Appeal details
Counselvise Citation
32124914 RSA 2011
Assessee PAN
Bench
Appeal Number
Duration Of Justice
2 year(s) 26 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
13-09-2013
Appeal Filed By
Assessee
Order Result
Dismissed
Bench Allotted
DB
Next Hearing Date
10-09-2013
Assessment Year
2006-2007
Appeal Filed On
18-08-2011
Judgement Text
3 , IN THE INCOME TAX APPELLATE TRIBULAL; RAJKOT BENCH, RAJKOT. R 3 . . R . . R BEFORE SHRI T. K. SHARMA JM AND SHRI D. K. SRIVASTAVA AM IT A NO. 3 21 /RJT/2011 . R R / ASSESSMENT YEAR 200 6 - 0 7 . M/S. KUNAL DEVELOPERS, C/O. NITIN KAMDAR & CO. (CA), II FLOOR, SATYAM BUILDING OPP: LAKHAJIRAJ LIBRARY LAKHAJIRAJ ROAD, RAJKOT - 360001. PAN : A A HF K 7226K ( A / APPELLANT) T HE INCOME TAX OFFICER, WARD - 1(4), RAJKOT. B(A / RESPONDENT REI / ASSESSEE BY . SHRI D. M. RINDANI, CA I / REVENUE BY SHRI DR. JAYANT B. JHAVERI , DR I / DATE OF HEARING 1 0 - 0 9 - 2013 I /DATE OF PRONOUNCEMENT 13 - 0 9 - 2013 / ORDER 3 . . , / T. K. SHARMA, J. M. : TH IS APPEAL BY THE ASSESSEE IS AGAINST THE ORDER DATED 21 - 02 - 2011 OF LD. CIT (A) - I, RAJKOT FOR THE ASSESSMENT YEAR 200 6 - 07. 2. T HE FACTS , IN BRIEF, ARE THAT TH E ASSESSEE IS A FIRM ENGAGED IN THE BUSINESS OF DEV ELOPER. FOR THE ASSESSMENT YEAR UNDER APPEAL, IT FILED THE RETURN OF INCOME ON 11 - 08 - 2006 DECLAR ING TOTAL INCOME AT RS. NIL . AO FRAMED THE ASSESSMENT U/S.143(3) OF THE I.T. ACT ON 27 - 12 - 2008 WHEREIN HE MAD E ADDITION OF RS.6,80,500/ - ON ACCOUNT OF ESTIMATION OF EXCESS VALUE OF PURCHASE OF LAND PLOTS BASED ON REPORT OF DVO. ON APPEAL BEFORE LD. CIT (A), ASSESSEE CONTENDED THAT THEY HAD PURCHASED PLOT NOS.1 TO 30 ADMEASURING 16627.99 SQ. MT. ONLY AND REMAINING AREA WITH LOADING, UNLOADING AND PARKING ADMEASURING TO 1773.92 SQ. MT. AND INTERNAL ROADS ADMEASURING TO 4369.38 SQ. MT. WERE NOT PURCHASED BY THEM. THE DEPARTMENTAL VALUATION OFFICER HAS VALUED AGGREGATE LAND OF 23472 SQ. MT. AT RS.20,89,000/ - . EXCLUDIN G THE COMMON AREA OUR COST IS HIGHER THAN VALUATION MADE BY DVO. AFTER CONSIDERING THESE CONTENTIONS OF THE ASSESSEE, LD. ITA 3 21 - 201 1 2 CIT (A) UPHELD THE ACTION OF AO FOR THE DETAILED REASON GIVEN IN PARA - 5 OF THE IMPUGNED ORDER WHICH READS AS UNDER: - 5. I HAVE CAREF ULLY CONSIDERED THE ISSUE, IT IS SEEN THAT THE APPELLANT HAS PURCHASED OPEN LAND AT SURVEY NO.76 KHATA NO.20 INDUSTRIAL PLOT NO.1 TO 30 ADMEASURING 17328.70 SQ. MT., LOADING, UNLOADING AND PARKING AREA 1+2+3 ADMEASURING 1773.92 SQ. MT AND INTERNAL ROADS AD MEASURING 4369.38 SQ. MT. TOTALING TO 23472 SQ. MT. FOR A CONSIDERATION OF RS.14,08,500 AS PER REGISTERED SALE DEED WHICH IS PLACED ON RECORD. ON PERUSAL OF REGISTERED SALE DEED, IT IS AMPLY CLEAR THAT THE APPELLANT HAS PURCHASED 23472 SQ. MT OF LAND INCLU DING PLOT NO.1 TO 30, LOADING, UNLOADING, PARKING AREA AND INTERNAL ROADS. HENCE THE CONTENTION OF THE APPELLANT THAT THEY HAVE ONLY PURCHASED INDUSTRIAL PLOT NO.1 TO 30 ADMEASURING 17328.70 SQ. MT IS FACTUALLY WRONG, HENCE ARGUMENT BASED ON WRONG AND UNFO UNDED FACTS IS FUTILE. THE DVO HAS CORRECTLY CONSIDERED AREA OF LAND AT 23472 SQ. MT AND MADE VALUATION. CONSIDERING FACTUAL POSITION THE ADDITION MADE BY THE ASSESSING OFFICER BASED ON VALUATION OF DEPARTMENTAL VALUATION OFFICER IS HEREBY CONFIRMED. AGGRIEVED WITH THE ORDER OF LD. CIT (A), THE ASSESSEE IS IN APPEAL BEFORE THE TRIBUNAL ON THE FOLLOWING GROUND: - THE LEARNED CIT (A) - I, RAJKOT IN FOR NOT JUSTIFYING THE MATTER OF LAW IN CONFIRMING THE ADDITION OF RS.680500/ - . 3. AT THE TIME OF HEARING BE FORE US, ON BEHALF OF ASSESSEE SHRI D. M. RINDANI, CA APPEARED AND POINTED OUT THAT THERE IS A DELAY OF 98 DAYS IN FILING OF THIS APPEAL WHICH TOOK PLACE DUE TO ILLNESS OF ASSESSEES UNCLE NAMELY MR. NANUMAL BHORWANI WHO WAS UNDERGOING AYURVEDIC TREATMENT FOR CANCER. THE COUNSEL OF THE ASSESSEE FURTHER CLARIFIED THAT THOUGH THE REGISTRY HAS MENTIONED AS 849 DAYS IN THE DEFECT NOTICE BUT IN FACT, THE DELAY IS 98 DAYS ONLY BECAUSE WHILE FILING THE MEMO OF APPEAL, THE DATE OF RECEIPT OF ORDER OF LD. CIT (A) WA S INCORRECTLY STATED AS 20 - 02 - 2009 WHEREAS THE CORRECT DATE ON WHICH THE ORDER OF LD. CIT (A) WAS RECEIVED IS 11 - 03 - 2011 . THE COUNSEL OF THE ASSESSEE PLEASED THAT SINCE THE ASSESSEE WAS PREVENTED BY SUFFICIENT CAUSE IN FILING THE APPEAL IN TIME, THEREFORE SMALL DELAY OF 98 DAYS BE CONDONED AND THE APPEAL OF THE ASSESSEE BE ADMITTED. ON THE CONDONATION PLEA, LD. DR POINTED OUT THAT SAME MAY BE DECIDED ON MERIT KEEPING IN VIEW THE CONTENTS/AVERMENTS MADE IN AFFIDAVIT FILED BY THE ASSESSEE FOR CONDONATION OF DELAY. 4. AFTER HEARING BOTH SIDES ON CONDONATION, WE ARE SATISFIED THAT DELAY HAS OCCURRED DUE TO ILLNESS OF UNCLE OF ASSESSEE NAMELY NANUMAL BHORWANI. WE ITA 3 21 - 201 1 3 THEREFORE CONDONE THE DELAY OF 98 DAYS AND APPEAL OF THE ASSESSEE IS ADMITTED. THE COUNSEL OF THE ASSESSEE POINTED OUT THAT ASSESSEE HAS FILED A PRAYER FOR ADMISS ION OF ADDITIONAL EVIDENCE UNDER RULE 29 OF APPELLATE TRIBUNAL RULES, 1963 WHICH READS AS UNDER: - 1. THE APPELLANT ABOVENAMED MOST RESPECTFULLY PRAYS BEFORE THE HONBLE TRIBUNAL THAT IT HAS F ILED A COMPILATION OF DOCUMENTS ON 17 - 7 - 2013 WHICH COMPRISES DOCUMENTS IN THE NATURE OF EVIDENCE THAT COULD NOT BE PRODUCED BEFORE THE LOWER AUTHORITIES. 2. THE APPELLANT STATES THAT THE DOCUMENT AT SR. NO. 1 IS AN ORDER OF THE DY. COLLECTOR RAJKOT DATED 19 - 4 - 2010. IT COULD NOT BE PRODUCED BEFORE THE ASSESSING OFFICER BECAUSE THE SAID ORDER WAS PASSED MUCH AFTER THE DATE OF ASSESSMENT ORDER. THE SAID ORDER WAS HOWEVER FILED BEFORE THE FIRST APPELLATE AUTHORITY. THE APPELLANT SUBMITS THAT THE SAID ORDER IS BY WAY OF LATER AFFIRMATION OF THE PLEA ALREADY ADVANCE BY THE APPELLANT BEFORE BOTH THE LOWER AUTHORITIES TO THE EFFECT THAT THE AREA OF OPEN SPACE AND INTERNAL ROADS OF THE LAND SCHEME WERE WRONGLY MENTIONED IN THE ORIGINAL PURCHASE DEED AS SALE OF SUCH AREA. THE ORDER OF DY. COLLECTOR ONLY CONFIRMS THE SAME AND HENCE THE SAME MAY KINDLY BE TREATED AS IN SUPPORT OF THE CONTENTION OF THE APPELLANT, AND AS SUCH STRICTLY SPEAKING IT DOES NOT CONSTITUTE FRESH EVIDENCE. 3. THE DOCUMENT AT SR. NO.2 OF THE COMP ILATION IS A DEED OF CORRECTION OF PURCHASE DEED OF THE LAND, DATED 1 - 12 - 2009, EXECUTED BY THE SELLERS OF THE LAND PLOTS IN FAVOUR OF THE PURCHASER (BEING THE APPELLANT HERE). THIS DOCUMENT WAS EXECUTED BY THE SELLERS AFTER THE DATE OF ASSESSMENT AND HENCE IT COULD NOT BE PRODUCED DURING ASSESSMENT PROCEEDINGS. IT WAS PRODUCED DURING FIRST APPEAL PROCEEDINGS. THE SAID DOCUMENT IS ALSO BY WAY OF CORRECTION TO THE PURCHASE DEED IN RESPECT OF THE AREA OF LAND AND HENCE IT MAY BE CONSIDERED ON SAME LINES AS THE DOCUMENT MENTIONED IN 2 ABOVE. 4. THE DOCUMENT AT SR. NO.3 OF THE COMPILATION IS THE CORRECTED COPY OF RECORD OF RIGHT ISSUED BY THE COMPETENT AUTHORITY, WHEREBY THE CORRECTED AREA HAS BEEN NOTED ON THE BASIS OF ORDER DATED 19 - 4 - 2010 REFERRED TO IN SR. N O.2 ABOVE. 5. ON MERIT, RELYING ON THE AFORESAID ADDITIONAL EVIDENCE, COUNSEL OF THE ASSESSEE SUBMITTED THAT ADDITION OF RS.6,80,500/ - WHICH IS SUSTAINED BY LD. CIT (A) BY WAY OF EXCESS VALUE OF PURCHASE OF LAND PLOTS BASED ON REPORT OF DVO BE DELETED I N VIEW OF FOLLOWING SUBMISSION: - THE ONLY GROUND OF APPEAL IS IN RESPECT OF ADDITION OF RS.6,80,500/ - SUSTAINED BY THE C.I.T. (APPEALS) BY WAY OF EXCESS VALUE OF PURCHASE OF LAND PLOTS BASED ON REPORT OF DVO. 1. THE APPELLANT PURCHASED NON - AGRICULTURAL LAND IN METODA VILLAGE REVENUE SURVEY NO.76 VIDE DEED OF CONVEYANCE DATED 7 - 9 - 2005 SHOWING PURCHASE PRICE OF RS.14,08,500/ - . THE TOTAL LAND AREA SHOWN IN THE DEED WAS 23472 SQ. MTRS. WHICH INCLUDED MANDATORY OPEN PLOT AREA AND INTERNAL ROADS OF 6144 SQ. MT RS. HENCE, THE NET SALABLE AREA WAS 17328 S1. MTRS. MENTIONED IN THE DEED OF CONVEYANCE. 2. THE A.O. REFERRED THE VALUATION TO D.V.O. WHO HAS VALUED THE GROSS LAND AREA OF 23472 SQ. MTRS. @ RS.89/ - PER SQ. MTR. AT RS.20,89,000/ - . THUS, THE ITA 3 21 - 201 1 4 DIFFERENCE OF RS.6,80,500/ - HAS BEEN ADDED AS UNDISCLOSED INVESTMENT. DURING ASSESSMENT, THE APPELLANT OBJECTED TO THE D.V.O. AND ALSO FILED LETTERS OF EXPLANATION. EXPERT OPINION OF ADVOCATE REGARDING COMMON PLOT AREA WAS ALSO SUBMITTED. 3. THE C.I.T. (A) HAS SUSTAIN ED THE ADDITION BASED ON REPORT OF D.V.O. ON THE GROUND THAT THE APPELLANT PURCHASED 23472 SQ. MTRS. OF LAND INCLUDING OPEN AREAS. 4. THE APPELLANT SUBMITS AS UNDER: - ( I ) ALTHOUGH THE DEED OF PURCHASE REFERS TO GROSS AREA OF 23472 SQ. MTRS., THE DEED ITSEL F MENTIONS THAT THE SALE IS SUBJECT TO CONDITIONS OF ORDER CONVERTING THE LAND TO NON - AGRICULTURE AND THE DEED ALSO MENTIONS THE NET AREA OF 17328 SQ. MTRS. ( II ) THE NON - AGRICULTURE ORDER READ WITH GOVT. OF GUJARAT REVENUE DEPT. RESOLUTION CLEAR STIPULATE THAT OPEN LAND CANNOT BE UTILIZED FOR ANY OTHER PURPOSE AND THAT THE LAND FOR INTERNAL ROADS AS PER PLAN SHALL BE KEPT OPEN WITHOUT CHARGING ANY COMPENSATION FOR THE SAME. ( III ) THE GOVT. RESOLUTION MANDATES THAT COMMON PLOT ON INTERNAL ROADS SHALL BELONGS TO THE S OCIETY OR TO ALL PLOTS HOLDERS AND ORIGINAL OWNER SHALL NOT HAVE ANY RIGHTS THEREIN; NO PERMISSION FOR CONSTRUCTION ON COMMON PLOT SHALL BE GIVEN; LAND OF THE ROADS AND COMMON PLOT SHALL NOT BE TRANSFERRED OR SOLD. ( IV ) THE ABOVE RESTRICTIONS REGARDING THE OPE N AREAS AND ROADS WERE CLEARLY INFORMED TO THE D.V.O. VIDE LETTER DATED 24 - 12 - 2008 AND ALSO INFORMED TO THE A.O. ( V ) AS STATED IN THE PAPERBOOK OF ADDITIONAL EVIDENCE, THE ORIGINAL DEED OF CONVEYANCE DATED 7 - 9 - 2005 HAS BEEN SUBSEQUENTLY RECTIFIED BY THE ORIGI NAL SELLERS FROM WHOM THE APPELLANT PURCHASED THE LAND AND IF SUCH CORRECTION DEED THE ACTUAL SALEABLE AREA HAS BEEN CORRECTED TO 17328 SQ. MTRS. OF NET LAND AT THE SAME PRICE OF RS.14,08,500/ - , AFTER RECORDING THE REASONS FOR THE SAID CORRECTION. ( VI ) THEREAF TER, THE DY. COLLECTOR, RAJKOT VIDE ORDER DATED 19 - 4 - 2010 HAS PASSED AN ORDER ACCEPTING THE AFORESAID CORRECTION DEED FOR THE NET LAND AREA BECAUSE THE EARLIER/ORIGINAL DEED OF CONVEYANCE WAS REJECTED BY THE AUTHORITY FOR THE PURPOSE OF MUTATING THE NAME O F THE APPELLANT AND DETAILS OF LAND IN THE REVENUE RECORDS. ( VII ) FINALLY, IN THE RECORD OF RIGHTS, THE ENTRY FOR ONLY 16,627 SQ. MTRS. IS MADE BY AUTHORITY, SHOWING THAT THE APPELLANT GOT POSSESSION AND RIGHTS OVER ONLY 16,627 SQ. MTRS. ( VIII ) NOW THAT THE REVISED L AND AREA WHICH WAS TRANSFERABLE HAS BEEN ACCEPTED BY COMPETENT AUTHORITY, THE ORIGINAL PURCHASE PRICE DESERVES TO BE ACCEPTED, PARTICULARLY IN ABSENCE OF ANY EVIDENCE SHOWN BY THE A.O. WITH REGARD TO ANY UNDISCLOSED CONSIDERATION HAVING BEEN PAID. ( IX ) ON MERI TS OF VALUATION, THE REPORT OF D.V.O. DOES NOT PERTAIN TO COMPARABLE SALE INSTANCES OF THE SAME SURVEY NO. AND HENCE THE INSTANCES CITED CANNOT BE SAID TO BE COMPARABLE TO DETERMINE THE FAIR MARKET VALUE. ( X ) WITHOUT PREJUDICE TO ABOVE, IT IS SUBMITTED THAT E VEN IF THE RATE OF RS.89/ - ESTIMATED BY THE D.V.O. IS TO BE ADOPTED, THE SAME SHOULD APPLY TO NET LAND AREA OF 16,627 SQ. MTRS. IN POSSESSION AND NOT TO GROSS AREA OF 23472 SQ. MTRS. FOR REASONS STATED ABOVE. THIS WOULD TRANSLATE INTO VALUE ITA 3 21 - 201 1 5 OF RS.14,79,892 / - AS AGAINST RS.14,08,500/ - DISCLOSED, GIVING RISE TO VALUE DIFFERENCE OF RS.71,392/ - AT BEST AS AGAINST RS.6,80,500/ - ADDED. 6 . ON THE OTHER HAND, DR. JAYANT B. JHAVERI, DR APPEARED FOR THE REVENUE VEHEMENTLY SUPPORTED THE ORDER OF LD. CIT (A). THE LD. DR POINTED OUT THAT THOUGH THE JANTRI PRICE IS @ 100/ - SQ. MTR S . BUT THE AO APPLIED THE LOWER RATE I.E.@ 89/ - PER SQ. MTR S . O N THE BASIS OF DVO REPORT. THE ASSESSEE FIRM HAS PURCHASED THE ENTIRE DEVELOPED AREA ADMEASURING 17328 SQ. MTRS., LOADING, UNLOA DING AND PARKING AREA 1+2+3 ADMEASURING 1773.92 SQ. MTRS. AND INTERNAL LOAD ADMEASURING 4369.38 SQ. MTRS. TOTALING TO 23472 SQ. MTRS. THEREFORE THE PLEA OF THE ASSESSEE TO EXCLUDE LOADING, UNLOADING, PARKING, INTERNAL ROADS ETC. IS NOT ACCEPTABLE. IN THIS REGARD, LD. DR DREW OUR ATTENTION TO VALUATION REPORT DATED 22 - 12 - 2008 OF ER. ANAND SINGH, VALUATION OFFICER, INCOME TAX DEPARTMENT, RAJKOT (HEREINAFTER KNOWN AS DVO) WHO IN PARA - 11.0 CONSIDERED THE ASSESSEES RELEVANT POINTS/OBJECTIONS RAISED IN HIS LET TER DATED 10 - 12 - 2008 FILED BEFORE THE AO REGARDING SO - CALLED FREE AREA OF 6143.30 SQ. MT. FOR LOADING, UNLOADING AND PARKING SPACE AND INTERNAL ROADS AND THEREAFTER DVO HAS OBSERVED AS UNDER: - TRANSFEROR SHRI SAVJIBHAI VALJIBHAI BHALODIYA HAS SOLD AND TH E PURCHASE M/S. KUNAL DEVELOPER REPRESENTED BY SHRI SAURABH KIRANBHAI SHAH (ASSESSEE) HAS PURCHASED THE CONCRETE PARCEL OF LAND ADMEASURING 5 ACRES - 32 GUNTHAS (23473 SQM.). THE WHOLE LAND IS DIVIDED IN 30 NO PLOTS LEAVING NECESSARY ROAD AND SPACE FOR LOADI NG, UNLOADING AND PARTKING AS PER DEVELOPMENT PLAN. THE AREA OF 6143.30 SQM FOR ROAD AND LOADING, UNLOADING AND PARKING SPACE IS FREE AND NOT PURCHASED BY HIM IS NOT ONLY UNCONVINCING BUT RIDICULOUS TOO. IN FACT THE COST OF 6143.30 SQM AREA OF ROADS, LOAD ING, UNLOADING AND PARKING SPACE WILL BE PROPORTIONATELY SHARED BY RETAIL PURCHASER OF EACH PLOT OUT OF TOTAL 30 PLOTS TO BE DEVELOPED FROM TOTAL LAND MEASURING 23472 SQM. ALL THE FACTORS LIKE SALE INSTANCES IN THE SAME/NEARBY AREA, SPACE REQUIRED FOR ROA DS, LOADING, UNLOADING AND PARKING ETC., SIZE, SHAPE, LOCATION AND SITUATION, UTILITY, RELATIVE DEVELOPMENT EXPENDITURE REQUIRED ETC. HAS DULY BEEN CONSIDERED AND FAIR MARKET VALUE HAS BEEN FIXED ACCORDINGLY. 7. THE LD. DR POINTED OUT THAT PLEA NOW RAIS ED IS DULY REJECTED BY THE DVO PARA - 11.0 OF HIS VALUATION REPORT THEREFORE, THE LD. CIT (A) IS LEGALLY AND FACTUALLY CORRECT IN HOLDING THAT LOADING, UNLOADING AND PARKING SPACE AND INTERNAL ROADS CANNOT BE EXCLUDED FOR THE PURPOSE OF VALUATION. THE LD. DR CONCLUDED THAT ITA 3 21 - 201 1 6 DVO VALUED THE LAND IN QUESTION @ 89 PER SQ. MT. AS AGAINST JANTRI RATE WHICH 100 PER SQ. MT. THEREFORE VIEW TAKEN BY LD. CIT (A) BE UPHELD. 8 . AFTER HEARING BOTH SIDES, WE HAVE CAREFULLY GONE THROUGH THE ORDER OF AUTHORITIES BELOW. THE PL EA OF LD. COUNSEL OF THE ASSESSEE THAT LOADING, UNLOADING AND PARKING AREA SHOULD BE EXCLUDED CANNOT BE ACCEPTED AS THE PLOT NO.1 TO 30 CANNOT BE ENJOYED WITHOUT LOADING, UNLOADING AND PARKING AREA. THIS PLEA WAS DULY CONSIDERED BY DVO IN ITS VALUATION REP ORT AND RIGHTLY REJECTED. IT IS PERTINENT TO NOTE THAT ASSESSEE HAS PURCHASED THE ENTIRE DEVELOPED AREA ON INDUSTRIAL PLOT NO.1 TO 30 ADMEASURING 17328.70 SQ. MT., LOADING, UNLOADING AND PARKING AREA 1+2+3 ADMEASURING 1773.92 SQ. MT. AND INTERNAL ROADS ADM EASURING 4369.38 SQ. MT. TOTALING TO 23472 SQ. MT. FOR A CONSIDERATION OF RS.14,08,500/ - AS PER REGISTERED SALE DEED. IN THIS VIEW OF THE MATTER, WE ARE OF THE VIEW THAT BOTH THE DEPARTMENTAL AUTHORITIES BELOW ARE LEGALLY AND FACTUALLY CORRECT IN MAKING TH E ADDITION/CONFIRMING THE SAME. WE THEREFORE DECLINED TO INTERFERE. 9 . IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DISMISSED. 10 . THIS O RDER IS PRONOUNCED IN OP EN COURT ON THE DATE MENTIONED HEREINABOVE. SD/ - SD/ - ( . . . D. K. SRIVASTAVA ) ( . . R / T. K. SHARMA) / ACCOUNTANT MEMBER / JUDICIAL MEMBER U / ORDER DATE 13 - 0 9 - 2013. /RAJKOT NVA/ - JO O / COPY OF ORDER FORWARDED TO: - 1 . A /APPELLANT - M/S. KUNAL DEVELOPERS, C/O. NITIN KAMDAR & CO. (CA), II ND FLOOR , S ATYAM BUILDING, OPP:LAKHAJIRAJ LIBRARY, LAKHAJIRAJ ROAD, RAJKOT - 360001 . 2 . B(A /RESPONDENT - THE INCOME TAX OFFICER , WARD - 1(4), RAJKO T. 3 . 3 N / CONCERNED CIT - I, RAJKOT . 4 . I, R JKOT - / CIT (A) - I, RAJKOT. 5 . B3 , 3 , / DR, ITAT, RAJKOT 6 . R / GUARD FILE. / BY ORDER TRUE COPY. PRIVATE SECRETARY, ITAT, RAJKOT
