OBSERVE THAT THE BOOKS OF ACCOUNT MAINTAINED BY THE ASSESSEE CANNOT BE RELIED AS THERE IS DISCREPANCY OF STOCK R EGISTER AND QUANTITATIVE DETAILS OF OPENING AND CLOSING STOCK OF THE ASSESSE E. HENCE, THE AO REJECTED THE BOOKS OF ACCOUNT OF THE ASSESSEE AND I NVOKED THE PROVISION OF SECTION 145(3) OF THE ACT. AFTER REJECTING THE BOOK RESULT, THE GROSS PROFIT IS REQUIRED TO BE ESTIMATED BY THE AO AND IN SUCH C ASES, THE BEST GUIDING FACTOR TO DECIDE THE GROSS PROFIT IS PAST HISTORY OF THE ASSESSEE. DURING THE PRECEDING YEAR, THE AO HAD MADE TRADING ADDITION OF RS. 2.50 LACS ALMOST IN SIMILAR CIRCUMSTANCES. HENCE, THE AO OBSERVED TH AT IT WOULD BE LOGICAL, FAIR AND REASONABLE TO MAKE SAME TRADING A DDITION OF RS. 2.50 LACS ITA NO. 226/JP/2016 M/S. POPULAR PRINTERS VS. ITO, WARD- 5 (2), JAIPUR . 4 FOR THE YEAR UNDER CONSIDERATION AND THUS HE MADE T HE TRADING ADDITION OF RS. 2.50 LACS AND ADDED THE SAME TO THE TOTAL INCOM E OF THE ASSESSEE. 2.2 BEING AGGRIEVED, THE ASSESSEE CARRIED THE MATTE R BEFORE THE LD. CIT(A) WHO HAS CONFIRMED THE ACTION OF THE AO BY OB SERVING AS UNDER:- 2.3 I HAVE CONSIDERED THE FACTS OF THE CASE, THE ASSESSMENT ORDER AND SUBMISSIONS OF THE APPELLANT. THE SAME ISSUE ALSO AROSE IN THE CASE OF THE APPELLANT IN A. Y. 2008-09 A WELL AS IN A.Y. 2009-10 WHEREIN THE CIT (A)II, JA IPUR IN APPEAL NO. 299/10-11 DATED 22-04-2013 FOR A.Y. 2008 -09 AND APPEAL NO. 422/11-12 FOR A.Y. 2009-10 DATED 8-0 12015 HAVE UPHELD THE REJECTION OF BOOKS OF ACCOUNT ON TH E GROUNDS THAT NO STOCK REGISTER HAS BEEN MAINTAINED AND A NU MBER OF EXPENSES ARE SUPPORTED ONLY BY SELF MADE VOUCHERS. THE FATS BEING THE SAME IN THIS YEAR ALSO, THE REJECTION OF BOOKS OF ACCOUNT U/S 145(4) IS HEREBY UPHELD. IT IS FURTHER NOTED THAT AFTER REJECTION OF BOOKS OF ACCOUNT, TRADING ADDITI ON OF RS. 2,00,000 AND RS. 2,50,000 RESPECTIVELY WERE UPHELD IN ASSESSMENT YEARS 200-09 AND 2009-10 BASED UPON THE FALL IN G.P. RATE IN THOSE YEARS. IN THE YEAR UNDER CONSIDE RATION, THE GROSS PROFIT RATE HAS SLIGHTLY RISEN FROM 17.23% IN A.Y. 2009-10 TO 17.29% IN A.Y. 2010-11. HOWEVER, THE GRO SS PROFIT RATE FOR A.Y. 200-09 WAS 20.99%. THERE IS TH EREFORE, A SUBSTANTIAL FALL IN G.P. DURING THE YEAR AS COMPARE D TO THAT IN A.Y. 2008-09. HOWEVER, THE AVERAGE G.P. OF A.Y. 200 8-09 AND 2009-10 WOULD BE A BETTER INDICATOR OF GROSS PR OFIT RATE WHICH MAY BE APPLIED. SUCH AVERAGE COMES TO 19.11% WHICH IF APPLIED WOULD LEAD TO AN ADDITION OF RS. 18,95,7 04/- AS AGAINST THE TRADING ADDITION OF RS. 2.50,000/- MADE BY THE AO. THEREFORE, I FIND NO REASON TO INTERFERE WITH T HE TRADING ADDITION OF RS. 2,50,000/- WHICH IS UPHELD. ITA NO. 226/JP/2016 M/S. POPULAR PRINTERS VS. ITO, WARD- 5 (2), JAIPUR . 5 2.3 DURING THE COURSE OF HEARING, THE LD. AR OF THE FILED THE FOLLOWING WRITTEN SUBMISSION WITH THE PRAYER TO DELETE THE TR ADING ADDITION CONFIRMED BY THE LD. CIT(A). 1.REJECTION OF BOOKS OF ACCOUNT: THE LD A.O. REJECTED BOOKS OF ACCOUNTS BY RESORT TO SECTION 145(3) OF THE INCOME TAX ACT 1961ONLY ON THE GROUND THAT THE ASSESSEE HAS NO T MAINTAINED THE STOCK REGISTER. IN THIS REGARDS IT IS SUBMITTED THAT THE ASSESSEE HAS ENGAGED IN PRINTING WORK AND IN SUCH TRADE IT IS NOT POSSIBLE TO MAINTAIN ITEMWISE STOCK REGISTER AT THE LEVEL OF BUSINESS OF THE ASSESSEE, HOWEVER THE ASSESSEE MAINTAIN FULL IN TERNAL CONTROL OVER DAY TO DAY MATERIAL RECEIPT AND ISSUE BY WAY OF KEEPING MATERI AL RECEIPT AND ISSUE REGISTER MAINTAINED AT THE GATE OF PRESS AND ALL THE ENTRIES IN GATE REGISTER IS VERIFIABLE FROM THE ACCOUNTS. THE ASSESSEE HAS ALSO MAINTAINED FULL DET AILS OF OPENING AND CLOSING STOCK WITH VALUE OF EACH ITEM WHICH IS AS PER ACTUAL PHYS ICAL STOCK AT THE END OF THE YEAR TAKEN BY THE MANAGEMENT AND SUBMITTED DURING COURSE OF HEARING(PB 41-63 ). AS PER SAID DETAILS THE STOCK IS FULLY VERIFIABLE.THE VALU ATION OF STOCK ARE AT COST OR MARKET PRICE WHICHEVER IS LOWER WHICH IS ALSO VERIFIABLE F ROM THE BOOKS OF ACCOUNTS OF THE FIRM. IT IS ADMITTED FACT THAT THE ASSESSEE MAINTAIN REGU LAR BOOKS OF ACCOUNTS CONSISTING OF CASH BOOK, LEDGER,JOURNAL, SALE AND PURCHASES REGI STER, MATERIAL RECEIPT AND ISSUE REGISTER WHICH HAS BEEN PRODUCED DURING COURSE OF ASSESSMENT PROCEEDING AND NO DEFECT FOUND DURING COURSE OF EXAMINATION OF SUCH B OOKS. THE ACCOUNTS OF ASSESSEE PRODUCED WERE DULY AUDITED BY INDEPENDENT CHARTERED ACCOUNTNAT (PB 4-40). AS SUCH THE RESULTS DERIVED FROM BOOKS OF ACCOUNT MAIN TAINED BY THE ASSESSEE ARE FULLY VERIFYABLE AND NO QUESTION OF APPLYING SECTION 145 OF INCOME TAX ACT ARISES. IT IS SUBMITTED THAT MERE ABSENCE A STOCK REGISTE R CANNOT BE BASIS FOR FRAMING ASSESSMENT UNDER SECTION 144 / 145 OF THE ACT. THIS WOULD BE PARTICULARLY SO WHEN THE APPELLANT EXPLAINED THAT PREPARATION / MAINTENANCE OF QUANTITATIVE DETAILS OF CONSUMPTION IS NOT PRACTICALLY FEASIBLE. FOR THIS P ROPOSITION, WE RELIED UPON THE DECISION OF THE FOLLOWING JUDICIAL DECISIONS : (I) ASHOKA REFRACTORIES (P) LTD. V CIT [2005] 148 T AXMAN 635 ( CAL.) WHERE IT WAS HELD THAT IN THE ABSENCE OF STOCK REGISTER OR FAIL URE TO MAINTAIN ITEM WISE STOCK IN STOCK REGISTER, BOOKS OF ACCOUNTS OF ASSESSEE COULD NOT B E REJECTED UNLESS THERE WAS FINDING OR OPINION EITHER THAT RECORD WERE INCURRED AND INCOMP LETE OR THAT METHOD OF ACCOUNT APPLIED WAS SUCH THAT INCOME COULD NOT BE DEDUCED FROM ACCOUNTS MAINTAINED BY ASSESSEE. (II) C.I.T. VS. SHERE PUNJAB SILK STORES 1981 TAX 63(1)-DELHI HC (III) VEERIAH REDDIAR VS. C.I.T . : 38 ITR 52 (KER.) (III) BHAGWATI EMPORIUM VS. ITO (1995) 80 TAXMAN 227 (AHD.) ; ITA NO. 226/JP/2016 M/S. POPULAR PRINTERS VS. ITO, WARD- 5 (2), JAIPUR . 6 (IV) KABIR LEATHERS VS.ADDL . C.I.T. 27 SOT 498 (DELHI) (V) C.I.T. VS. JAS JACK ELEGANCE EXPORTS 324 ITR 95(DELHI HC) (VI) C.I.T. VS. JACKSONS HOUSE : 198 TAXMAN 385(DELHI HC) (VII) ITAT CHENNAI BENCH DIN THE CASE ACIT VS HEERAL CO NSTRUCTION PVT LTD REPORTED IN TAXMAN PAGE 848 VOL-4 (2004). (VIII) ITAT JAIPUR BENCH IN THE CASE OF ANTIQUARIAT VS AC IT (ITA NO. 220/JP/2005 (TAXWORD VOL XXXVII PAGE 145) FROM THE ABOVE FACTS, IT IS CLEAR THAT THERE IS NO DEFECTS IN BOOKS OF ACCOUNT TO VERIFY THE TRADING RESULTS THEREFORE ACCOUNTS BOO KS OF ASSESSEE CAN NOT BE REJECTED. 2. TRADING ADDITION: WITHOUT PREJUDICE TO ABOVE, WE FURTHER SUBMIT THAT EVEN THE BOOKS OF ACCOUNTS REJECTED BY THE LD A.O, HE IS FURTHER WRON G, UNJUSTIFIED AND BAD IN LAW IN MAKING ADHOC TRADING ADDITION RS 250000/- ARBIT RARILY. AS AGAINST ACTION OF A.O, WE SUBMIT AS UNDER: 2.1 THE APPELLANT DECLARED BOOK RESULTS WHICH ARE FULLY VERIFIABLE FROM THE RECORD MAINTAINED AND AS PER AUDITED ACCOUNT SUBMIT TED. 2.2 IN THE RELEVANT PERIOD THE TURNOVER IS APPROXIM ATELY SAME WITH THE INCREASING GP FROM THE LAST YEAR. REDUCTION IN GP W AS ONLY AS COMPARED TO A.Y 2008-09 TWO YEAR BACK WHICH WAS ALSO DULY JUSTI FIED AS UNDER: - WE ARE ENGAGED IN PRINTING & SUPPLYING OF VARIOUS K IND OF PRINTED MATERIAL LIKE DAIRIES, BOOKS, PAMPHLETS, POSTERS ETC. THE IN DUSTRY STARTED IN TOUGH COMPETITION SINCE F.Y 2008-08SPECIALLY BECAUSE OF A DDITION OF NEWER & NEWER PRINTING TECHNOLOGY REQUIRING LESS HUMAN INTE RFACE WITH GREATER EFFICIENCY. - THAT THE COST OF PRODUCTION ARE ALSO INCREASING YE AR BY YEAR DUE TO NOT HAVING NEWER TECHNOLOGY AND RUNNING THE PRESS ON OL D & INEFFICIENT MACHINERIES WHICH ARE LABOUR INTENSIVE REQUIRING, M ORE WORK POWER THUS REDUCING THE GROSS PROFIT. - THERE WAS SIGNIFICANT INCREASE IN SALE DURING IN C OMPARISON TO AY 2008- 09 WHICH IS POSSIBLE DUE TO CHANGE IN PROPORTION OF NATURE OF WORK/SALE AND FORCED TO REDUCED IN MARGIN. HOWEVER THERE IS I NCREASE IN TOTAL GROSS PROFIT AND NET PROFIT WHICH MAY KINDLY BE APPRECIAT ED. - THAT IN THE VAT EXEMPTED SALES HAVE INCREASED SIGNI FICANTLY DURING THE YEAR FROM RS. 3,39,57,219/- IN THE A.Y. 2008-09 TO RS. 8,15,97,224 IN THE A.Y. 2009-10 AND SAME IN A.Y 2010-11. WE WOULD LIKE TO BRING TO YOUR NOTICE THAT EXEMPTED SALES RELATES TO PRINTING OF M ATERIAL WHICH IS OF NATURE OF BOOKS I.E. ON BOUND FORM E.G. BOOKS, SCHOOL DIAR IES ETC. IN SUCH KIND OF SUPPLY WE COULD NOT GET GOOD MARGIN SPECIALLY BECAU SE THESE MATERIAL REQUIRE USE OF HUGE QUANTITY OF PAPERS AND ALSO REQ UIRE INCURRING OF OTHER ITA NO. 226/JP/2016 M/S. POPULAR PRINTERS VS. ITO, WARD- 5 (2), JAIPUR . 7 SUBSTANTIAL DIRECT EXPENSES LIKE BINDING, LAMINATIO N ETC. HENCE, MORE THE EXEMPTED SALES, LESS IS G.P. RATE. - THAT THE APPELLANT IS IN THE PANEL OF PRINTERS MAIN TAINED BY DIRECTOR OF PUBLIC RELATION, GOVT. OF RAJASTHAN (DIPR). FOR BEI NG IN PANEL, WE HAVE TO WORK WITH VERY LOW MARGIN. SINCE YEAR RELATED TO A. Y. 2009-10 AND ONWARD OUR SALES IN RELATION TO DPIR INCREASED SIG NIFICANTLY. THIS HAS AFFECTED OUR GP RATE SUBSTANTIALLY. 2.3. THE LD. A.O. REFERRED TO THE CASE OF S.N. NAMA SWERY CHETTIYAR VS CIT (1960) ITR 579 AND THE LD. A.O. REFERRED TO THE CAS E OF CIT VS BRITISH PAINTS INDIA LTD. 188 ITR 44 IS NOT APPLICABLE TO OUR CAS E AS IN THE SAID CASE AS THE FACTS AND SITUATION IN THIS CASE ARE DIFFERENT FROM THAT OF THIS CASE. THE GIVEN CASE RELATES TO THE PRINCIPLE OF VALUATION OF STOCK AND THE SAME IS NOT IN OUR CASE. AS SUBMITTED ABOVE FACTS THE GROSS PROFIT DECLARED BY THE APPELLANT IS MOST REASONABLE AND AT THE LEVEL OF BUSINESS IN THE RELE VANT ASSESSMENT YEAR AND AND ALSO COMPARABLE FROM THE LAST ASSESSMENT YEAR AT TH E SAME LEVEL OF BUSINESS. THE A.O. IS NOT JUSTIFIED IN MAKING FURTHER ADDITI ON TO DECLARED PROFIT ARBITRARILY. LOOKING TO ABOVE FACTS, THERE IS NO JUSTIFICATION O F TRADING ADDITION MADE BY LD A.O THEREFORE YOUR HONOR IS REQUESTED TO KINDLY DELETE SUCH TRADING ADDITION MADE. 2.4 THE LD. DR RELIED ON THE ORDERS OF THE LOWER AU THORITIES 2.5 I HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. IT IS NOTED THAT THE AO MADE O N ACCOUNT OF INVOKING PROVISIONS OF SECTION 145(3) OF THE ACT AFTER REJEC TING THE BOOKS OF ACCOUNT AND ESTIMATED THE TRADING ADDITION OF RS. 2 .50 LACS . THE AO ALSO MADE DISALLOWANCES OF VARIOUS EXPENSE LIKE CAR EXPE NSES, INSURANCE OF CAR, INTEREST ON CAR LOANS, DEPRECIATION ON CAR, TR AVELING EXPENSES, CONVEYANCE EXPENSES, BUSINESS PROMOTION EXPENSES, S TAFF TEA & BEVERAGE EXPENSES, GENERAL EXPENSES, OTHER REPAIR EXPENSES, POOJAN EXPENSES AND TELEPHONE EXPENSES FOR WHICH THE ASSESSEE IS NOT IN APPEAL. IT IS OBSERVED THAT ONCE THE ADDITIONS ARE MADE FROM SPECIFIC EXPE NSES DEBITED IN THE ITA NO. 226/JP/2016 M/S. POPULAR PRINTERS VS. ITO, WARD- 5 (2), JAIPUR . 8 PROFIT AND LOSS ACCOUNT AND THE SAME WAS SUSTAINED BY THE LD. CIT(A) THEN IN MY VIEW THE ESTIMATED TRADING ADDITION IN A DDITION TO SUCH DISALLOWANCES WAS NOT JUSTIFIED. HENCE, THE ADDITIO N CONFIRMED BY THE LD. CIT(A) IS DELETED. THUS THE SOLITARY GROUND OF THE ASSESSEE IS ALLOWED. 3.0 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS AL LOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 25 /07/ 2016 SD/- HKKXPUN ( BHAGCHAND) YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 25 /07/ 2016 *MISHRA VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- M/S. POPULAR PRINTERS, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- THE ITO, WARD- 5 (2), 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. 226/JP/2016) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ @ ASSISTANT. REGISTRAR