DCIT, Jaipur V. ADVENT INFRAPROJECTS PVT. LTD., Jaipur

ITA 333/JPR/2017

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 1917 (ITAT-JAIPUR)
• Duration Of Justice: 6 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 15-11-2017
• Appeal Filed By: Department
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2015-2016
• Appeal Filed On: 02-05-2017
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: VRINDERA MEHTA
• Assessee Lawyers: D C AGRAWAL
• Keywords: Unexplained investment; Search and seizure; Tangible material; Fair market value; Valuation report
• Section: 131; 132

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 FOT; IKY JKO] U;KF;D LNL; ,OA JH HKKXPAN] YS[KK L NL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM & SHRI BHAGCHAND, A M VK;DJ VIHY LA- @ ITA NO. 333/JP/2017 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2015-16 THE DCIT, CENTRAL CIRCLE-3, JAIPUR. CUKE VS. M/S ADVENT INFRAPROJECTS PVT. LTD., 424-425, GANPATI PLAZA, M.I. ROAD, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AADCA2327C VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI D.C. AGRAWAL (ADV.) JKTLO DH VKSJ LS @ REVENUE BY : SHRI VRINDERA MEHTA (CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 17/10/2017 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT: 15/11/2017 VKNS'K@ ORDER PER: VIJAY PAL RAO, J.M. THIS APPEAL BY THE REVENUE IS DIRECTED AGAINST THE ORDER DATED 27.03.2017 OF CIT (A) FOR THE A.Y. 2015-16.THE REVE NUE HAS RAISED THE FOLLOWING GROUNDS AS UNDER:- 1 WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE CIT(A) WAS RIGHT IN DELETING THE ADDITION OF RS. 4, 66,00,000/- MADE BY A.O. ON ACCOUNT OF UNACCOUNTED INVESTMENT U /S 69B OF THE INCOME TAX ACT, 1961. ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 2 THE APPELLANT CRAVE, LEAVE OR RESERVES THE RIGHT TO AMEND MODIFY, ALTER ADD OR FOREGO ANY GROUND(S) OF APPEAL AT ANY TIME BEFORE OR DURING THE HEARING OF THIS APPEAL. 2. THERE WAS A SEARCH U/S 132 OF THE ACT ON 17.12.2 014 IN THE CASE OF ADVENTAGE GROUP, JAIPUR. DURING THE SEARCH PROCE EDINGS APART FROM OTHER DOCUMENTS TWO AGREEMENTS WERE FOUND FROM THE BUSINESS PREMISES OF THE ASSESSEE CONCERN AT 424-425, GANPA TI PLAZA, MI ROAD, JAIPUR. THESE AGREEMENTS WERE SEIZED AND MARKED AS EXHIBIT-24 OF ANNEXURE A. THE AO NOTED THAT AS PER THESE AGREEME NTS DATED 28.03.2013, TWO PLOTS SITUATED AT 201 AND 202 GIRNA R COLONY, GANDHI PATH, JAIPUR WERE TO BE SOLD BY SH. KAILASH CHAND S HARMA AND SMT. URMILA SHARMA TO SH. MANPREET VISHNOI AND MS SABIA VISHNOI FOR CONSIDERATION OF RS. 3,82,50,000/- AND RS. 2,97,50, 000/- RESPECTIVELY. BOTH THE AGREEMENTS HAVE BEEN DULY SIGNED BY THE BO TH PARTIES. THESE AGREEMENTS WERE CANCELLED VIDE AGREEMENT DATED 06.0 6.2013. SUBSEQUENTLY, THESE TWO PLOTS OF LAND NO. 201 & 202 WERE SOLD TO SH. ARUN GOYAL IN THE MONTH OF AUGUST AND OCTOBER 2013 FOR A CONSIDERATION OF RS. 97.25 LAKHS & RS. 76.50 LAKHS RESPECTIVELY. THE AO WAS OF THE VIEW THAT THE FAIR MARKET PRICE/ VALUE O F THESE PLOTS WERE RS. 3,82,50,000/- AND RS. 2,97,50,000/- RESPECTIVELY AS IT WAS MENTIONED IN THE EARLIER AGREEMENTS TO SELL. THE AO FURTHER NOTE D THAT THE ASSESSEE ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 3 PURCHASED BOTH THESE PROPERTIES FROM SH. ARUN GOYAL ON 07.05.2014 FOR CONSIDERATION OF RS. 1,20,37,500/- AND RS. 93,6 2,500/- RESPECTIVELY. THE AO NOTED THE CHAIN OF EVENT REVEALED FROM OF AGREEMENT TO SELL, CANCELLATION OF THE ORIGINAL AGREEMENT TO SELL BETW EEN SH. KAILASH CHAND SHARMA AND SMT. URMILA SHARMA AND SH. MANPREET VIS HNOI AND MS SABIA VISHNOI AND THEREAFTER THESE PLOTS WERE SOLD TO SH. ARUN GOYAL WITHIN 3 MONTHS FROM THE DATE OF THE EARLIER AGREEM ENT CANCELLED AND AGAIN SOLD TO THE ASSESSEE AT A SUBSTANTIALLY LOW SALE CONSIDERATION IN COMPARISON TO THE ORIGINAL AGREEMENTS. ACCORDINGLY, THE AO ISSUED A SHOW CAUSE NOTICE TO THE ASSESSEE AS TO WHY THE DI FFERENTIAL AMOUNT OF PURCHASE CONSIDERATION BETWEEN THE ORIGINAL AGREEME NTS AND THE SALE DEED BY WHICH THE ASSESSEE PURCHASE THESE PLOTS SHO ULD NOT BE CONSIDERED AS UNDISCLOSED IN TERMS OF SECTION 69B OF THE ACT. THE ASSESSEE FILED ITS DETAILED REPLY BEFORE THE AO. TH E AO DID NOT ACCEPT THE CONTENTION OF THE ASSESSEE AND MADE ADDITION OF THE DIFFERENTIAL AMOUNT OF RS. 4,66,00,000/-. THE ASSESSING OFFICER TOOK FULL VALUE CONSIDERATION BY APPLYING THE PROVISIONS OF SECTION 50D OF THE ACT AS IT WAS STATED IN THE ORIGINAL AGREEMENTS DATED 28.03.2 013 AND 06.06.2013. THE ASSESSEE CHALLENGED THE ACTION OF T HE AO BEFORE THE LD. CIT(A) AND SUBMITTED THAT THE EARLIER AGREEMENTS W ERE BETWEEN ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 4 DIFFERENT PARTIES SHOWING A HIGHER SALE CONSIDERATI ON CANNOT BE ADOPTED AS FAIR MARKET VALUE OF THE PROPERTY IN TRANSACTION S BETWEEN THE ASSESSEE AND VENDER. THE LD. CIT(A) HAS DELETED THE ADDITION MADE U/S 69B OF THE ACT BY THE AO. 3. BEFORE US, LD. DR HAS SUBMITTED THAT THOUGH THE RE IS NO DIRECT EVIDENCE OF PAYMENT OF ON MONEY BY THE ASSESSEE T O THE SELLER HOWEVER, THE INCRIMINATING DOCUMENTS FOUND DURING THE SEARCH IN CASE OF ADVENTAGE GROUP CLEARLY SHOWN THE CHAIN OF EVENTS FROM INTENDED BUYERS TO THE FINAL TRANSFER OF THE PROPER TY IN FAVOUR OF THE ASSESSEE. THE ASSESSING OFFICER HAS ESTABLISHED THE FACT THAT THE SALE CONSIDERATION WAS AGREED UPON BETWEEN THE ORIGINAL OWNER AND THE PERSPECTIVE BUYER AS PER AGREEMENT DATED 28.03.2013 AT RS. 3,82,50,000/- IN RESPECT OF PLOT NO 201 AND RS. 2,9 7,50,000/- IN RESPECT OF PLOT NO. 202 GIRNAR COLONY, GANDHI PATH, JAIPUR. FURTHER AS PER THE AGREEMENT DATED 28.03.2013 AN ADVANCE PAYMENT WAS M ADE IN CASH BY THE PURCHASERS SH. MANPREET VISHNOI AND MS SABIA VI SHNOI. SUBSEQUENTLY, THE AGREEMENT TO SELL WAS CANCELLED V IDE ANOTHER AGREEMENT DATED 06.06.2013 HOWEVER, THE ADVANCE REC EIVED IN CASH WAS REFUNDED BY SH. KAILASH CHAND SHARMA AND SMT. U RMILA SHARMA ONLY AFTER THESE PLOTS WERE SUBSEQUENTLY SOLD TO SH . ARUN GOYAL IN THE ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 5 MONTHS OF AUGUST AND OCTOBER 2013 FOR A SUBSTANTIAL LY LESS CONSIDERATION OF RS. 97.25 LAKHS & RS. 76.50 LAKHS RESPECTIVELY. THE AO HAS OBSERVED THAT THE CONSIDERATION WAS PAID IN BY CHEQUE AS STATED IN THE SALE DEED, HOWEVER, THE DIFFERENTIAL AMOUNT WA S PAID IN CASH AND ONLY AFTER THE SAID TRANSACTION OF SALE OF THESE T WO PLOTS TO SH. ARUN GOYAL THE OWNERS REFUNDED THE ADVANCE TO SH. MANPRE ET VISHNOI AND MS SABIA VISHNOI. BY VIRTUE OF MULTI LAYER TRANSACTION OF TRANSFER, THE ASSESSEE HAS TRIED TO SHOW THE PURCHASE CONSIDERATI ON AT SUBSTANTIAL LOW IN COMPARISON TO THE FAIR MARKET PRICE OF PROPE RTY IN QUESTION. DUE TO PASSAGE OF TIME THE VALUE OF THE PROPERTIES TO G ET INCREASED INSTEAD OF DECREES AS CLAIMED BY THE ASSESSEE. HE HAS RELIE D UPON THE ORDERS OF THE ASSESSING OFFICER. 4. ON THE OTHER HAND, LD. AR OF THE ASSESSEE HAS SU BMITTED THAT THE ASSESSING OFFICER HAS MADE THE ADDITION U/S 69B WHI CH IS NOT ATTRACTIVE IN THE FACTS OF THE PRESENT CASE WHEN NONE OF THE P ARTIES IN THE TRANSACTION HAS ADMITTED ANY ON MONEY PAID OR RECEI VED OVER AND ABOVE THE SALE CONSIDERATION STATED IN THE SALE DEE D. HE HAS FURTHER SUBMITTED THAT THE ASSESSING OFFICER HAS PROCEEDED ON THE PRESUMPTION OF MARKET VALUE OF THE PROPERTY ON THE BASIS OF THE AGREEMENT WHICH WAS SUBSEQUENTLY CANCELLED AND THEREFORE, THE VERY BASIS OF MARKET ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 6 VALUE OF THE PROPERTY ADOPTED BY THE AO WAS NOT INE XISTENCE. HE HAS FURTHER CONTENDED THAT THE AGREEMENTS BETWEEN THIRD PARTIES CANNOT BE A BASIS OF THE CONSIDERATION BETWEEN THE ASSESSEE A ND SELLER. FURTHER THE SALE/PURCHASE CONSIDERATION PAID BY THE ASSESSE E IS MORE THAN THE DLC RATES OF THESE PROPERTIES, THEREFORE, THERE IS NO QUESTION OF INVOKING THE PROVISIONS OF SECTION 50D. HE HAS CONT ENDED THAT EVEN OTHERWISE SECTION 50D CAN BE APPLIED ONLY IN THE CA SE OF COMPUTATION OF CAPITAL GAIN AND IN THE HANDS OF THE SELLER AND NOT IN THE HANDS OF THE PURCHASER. THE ASSESSING OFFICER HAS MADE THE ADDIT ION WITHOUT ESTABLISHING THE FACT THAT THE OWN MONEY OVER AND A BOVE SALE CONSIDERATION DECLARED WAS ACTUALLY PAID. HE HAS RE LIED UPON THE FOLLOWING DECISIONS:- (I) ANEETA SINGH V. ITO 20 TAXMANN.COM 93. (II) CIT V. BERRY PLASTICS (P.) LTD. 35 TAXMAN.COM 296. (III) CIT V. FAIRDEAL TEXTILE PARK (P.) LTD. 43 TA XMAN.COM 393. (VI) CIT V. PUNEET SABHARWAL 16 TAXMAN.COM 320. (V) CIT V. SADHNA GUPTA 32 TAXMAN.COM 185. (VI) CIT V. DAULATRAM RAWATMULL 53 ITR 574. 5. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WEL L AS RELEVANT MATERIAL ON RECORD. DURING THE COURSE OF SEARCH AND SEIZURE ACTION ON ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 7 17.12.2014 IN CASE OF ADVENTAGE GROUP TO WHICH THE ASSESSEE COMPANY BELONGS APART FROM OTHER INCRIMINATING MATE RIAL TWO AGREEMENTS WERE FOUND WHICH WERE SEIZED AND EXHIBIT AS 24 OF ANNEXURE A. THESE TWO AGREEMENTS DATED 28.03.2013 SHOW THAT TWO PLOTS OF LAND SITUATED AT 201 & 202 GIRNAR COLONY, GANDHI PATH, JAIPUR WERE TO BE SOLD BY SH. KAILASH CHAND SHARMA AND SMT . URMILA SHARMA TO SH. MANPREET VISHNOI AND MS SABIA VISHNOI FOR C ONSIDERATION OF RS. 3,82,50,000/- AND RS. 2,97,50,000/- RESPECTIVELY. T HESE AGREEMENTS WERE SUBSEQUENTLY CANCELLED BY THE AGREEMENT DATED 06.06.2013. THE STATEMENTS OF SH. KAILASH CHAND SHARMA AND SMT. URM ILA SHARMA AS WELL AS SH. MANPREET VISHNOI AND MS SABIA VISHNOI W ERE RECORDED U/S 131 OF THE ACT. THESE PERSONS CONFIRMED SALE CONSID ERATION AGREED UPON BETWEEN THE PARTIES OF RS. 3,82,50,000/- AND R S. 2,97,50,000/- RESPECTIVELY. HOWEVER, THE REASONS FOR CANCELLATION OF AGREEMENTS WERE STATED TO BE HIGHER SALE CONSIDERATION. AFTER THE C ANCELLATION OF AGREEMENTS ON 06.06.213 THESE PLOTS WERE SOLD TO SH. ARUN GOYA IN THE AUGUST AND OCTOBER 2013 FOR A CONSIDERATION OF RS. 97.25 LAKHS AS AGAINST THE SALE CONSIDERATION AGREED UPON IN THE O RIGINAL AGREEMENTS DATED 28.03.2013 OF RS. 3,82,50,000/- AND RS. 76.5 0 LAKHS AS AGAINST THE SALE CONSIDERATION OF RS. 2,97,50,000/- AS PER THE AGREEMENT DATED ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 8 28.03.2013. THUS THE SALE WAS EFFECTED AT A CONSIDE RATION WHICH WAS ALMOST OF THE ORIGINAL SALE CONSIDERATION. THIS W AS THE REASONS FOR THE AO TO PROCEED WITH THE MATTER FOR MAKING THE AD DITION ON ACCOUNT OF ON MONEY PAID BY THE ASSESSEE FOR PURCHASE OF TH ESE PLOTS OF LAND FOR OWN ON 07.05.2014 FOR CONSIDERATION OF RS. 1,20 ,37,500/- AND RS. 93,62,500/- RESPECTIVELY. THESE CHAIN OF EVENTS AS EMERGING FROM AGREEMENTS DATED 28.03.2013 CANCELLATION AGREEMENT DATED 06.06.2013, CASH RECEIVED AT THE TIME OF ORIGINAL A GREEMENT DATED 28.03.2013 WHICH WAS REFUNDED SUBSEQUENT TO THE PLO TS WERE SOLD FOR A SUBSTANTIALLY LOWER CONSIDERATION WHICH IS ALMOST OF THE ORIGINAL SALE CONSIDERATION AGREED UPON BETWEEN THE PARTIES LED T O THE AO TO INVESTIGATE THE MATTER FURTHER. THOUGH THE ASSESSIN G OFFICER HAS NOT CONDUCTED AN ENQUIRY FOR DETERMINING THE FAIR MARKE T PRICE OF THE PROPERTY IN QUESTION AS REQUIRED U/S 69B TO SATISFY HIMSELF THAT THE ACTUAL VALUE OF THE PROPERTY IS MUCH HIGHER THAN TH E SALE CONSIDERATION SHOWN BY THE ASSESSEE RESULTING THE INVESTMENT MADE BY THE ASSESSEE TO THE EXTENT OF THE DIFFERENCE BETWEEN THE FAIR MA RKET PRICE AND THE CONSIDERATION ADMITTED BEING NOT SHOWN IN THE BOOK S OF ACCOUNT CAN BE ADDED TO THE INCOME OF THE ASSESSEE. THE ASSESSIN G OFFICER HAS PROCEEDED ON THE BASIS OF THE SALE CONSIDERATION AS STATED IN THE ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 9 AGREEMENTS DATED 28.03.2013 AS WELL AS CANCELLATION AGREEMENTS DATED 06.06.2013. THERE IS NO DOUBT THAT EARLIER AGREEMEN TS WERE BETWEEN DIFFERENT PARTIES AND ASSESSEE WAS NOT PRIVY TO THE AGREEMENTS. THEREFORE, WHEN THE EARLIER AGREEMENT WAS CANCELLED THEN THE SALE CONSIDERATION STATED IN THE EARLIER AGREEMENT CANNO T BE ADOPTED AS A FAIR MARKET PRICE/VALUE OF THE PROPERTY FOR THE PUR POSE OF SECTION 69B OF THE ACT. THE ASSESSING OFFICER WAS OUGHT TO HAVE BR OUGHT SOME TANGIBLE MATERIAL TO SATISFY HIMSELF THAT THE INVES TMENT MADE IN THESE ASSETS WERE MORE THAN THE INVESTMENT AS SHOWN BY TH E ASSESSEE IN THE BOOKS OF ACCOUNTS. THE LD. CIT(A) ISSUE A REMAND OR DER WITH SPECIFIC DIRECTION THAT THE DIRECTOR OF THE ASSESSEE COMPANY SHOULD HAVE BEEN EXAMINED BY THE AO. IT IS PERTINENT TO NOTE THAT TH IS DIRECTION OF THE LD. CIT(A) EVEN OTHERWISE WOULD NOT ACHIEVED ANY PURPOS E AS THE DIRECTOR OF THE ASSESSEE COMPANY WOULD NOT GIVE A STATEMENT DETRIMENTAL TO THE INTEREST OF THE ASSESSEE COMPANY AND THEREFORE THE OUTCOME AND FATE OF SUCH ENQUIRY WAS PREDETERMINED. SINCE IT IS AN ISSUE OF DETERMINATION OF THE FAIR MARKET VALUE OF THE PLOT S OF LAND IN QUESTION AND IT IS APPARENT FROM THE FACTS AND CHAIN OF EVE NTS AS DISCOVERED FROM THE SEARCH AND SEIZURE ACTION AND EMERGED FRO M THE DOCUMENTS DISCLOSING THE EARLIER AGREEMENTS TO SELL OF THESE PLOTS OF LAND THAT ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 10 DIFFERENCE BETWEEN THE SALE CONSIDERATION AGREED UP ON BETWEEN THE PARTIES IN THE AGREEMENT DATED 28.03.2013 AND THE SALE CONSIDER FOR WHICH THE ASSESSEE PURCHASE THE PROPERTY VIDE SALE DEED DATED 07.05.2014 IS RS. 4.66 CRORES WHICH IS MORE THAN T HE TWICE OF THE SALE CONSIDERATION PAID BY THE ASSESSEE. THE ASSESSEE HA S NOT BROUGHT ON RECORD ANY FACTS OR CIRCUMSTANCES TO SHOW THAT THE VALUE OF THE PROPERTY HAS DEPRECIATED DURING THE PERIOD FROM 28. 03.2013 TO 07.05.2014 AND FURTHER THE FAIR MARKET PRICE OF THI S PROPERTY IS LESS THAN THE PREVAILING PRICE DUE TO CERTAIN DISADVANTAGES A TTACHED TO THIS PROPERTY. THEREFORE SO FAR AS THE ACTION OF THE AO TO INVOKE THE PROVISIONS OF SECTION 69B IS CONCERNED, IT IS PROPE R ON THE PART OF THE AO TO INVOKE THESE PROVISIONS IF THE AO IS SATISFIED T HAT THE INVESTMENT MADE BY THE ASSESSEE IS MUCH MORE THAN IT HAS SHOWN IN THE BOOKS OF ACCOUNTS. ACCORDINGLY, HAVING REGARD TO THE FACTS A ND CIRCUMSTANCES OF THE CASE WE ARE OF THE CONSIDERED VIEW THAT THIS MA TTER REQUIRES A PROPER VERIFICATION AND EXAMINATION AT THE LEVEL OF THE AO FOR DETERMINING THE FAIR MARKET PRICE/VALUE OF THE PLOT OF LAND IN QUESTION. SINCE THE VALUATION OF THE PROPERTY IS A SUBJECT MA TTER OF THE EXPERTS IN THE FIELD, THEREFORE, ASSESSING OFFICER OUGHT TO HA VE GOT THE VALUATION FROM THE EXPERT/DVO. AT THE SAME TIME THE ASSESSEE IS ALSO AT LIBERTY TO ITA NO. 333/JP/2017 DCIT V M/S ADVENT INFRAPROJECTS PVT. LTD. JAIPUR 11 SUPPORT ITS CLAIM BY FILING VALUATION REPORT FROM T HE REGISTERED VALUER. HENCE, THIS MATTER IS SET ASIDE TO THE RECORD OF TH E ASSESSING OFFICER FOR FRESH ADJUDICATION. NEEDLESS TO SAY THE ASSESSEE BE GIVEN AN OPPORTUNITY OF HEARING. IN THE RESULT, THE APPEAL FILED BY THE REVENUE IS ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 15/11/2017 SD/- SD/- HKKXPAN FOT; IKY JKO (BHAGCHAND) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 15/11/2017. * SANTOSH. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- THE DCIT), CENTRAL CIRCLE-3, JAIPUR. 2. IZR;FKHZ@ THE RESPONDENT- M/S ADVENT INFRAPROJECTS PVT. LTD., 424- 425, GANPATI PLAZA, M.I. ROAD, JAIPUR. 3. VK;DJ VK;QDR@ CIT 4. VK;DJ VK;QDR@ CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR. 6. XKMZ QKBZY@ GUARD FILE {ITA NO. 333/JP/2017} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR