Chand Monammad, Ajmer V. ITO, Ward 1(3), Ajmer

ITA 340/JPR/2022

AI Insights

The case involves Shri Chand Mohd., a power loom laborer, who was assessed for unexplained cash deposits amounting to Rs. 5,76,64,348 in his bank accounts during the financial year 2011-12. The Income Tax Officer (ITO) issued a notice under section 148 of the Income Tax Act, 1961, based on a report from the Financial Intelligence Unit (FIU) and the Directorate of Income Tax (Investigation), Udaipur. The AO treated these deposits as income from unexplained sources and added 10% of the total deposits as income for the assessment year 2012-13. The assessee contested the reassessment and the addition, arguing that he was merely a facilitator for other traders and not engaged in any trading activities himself. The CIT(A) upheld the AO's decision, leading to the filing of an appeal with the ITAT.

• Counselvise Citation: [2023] 140 COUNSELVISE.COM (IT) 132399 (ITAT-JAIPUR)
• Duration Of Justice: 11 month(s) 19 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-08-2023
• Appeal Filed By: Assessee
• Order Result: PartlyAllowed
• Bench Allotted: A
• Next Hearing Date: 18-07-2023
• Assessment Year: misc
• Appeal Filed On: 08-09-2022
• Other Referred Cases: Smt. Anita Choudhary vs. ITO, Shree Sidhnath Enterprise vs. ACIT, Sanjoy Kumar Garg vs. ACIT, Basant Kumar Jain vs. ACIT
• Laws Referred To: Income Tax Act
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: WE MAY SUBMIT; NIKHLESH KATARIA; TAKING INTO CONSIDERATION AGAIN ALL
• Keywords: Reopening of assessment; Invalid notice; Income from undisclosed sources; Opportunity of cross examination; Question of law; Corroborative evidences; Third party statement; Accommodation entries; Competent authority; Right to appeal; Reason to believe
• Section: 131; 148; 271(1)(c); 142(1); 234B; 143(2); 208; 139(1); 113; 2(A)

Judgement Text

vk;djvihyh; vf/kdj.k] t;iqjU;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, ‘’A” JAIPUR JhlaanhixkslkbZ]U;kf;dlnL; ,oaJhjkBksMdeys'kt;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: SHRI SANDEEP GOSAIN, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 340/JP/2022 fu/kZkj.ko"kZ@AssessmentYear : 2012-13 Shri Chand Mohd. 505, Raja Ready Ajmer Road Madanganj, Ajmer (Raj) 305 801 cuke Vs. The ITO Ward 1(3) Ajmer LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: BDXPM 8066 M vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri Nikhlesh Kataria, CA jktLo dh vksjls@Revenue by: Shri A.S. Nehra, Addl.CIT lquokbZ dh rkjh[k@Date of Hearing : 19/07/2023 mn?kks"k.kk dh rkjh[k@Date of Pronouncement: 28 /08/2023 vkns'k@ORDER PER: RATHOD KAMLESH JAYANTBHAI, AM This appeal filed by the assessee is directed against the order of the ld. CIT(A) dated 12-07-2022,National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment years 2012-13 wherein the assessee has raised the following grounds of appeal. ‘’1. That on the facts and circumstances of the case, the notice issued u/s 148 of the Act by the AO is bad in law for various reasons and prayed for being quashed. 2. That on the facts and circumstances of the case, the ld. CIT(A) erred in confirming the action of the AO of reopening the assessment without having jurisdiction and also without having any reason to believe as on the date of issue of notice u/s 147/148 2 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER that income has escaped assessment. The assessment in pursuance of same is thus prayed for being quashed. 3. On the facts and circumstances of the case, the ld. CIT(A) erred in confirming the action of the AO of reopening of assessment without obtaining appropriate sanction as provided u/s 151 of the Act and thus assessment in pursuance of same is prayed for being declared void ab initio. 4. On the facts and circumstances of the case, the ld. CIT(A) erred in confirming the action of the AO of making addition in hands of assessee of an income which does not belong to the assessee at all ignoring the facts and circumstances of the case. Such an addition is invalid and hence prayed for being deleted. 5. On the facts and circumstances of the case, the ld. CIT(A) erred in confirming the action of the AO of addition in hands of assessee ignoring the fact that assessee was not indulged in any business activities and had no source from which such huge receipts can be obtained by him. Such an invalid and arbitrary addition is thus prayed for being deleted. 6. On the facts and circumstances of the case and without prejudice to other grounds of appeal, the ld. CIT(A) erred in confirming the action of the AO of assessing the income of assessee at Rs.56,86,440/- making an addition of Rs.5576,435/- which is in alternate excessive and unjustified. It is hereby prayed for reducing the addition thus made. 2.1 Brief facts of the case are that in this case no return was filed by the assessee u/s 139(1) of the Act. The AO mentioned in the assessment order that as per information available on record a report was received FIU (IND) in the case of Shri Chand Mohammad from office of DDIT (Inv)-1, Udaipur vide letter No. 647 dated 27-03-2014. The AO after going through the report and its enclosures gathered that the assessee Shri Chand Mohammad was holding bank account Nos. 3573002100033003, 18372020001122 and U16173060 in the name of Proprietary concern M/s. Chand Trading with Punjab National Bank, Cinema Road, Ajmer, HDFC Limited and Indusin Bank, Ajmer respectively . The AO noted that huge amount of cash was deposited in this account during the F.Y. 2011-12 on daily 3 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER basis and the cash was withdrawn by the assessee through ATM or self cheque from the base branch in Kishangarh. The AO further noted that during the year under consideration, total amount of Rs.5,76,64,348/- was deposited in the aforementioned bank account of the assessee. The AO thus from the entries of cash deposit in bank account of assessee noticed that the cash was deposited at different stations all over the India. The AO also noted that it is pertinent to mention here that Kishangarh is well known for Marble and Granite Trading but in plenty of cases, marble and granite is sold through under billing and in some cases no bills are issued at all. The AO further noted that in this case the sale proceeds of out of books cash sales of assessee were deposited by different parties in her own accounts of PNB, HDFC and Indusind at different stations. The AO also observed that on the exactly identical facts, ITAT Jaipur in the case of Smt. Anita Choudhary in ITA No. 733/JP/2009 dated 07-05-2010 upheld the addition of an amount equal to 10% of such deposits which was confirmed by the Hon’ble Rajasthan High Court in DBIT No. 289/2010 dated 14-10-2011. Thus the AO on the basis of above information available on record, notice u/s 148 of the Act was issued by his office on 25-03-2019 after obtaining necessary satisfaction of competent authority. In response to this notice, the assessee had e-filed his return of income on 12-04-2019 declaring the income of Rs.1.10 lacs vide acknowledgement No. 46313715112419. Notices u/s 143(2) of the Act was issued 4 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER on 08-09-2019. Notice u/s 142(1) of the Act was issued on 01-08-2019 and the assessee was asked to furnish certain details and documents and the case was fixed for making compliance on 13-08-2019 and thus nobody attended on the date and time given by the AO for which show cause notice was issued to the assessee on 11-10-2019 for making compliance on 21-10-2019 but no compliance was made by the assessee. Summon u/s 131 of the Act was issued to the assessee on 22-10- 2019 and the case was fixed for hearing on 11-11-2019. In response to summon the assessee attended on 13-11-2019 and his statements were recorded on oath and the assessee was asked about his bank accounts and deposits in the bank account. The AO for the sake of clarity on the issue reproduced the statements of the asssessee at pages 2 to 16 in the assessment order. Thus the AO conclusively noted that as per the statements given by the assessee, it is clear that whole amount deposited into the Bank account of the assessee pertain to the assessee. The relevant observation of the AO making the addition of Rs. 55,76,435/-in the hands of the assessee is reproduced at page 10 of AO’s order is as under:- ‘’Moreover, the ld. CIT(A), Ajmer vide his order No. 313/2018-19 dated 20-08-2019 has dismissed the appeal of the assessee and upheld the order of the AO by confirming the addition of Rs.21,77,189/-. This means that whole deposits made into the bank account of the assessee during F.Y. 2010-11 as well as 2011-12 pertains to the assessee. In view of above discussed facts of the case and relying upon the decision of Hon’ble Bench of ITAT, Jaipur in case ofSmt.Anita Choudhary in ITA No.733/JP/2009 dated 07- 05-2010 on the similar facts which was confirmed by the Hon’ble Rajasthan High Court in DBITA No. 289/2010 dated 14-10-2011 income of the assessee for the year under consideration is assessed at Rs.55,76,435/- which is 10% of the total deposits in the bank 5 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER account of the assessee i.e. 5,57,64,348/-. Also the ld. CIT(A, Ajmer has confirmed the assessment order of the assessee for the A.Y. 2011-12 on similar issue.’’ 2.2 In first appeal, the ld. CIT(A), the ld. CIT(A) dismissed the appeal of the assessee by observing as under:- ‘’7.1. Grounds of Appeal No.1 and 5 a) These GOA are routine and general in nature and do not require separate adjudication. 7.2 Grounds of Appeal No.2: Addition of Rs. 55,76,435/-. a) The gist of addition made is outlined in para 2(a) to 2(d) of this order. b) The undersigned has gone through the written submissions andassessment order. This GOA is discussed and decided in para7.3 of this order. 7.3 Finding on GOA No. 2 a) In his written submission the Appellant has admitted that he has not done any marble trading and he was only an entry operator He allowed his bank a/c to be used for depositing unaccounted cash of different marble traders of Kishangarh. In these bank a/c's cash was deposited at different stations and then withdrawn in cash vide ATM of self cheque and handed over to the actual owners (beneficiaries). For this facility, the Appellant charged commission (page 5 of written submissions). Thus, the Appellant has admitted the whole modus operandii as outlined by the AO in the assessment order. b) The next question to be decided is that how the same is to be taxed in hands of Appellant. .In the case of Appellant for AY-2011-12 the ITO. Ward-2. Kishangarh passed order u/s 143(3) r.w.s. 147 and made an addition @ 10% of Total cash deposits amounting to Rs. 21.77,189/-in hands of Appellant. . In first appeal, the Ld. CIT(A), Ajmer vide order dated 20.08.2019 confirmed the addition made by AO by taxing @ 10% of Total cashdeposits made in bank a/c of Appellant. Thus, the action of AO was upheld by first Appellate Authority in case of Appellant for AY-2011- 12. .The AO relied on the judgment of Hon'ble ITAT, Jaipur in case of Anita Chaudhary in ITA No. 733/JP/2009 dated 07.05.2010 andjudgment of Hon'ble Rajasthan High Court in case of Anita Chaudhary in ITA No. 289/2010 dated 14.10.2011 where the addition made based on similar facts by the AO were confirmed. Addition was made @10% of Total cash deposits in case of Anita Chaudhary. In view of these facts the AO made addition of Rs 55,76,435/- in hand's of Appellant as unexplained cash deposits(10% of Total cash deposits of Rs. 5,57,64,348/-). 6 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER .c) In view of the facts and respectfully following the judgments of Hon'ble Jurisdictional ITAT and Hon'ble Jurisdictional High Court in case of Anita Chaudhary based on identical facts and respectfully following the order of CIT(A), Ajmer in case of Appellant for AY- 2011-12 based on identical facts the addition made by AO of Rs. 55,76,435/- 10% of total cashdeposits in bank a/c's of Appellant is hereby upheld and confirmed, GOANo. 2 is dismissed. 7.4 GOA No. 3: Charging of interest u/s 234A and 234B. Interest u/s 234A and 234B is mandatory and not discretionary as held by Hon'ble Supreme Court in the case of Anjum M.H. Ghaswala in 252 ITR 1 and CIT Vs. Hindustan Bulk Carriers in 259 ITR 449. For the purpose of statistics, this Ground of Appeal is hereby dismissed. 7.5 GOA No. 4: Penalty proceedings u/s 271(1)(c). This GOA is premature as penalty u/s 271(1)(c) has not yet been levied and only notice has been issued. Even otherwise penalty proceedings are separate from assessmentproceedings. Hence, this GOA No. 4 is dismissed. 8. In view of above facts the appeal is DISMISSED.’’ 2.3 Being aggrieved by the order of the ld. CIT(A), the assessee carried the matter before this Bench of ITAT with the prayer that the circumstances, evidences on record and conduct of the department as to the addition made are unsustainable in the eyes of law which deserves to be deleted. It is also noted from the written submission of the assessee at para 1.3 1 that No independent enquiry or investigation made by the ld. AO: It is submitted that despite of contrary statement of Shri Ganesh Goyal on record, no independent enquiry was made by the ld. AO and ld. AO has simply relied on the report of the investigation wing. As already submitted that even the assessee has agreed for the cross examination of Shri Ganesh Goyal but still the ld. AO chose not to examine Shri Ganesh Goyal. In 7 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER absence of any such independent enquiry or investigation, no credibility can be given to the investigation wing report and accordingly whole addition become bad in law.It is pertinent to mention the ld. AR of the assessee has filed detailed written submission containing pages 1 to 23 alongwith case laws countering the addition so made by the AO which is reproduced as under: ‘’Brief Facts: The assessee is a power loom labourer and during the year under consideration i.e. AY 2012-13, he was working in a power loom factory at Madanganj-Kishangarh. The ld. AO noted that as per information available on record from DDIT (Inv.)-I, Udaipur vide letter dt.647 dt.27-3-2014 the assessee was having bank account with Punjab National Bank, HDFC Bank and Indusind Bank in which cash was deposited at various places all over India and later on withdrawn from ATM or through self cheque at the branches of the bank. Total of such cash deposit stood at Rs.55764348/- and the ld. AO was of the view that this is sale proceeds of cash sales of the assessee. Therefore, on the basis of such information notice u/s 148 was issued on dt.25-3-2019 and in response to the same the assessee has filed his return of income on 12-4-2019 declaring income of Rs.110000/- from labour work. The copy of return of income and computation thereof is placed at PB 19-20. During the course of assessment proceedings, statement of the assessee was also recorded in which he explained that he was not aware of transactions in his bank account and these might have been done by one Mr. Ganesh Goyal. However, contention of the assessee was not accepted and following decision in case of Smt. Anita Choudhary in ITA no.733/JP/2009 dt.7-5-2010 (PB) which was later confirmed by the Hon’ble Rajasthan High Court in DBIT No.289/2010 dt.14-10-2011, the cash deposit made by the assessee was treated as trading turnover and income was assessed @10% of total cash deposit which came to Rs.5576435/-. Before the ld. CIT(A), besides challenging the reassessment proceedings and addition so made, the assessee also took alternative argument to assess commission income @Rs.100 to Rs.300/- per lac. However, the ld. CIT(A) following the decision of Hon’ble Rajasthan High Court in Smt. Anita Choudhary (supra) rejected the appeal of the assessee summarily and therefore the assessee has filed this second appeal before this Hon’ble Bench. Our Submission: 1.1.1 ITAT order in AY 2011-12: At the outset it is submitted that the Hon’ble ITAT has decided the similar case of the assessee for AY 2011-12 and the copy of order is placed at PB 127-135. The Hon’ble ITAT has given finding at para 7 of the order (PB 133) which read as under: “7. We have heard both the parties and perused the materials available on record and judicial precedent relied upon by them to drive home to their contentions. From the records, the Bench noted that the assessee had bank account with PNB wherein transaction of depositing / withdrawing the amount was continuous. These financial 8 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER transactions were within the knowledgeof the assessee as it is manifestly in the statement recorded and the clear findings of the lower authorities indicate that such transaction of depositing and withdrawing the amounts in the knowledge of the assessee. The ld. AR could not controvert the findings of the lower authorities which is based on the statement of the assessee recorded and, in that statement, nowhere it has been stated that he was not aware about having the bank account and has also not opposed the transaction done. The ld. AR of the assessee submitted that the action of the lower authorities is not correct and in fact the assessee has not earned so much of benefit as it is held by the lower authorities and the assessee being small tax payer the same may be considered accordingly. We find from the order of the ld. CIT(A) that he has already considered all the aspects and the decision cited by the assessee. The lower authorities has already granted the relief to the extent of 90 % of the amount deposited in the bank account and only considered the income to the extent of 10 % of the such deposit. The ld. AR of the assessee could not substantiate as to how and why the said relief is still not sufficient and has not submitted any comparative finding so as to deviate and grant more relief based on the stated facts. Since, the substantial relief has already been granted by the lower authorities recording the detailed finding of facts and in such a situation, we have no alternative except to confirm the action of the ld. CIT(A) as ld. AR did not controvert the findings of lower authorities. 8. Based on these observations the appeal of the assessee is dismissed.” 1.1.2 Order in earlier year i.e. AY 2011-12 not binding on Hon’ble ITAT: We may submit that though in earlier year the Hon’ble ITAT has decided the case against the assessee in similar circumstances however the same is not binding on the assessee for the following reasons: a. Assessment order and CIT(A) order is passed on misinterpretation/ incorrect facts and also against the settled judicial principles which issues have not dealt with in the earlier order of ITAT b. Incorrect finding of fact recorded in the order of Hon’ble ITAT c. Principle of res judicata is not applicable to the assessment proceedings and each year is a separate unit Now these aspects have been discussed in detail herein after. 1.1.2.1 Assessment passed on misinterpretation of facts which was not considered in earlier year order: It is submitted that the present assessment has been passed by the ld. AO suffers from serious infirmities and misinterpretation of facts which were not pointed out in the earlier year. These wrong facts as considered by the ld. AO are in the foundation of the addition made and consequently the entire addition and even the assessment order framed is bad in law. The incorrect facts on the basis of which the ld. AO framed the assessment has been discussed herein below: 9 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER 1.1.2.2 Decision of Hon’ble ITAT and Rajasthan High Court in case of Smt. Anita Choudhary not applicable: The entire basis of taxing of bank deposit as turnover was decision of Hon’ble Jaipur ITAT in case Income Tax Officer, Kishangarh-Vs- Smt. Anita Choudhary in ITA no. 733/JP/2009(PB 122-126) which was later confirmed by the Hon’ble Rajasthan High Court in DBIT Appeal no.289/2010 dt.14-10-2011. It is submitted that the above decision was entirely based on the specific fact of that case where the assessee was already carrying on the business of marble trading and it declared turnover of Rs.4434191/- on which gross profit was declared @8.78%. Considering the fact that the assessee is already carrying on the business and the bank deposit can be linked to the business of the assessee and accordingly the Hon’ble ITAT has directed to apply the GP rate @10% on the basis of comparison of history of the assessee. The finding of ITAT in case of Smt. Anita Choudhary (supra) is reproduced herein below: “4. We have heard both the parties. The Tribunal vide order dated 29th May, 2009 in the case of Shri Ram Swaroop in ITA No.113/JP/2009 for the assessment year 2005-06 had an occasion to consider the cash deposits of Rs.22.86 lacs made in the account of Shri Ram Swaroop in IDBI bank. The deposits were similar of the nature as are available in this case. The Tribunal after considering the facts of case held that income of Rs 1.25 lacs to be estimated and accordingly directed the AO to add the same of Rs.1.25 lacs as against cash deposit during the entire year. The ld.AR has filed before us the copy of the bank account. The copy of the bank account contains 9 pages. There are number of entries in each month. The maximum credit balance in the bank account is to the extent of Rs.1,51,905/- as on 11-08-2004. The minimum balance is of Rs. 563/-. The credit balance as on 31-03-04 is Rs. 56,5581- while credit balance as on 3l-03-05 is Rs. 566/. This shows that the amount deposited during the year is less as compared to the withdrawal made during the year. This is not the case of the Revenue that withdrawals made in this account have been utilized elsewhere. In case the amounts have been deposited by the assessee in the bank account then Revenue is required to consider the availability of such deposits from the withdrawals made from such bank account. It is true that the assessee has not been able to give the required details because such details have not been kept by the assessee. Under such circumstances, one has to consider the totality of the circumstances and accordingly one will have to consider income portion from the turnover as mentioned in the bank account. It is an accepted position that the assessee is doing the business in marble and the assessee is not having any other source of income. Once the assessee has offered an explanation and the Revenue has not established that explanation is false then one will have to consider the income generated from the turnover as in the bank account. It is true that the assessee has shown gross profit in the marble business and the ld. CIT(A) has partly upheld the addition by applying the gross profit rate of 8.78%. We feel that in case where funds are received for the purchase of marble and the assessee has to render the services for purchases of marble and transportation then the gross profit rate will be slightly higher and we feel that the income from the turnover to the extent of Rs.25,20,2721/- should be estimated at Rs.2.52 lacs. After considering the excess income declared in the return to the extent of Rs.2.10 lacs, the balance addition will remain to the extent of Rs.42,0001/- as against Rs.11271/- confirmed by the ld. CIT(A). Thus the solitary ground of the Revenue is partly allowed.” 10 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER The Hon’ble Rajasthan High Court has confirmed the case based on facts which were arrived at by the ITAT and no law was laid down that unexplained bank deposit can be treated as turnover in case of any assessee. 1.1.2.3 No history of the assessee – no comparison available to apply g.p. rate: As already submitted that the dominant aspect in the case of Smt. Anita Choudhary (supra) was that the assessee already carried on the business activity and a substantial turnover and gross profit thereon was declared. However, In the present case the assessee is daily wage earner and that too in a power loom factory. The return filed for the current year AY 2012-13 along with computation of total income is placed at PB 19-20. In the computation of total income which was also submitted before the lower authorities, it has specifically been mentioned that the assessee a daily wager. Thus there being no history of trading, the decision of Hon’ble ITAT as confirmed by the Hon’ble High Court in case of Smt. Anita Choudhary (supra)has no applicability on the facts of the present case. Therefore, both the lower authorities completely erred in interpreting the order of high court by relying on the order and treating the bank deposits as turnover of the assessee. 1.1.3 No contradiction in the statement of the assessee – baseless fact finding of the AO: It is submitted that from the very start of the proceedings, the stand of the assessee was that it was not aware of the transactions in its bank account in which alleged amounts were deposited and withdrawn. It has been stated by the ld. AO that there is contradiction in the statement of the assessee and that in its statement the assessee has accepted that the transactions were being carried on with his knowledge. The consistency of the stand of the assessee can be seen from the following: 1.1.3.1 No business or other income declared on account of such transactions: We may submit that even in response to the return filed u/s 148, the assessee has not declared any income on account of transactions in the alleged bank accounts for the reason that it was not at all aware of any such transactions being carried out. The copy of return and computation of total income is placed at PB 19-20 in which only the income from daily wages have been declared. 1.1.3.2 Clearly stated in the statement recorded u/s 131: It is submitted that the statement of the assessee was recorded by the ld. AO on 13-11-2019. In the statement so recorded the assessee (AO page 3 onwards) has clearly stated that he was not aware of any transactions in his bank account. iz’u la- 1%&d`Ik;kviukiw.kZifjp; nsosaA mRrj%& esjk uke pkaneksgEeniq= JhNksVw [kakugSAeSa 33 o"kZ dk gwW irk 505] jktkjsMh] vtesjjksM] egcxt&fd’kux< es jgrkgWWwAeSaikapoh d{kk iklgWWw A fgUnhi<&cksysvkSj le>ysrkgWwA iz’u la- 2%&vkiusvk; ds leLrसाधनŌ ds ckjsesaKkudkjhnsosaA mRRkj%& eSayxHkx 21 o"kZ ls ikcjywx es ukSdjhdjrkgWw ] fQygkyeSagkWyhesDlgksVy ds ihNsokyhxyhesalds"kthegsrk ds ;gkW ’kVZyokyhywe pykrkgWwA ;gkij ,d vknehyxHkx 4 ywepykrkgSeSaHkhckjywepykrkgWwA 12 /kUVs dh f’k¶V ds yxHkx :i;s 500@&izfrfnu ds fglkc ls feyrsgSAbldsvykokvkSjdksbZdke ugh djrkgwWA 11 ITA NO. 340/JP/2022 SHRI CHAND MOHAMMAD VS ITO, WARD 1(3), AJMER iz’u la- 4%&fjdkMZijmiyC/k Kkudkjh ds vuqlkjvkidsiatkcus’kuycSadflusekjksM] vtesj] ,p-Mh-,Q-lh- cSadfd’kux<] b.Mlb.McSadvtesj ds [kkrkuEcj 357302100033001 ¼pkan VªsfMax½ 18372020001122 ¼pkan eksgEen½ rFkk 0129U16173060 ¼pakn VsªfMax½ gS] ftldkLVsVesUVeSavkidksfn[kk jgkgWwA ;s [kkrsvkidsgSaftudhजानकारीvki us ugh nhgSad`Ik;kcrk;safd ;s [kkrs dc [kqyok;sFksrFkkbu dh जानकारीvki us D;ksa ugh nhgSA mRRkj %& bu [kkrksa ds ckjs es eq>s Kkudkjh ugh gSaAysfdu eq>s ;g vPNhrjg ;kngSfdo"kZ 2010 ;k 2011 esaesjslsBthJhx.ks’kxks;yftudhQsDVh fey dkWyksuhesagS] ogkWeSadkedjrkFkk oks eq>s ;g dgdjvtesjysx;sFksfdcSd [kkrs [kqyokusgSvkSjeS muds lkFkx;kFkkvkSjviukifjp; i= Hkhysdjx;kFkk] ogkWtkdjmUgksusdqNdkxtksaijesjs gLRkk{kjdjok;sFksAmUgksusvtesjesa eq>s 50 :Ik;sfdjk;s ds fd’kuxs bl ckjsessadksbZजानकारीugh gSA iz’u la- 6%&vkidksaigyhckj dc irk pykfdvkids uke ls ;s cSad [kkrsFksaftuesudntekgqvkFkkA mRrj %& ekpZ 2018 esatc eq>s vkidkuksfVlfeykmldsdqNfnu ds cknesa eq>s irk pykfdesjs [kkrsesacgqrlkjs :Ik;satekdjokdjfudkysx;sgSA iz’u la- 8%&Jhx.ks’kxks;y ds c;kuvk;djmifunsZ’kd ¼v-osa-½&izFke] mn;iqj }kjkvk;djvf/kfu;e dh /kkjk 131 ds rgr 05-07-2012 dksfy;sx;sFkstkseSavkidksis i