M/S UNITED PLYWOOD, AJMER V. PR. COMMISSIONER OF INCOME TAX, AJMER

ITA 352/JPR/2019

• Counselvise Citation: [2019] 116 COUNSELVISE.COM (IT) 5840 (ITAT-JAIPUR)
• Duration Of Justice: 4 month(s) 25 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-08-2019
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Assessment Year: 2014-2015
• Appeal Filed On: 14-03-2019
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: B K GUPTA CIT DHK
• Keywords: Business income; Revision of order; Set aside
• Section: 142(1); 263

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCH B, JAIPUR JH FOT; IKY JKWO] U;KF;D LNL; ,O A JH FOE FLAG ;KNO] YS[KK LNL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM VK;DJ VIHY LA- @ ITA NO. 352/JP/2019 FU/KZKJ.K O'K Z @ ASSESSMENT YEARS : 2014-15. M/S. UNITED PLYWOOD, 125, GHEE MANDI, MADAR GATE, AJMER. CUKE VS. THE PRINCIPAL CIT, AJMER. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO. AABFU 6227 A VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI P.C. PARWAL (CA) JKTLO DH VKSJ LS@ REVENUE BY : SHRI B.K. GUPTA (CIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 07.082019 ?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 08/08/2019. VKNS'K@ ORDER PER VIJAY PAL RAO, J.M. THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST TH E REVISION ORDER PASSED BY LD. PCIT DATED 27.02.2019 PASSED UNDER SECTION 263 OF THE IT ACT FOR THE ASSESSMENT YEAR 2014-15. THE ASSESSEE HAS RAISED T HE FOLLOWING GROUNDS OF APPEAL :- 1. UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, ORDER PASSED BY THE LD. PCIT U/S 263 IS ILLEGAL & BAD IN LAW AND TH E SAME BE QUASHED. 2. THE LD. PCIT HAS ERRED ON FACTS AND IN LAW IN HO LDING THAT REDUCTION OF RS. 11,04,944/- ON ACCOUNT OF VAT U/S 145A IN COMPUTING THE BUSINESS INCOME IS NOT ALLOWABLE AS S AME IS NOT ACTUALLY PAID OR INCURRED BY THE ASSESSEE IGNORING THE PROVISION OF SECTION145A ACCORDING TO WHICH THE VAT INCLUDED IN OPENING 2 ITA NO. 352/JP/2019 M/S. UNITED PLYWOOD, AJMER. STOCK AND PURCHASES TO THE EXTENT OF RS. 29,82,461/ - WAS ADDED TO BUSINESS PROFIT IN DIFFERENT YEARS AND VAT AMOUN TING TO RS. 15,65,203/- (INCLUDING RS. 11,04,944/-) HAS BEEN RE DUCED FROM BUSINESS INCOME TILL AY 2014-15 TO GIVE EFFECT TO S ECTION 145A AND THUS, NO PREJUDICE IS CAUSED TO THE REVENUE ON SUCH ADJUSTMENT MADE AS PER LAW. 2.1. THE LD. PCIT HAS ERRED ON FACTS AND IN LAW IN HOLDING THAT AO HAS FAILED TO ENQUIRE INTO THE AUDIT STATEMENT AS T O THE VALUATION OF CLOSING STOCK ARRIVED ON ESTIMATED BASIS AND THU S THE ORDER PASSED BY AO IS ERRONEOUS AND PREJUDICIAL TO THE IN TEREST OF REVENUE IGNORING THAT ASSESSEE HAS FOLLOWED THE SAM E METHOD OF VALUATION OF CLOSING STOCK. 3. THE APPELLANT CRAVES TO ALTER, AMEND AND MODIFY ANY GROUND OF APPEAL. 5. NECESSARY COST BE AWARDED TO THE ASSESSEE. 2. THE ASSESSMENT WAS COMPLETED UNDER SECTION 143(3 ) ON 28.12.2016 AT THE TOTAL INCOME OF RS. 7,50,750/- AS AGAINST THE RETUR NED INCOME AT RS. 5,32,410/-. SUBSEQUENTLY ON EXAMINATION OF RECORD, THE LD. PCIT NOTED THAT THE ASSESSEE HAS REDUCED THE VALUE OF CLOSING STOCK BY A SUM OF RS. 11,04,944/- AS AN EFFECT OF SECTION 145A OF THE ACT, HOWEVER, THE ASSESSEE HAS NOT MAINTAINED ANY STOCK RECORD FOR THE YEAR UNDER CONSIDERATION. THEREFORE, THE LD . PCIT HAS OBSERVED THAT THE CLOSING STOCK AS ON 31 ST MARCH, 2014 WAS NOT ASCERTAINABLE AND HENCE THE DE DUCTION OF RS. 11,04,944/- CLAIMED BY THE ASSESSEE IS NOT A LLOWABLE AS EFFECTS OF SECTION 145A ON ACCOUNT OF VAT COMPUTED ON VALUATION OF CLO SING STOCK. THE LD. PCIT ACCORDINGLY ISSUED A SHOW CAUSE NOTICE UNDER SECTIO N 263 ON 18.09.2018 ON THIS ISSUE AND ASKED THE ASSESSEE TO SHOW CAUSE AS TO WH Y THE ORDER PASSED BY THE AO DATED 28.12.2016 SHOULD NOT BE CONSIDERED AS ERRONE OUS IN SO FAR AS IT IS PREJUDICIAL TO THE INTEREST OF THE REVENUE. THE ASSESSEE FILED REPLY TO THE SHOW CAUSE NOTICE 3 ITA NO. 352/JP/2019 M/S. UNITED PLYWOOD, AJMER. AND SUBMITTED THAT THE ASSESSEE HAS COMPUTED THE IM PACT OF SECTION 145A CORRECTLY AND THE CLOSING STOCK HAS BEEN VALUED AFTER GIVING THE EFFECT OF SECTION 145A ON ACCOUNT OF VAT PAID OR PAYABLE AS ON 31 ST MARCH, 2014. THE LD. PCIT WAS NOT IMPRESSED WITH THE REPLY AND EXPLANATION OF THE ASS ESSEE AND HELD THAT THE ASSESSEE HAS SHOWN NEGATIVE VAT AMOUNT OF RS. 11,04,944/- WH ICH IS NOT ACTUALLY PAID OR INCURRED BY THE ASSESSEE, THEREFORE, NO ADJUSTMENT IS REQUIRED TO BE MADE BY THE ASSESSEE UNDER SECTION 145A OF THE ACT. CONSEQUENT LY, THE LD. CIT HAS HELD THAT THE ORDER OF THE AO IS ERRONEOUS IN SO FAR AS IT IS PRE JUDICIAL TO THE INTEREST OF THE REVENUE AND THE SAME WAS SET ASIDE TO THE FILE OF A O FOR MAKING AFRESH AFTER CARRYING OUT ENQUIRY IN THE MANNER AS DISCUSSED IN THE IMPUGNED ORDER. 3. BEFORE US, THE LD. A/R OF THE ASSESSEE HAS SUBMI TTED THAT THE IMPACT OF SECTION 145A HAS BEEN CONSIDERED BY THE ASSESSEE ON THE BASIS OF AUDIT REPORT WHICH IS EVIDENT FROM ANNEXURE D TO THE TAX AUDIT R EPORT. IN THIS ANNEXURE THE IMPACT OF SECTION 145A ON THE PROFIT HAS BEEN COMPU TED AND ACCORDINGLY, THE PROFIT HAS BEEN REDUCED TO THE EXTENT OF RS.11,04,944/-. T HE LD. PCIT HAS STATED THAT THE ASSESSEE IS NOT MAINTAINING STOCK REGISTER AND THE EFFECT OF VAT HAS BEEN TAKEN ON ESTIMATED BASIS. IT IS EXPLAINED THAT THE NATURE OF THE BUSINESS IS SUCH THAT ASSESSEE DOES NOT MAINTAIN STOCK REGISTER. HOWEVER, AT THE Y EAR END THE SAME IS DETERMINED BY THE ASSESSEE AND IS CONSIDERED IN THE BOOKS. THE ASSESSEE IS FOLLOWING THIS METHOD FROM PAST MANY YEARS AND THE IMPACT OF IS GI VEN ACCORDINGLY. IN AY 2013- 14, THERE IS ADDITION TO THE INCOME U/S 145A BY RS. 8,55,867/- AS IS EVIDENT FROM ANNEXURE C TO THE AUDIT REPORT. THUS, THE ASSESSEE HAS CORRECTLY COMPUTED THE IMPACT OF SECTION 145A ON THE PROFIT. THIS HAS ALSO BEEN CONSIDERED BY THE AO DURING THE ASSESSMENT PROCEEDINGS AS IS EVIDENT FRO M THE REPLIES FILED. THUS, IT CAN 4 ITA NO. 352/JP/2019 M/S. UNITED PLYWOOD, AJMER. BE NOTED THAT THE AO AFTER CONSIDERING THE IMPACT O F SECTION 145A ALLOWED THE CLAIM. THUS, WHEN AO HAS ALLOWED THE CLAIM OF VAT U/S 145A AFTER EXAMINING ALL THE FACTS AND CONDUCTING PROPER ENQUIRY, IT CANNOT BE SAID TH AT HE HAS NOT MADE PROPER ENQUIRY IN ALLOWING THE CLAIM. THEREFORE, THE ORDER PASSED BY AO BY NO STRETCH OF IMAGINATION CAN BE CONSIDERED AS ERRONEOUS FOR WANT OF PROPER ENQUIRY. THE LD. A/R FURTHER SUBMITTED THAT IT MAY BE NOTED THAT ASSESSE E HAS BEEN FOLLOWING THE CONSISTENT METHOD OF GIVING THE IMPACT OF SECTION 1 45A IN THE COMPUTATION OF TOTAL INCOME. AS A RESULT OF THE SAME THERE IS ADDITION T O THE INCOME IN SOME YEAR AND DEDUCTION IN SOME YEAR. THE IMPACT OF SECTION 145A IN THE COMPUTATION OF TOTAL INCOME FROM THE LAST 7 YEARS IS AS UNDER:- ASSTT. YEAR IMPACT OF SECTION 145A CONSIDERED IN RETURN OF INCOME ADDITION TO INCOME DEDUCTION TO INCOME 2007-08 5,55,070 2008-09 1,25,227 2009-10 5,87,391 2010-11 5,21,397 2011-12 4,60,259 2012-13 3,37,509 2013-14 8,55,867 2014-15 11,04,944 TOTAL 29,82,461 15,65,203 THUS, IT CAN BE NOTED THAT OVER THESE YEARS ASSESSE E HAS MADE ADDITION TO THE TOTAL INCOME U/S 145A FOR RS.29,82,461/- WHEREAS HE HAS C LAIMED DEDUCTION OF RS.15,65,203/- ONLY. IN ALL EARLIER YEARS THE WORKI NG OF THE ASSESSEE HAS BEEN ACCEPTED AND THEREFORE, THE ADJUSTMENT MADE IN THE COMPUTATION OF TOTAL INCOME FOR THE YEAR UNDER CONSIDERATION CANNOT BE HELD TO BE E RRONEOUS. THIS ADJUSTMENT IS 5 ITA NO. 352/JP/2019 M/S. UNITED PLYWOOD, AJMER. MADE AS PER THE PROVISIONS OF THE ACT, GUIDANCE NOT E ISSUED BY ICAI U/S 44AB OF IT ACT, 1961 AND DULY VERIFIED AND CERTIFIED BY THE TA X AUDITOR. HENCE, THE OBSERVATION MADE BY LD. PCIT ABOUT NON MAINTENANCE OF STOCK REC ORD IS IRRELEVANT. IN FACT THE LD. PCIT HAS NOT APPRECIATED THE MANDATE OF SECTION 145A IN HOLDING THAT ADJUSTMENT MADE BY THE ASSESSEE IS ERRONEOUS. THE L D. A/R HAS ALSO REFERRED TO THE STATEMENT OF COMPUTATION OF IMPACT OF SECTION 145A WHICH WAS FILED BEFORE THE AO AND SUBMITTED THAT THE ASSESSEE HAS COMPUTED THE AM OUNT OF RS. 11,04,944/- AFTER GIVING THE EFFECT OF VAT PAID/PAYABLE ON OPENING ST OCK, PURCHASES AND SALES AND CONSEQUENTLY THE PROFIT STAND DECREASED BY RS. 11,0 4,944/- DUE TO THE NET PAYMENT ON THE PURCHASES AND SALES DURING THE YEAR UNDER CO NSIDERATION AS WELL AS THE OPENING STOCK AS ON 1 ST APRIL, 2013. HE HAS REFERRED TO THE SUMMARY OF VAT INPUT AND VAT OUTPUT AND SUBMITTED THAT THE AVERAGE OF VA T COMES TO 3.44% BY CONSIDERING ALL THE COMPONENTS I.E. THE PURCHASES M ADE WITHIN THE STATE, PURCHASES MADE OUTSIDE THE STATE ATTRACTING CST AT 2% AND PUR CHASES HIGH SEA SALES. THE LD. A/R HAS FILED THE DETAILS OF PURCHASES AND DETAILS OF SALES WHICH ARE ATTRACTING DIFFERENT RATES OF VAT AND CST AND ALSO EXPLAINED T HE DETAILS OF SALES RETURNED, DISCOUNT ON PURCHASES ETC. THE SAID COMPUTATION SH OWN IN THE DETAILS NOW FILED ARE MATCHING WITH THE DETAILS OF THE STATEMENT COMPUTIN G IMPACT OF SECTION 145A ON THE PROFIT AS ANNEXURES C AND D TO THE AUDITED FINANCIA L STATEMENTS. THUS THE LD. A/R HAS POINTED OUT THAT ALL THE RELEVANT DETAILS WERE FILED BEFORE THE AO IN RESPONSE TO THE NOTICE UNDER SECTION 142(1) WHEREIN THE AO HAS RAISED A SPECIFIC QUERY ABOUT THE IMPACT OF SECTION 145A. HE HAS ALSO REFERRED T HE REPLY OF THE ASSESSEE DATED 30.11.2016 FILED IN RESPONSE TO THE NOTICE ISSUED B Y THE AO AND SUBMITTED THAT THE ASSESSEE HAS GIVEN THE WORKING OF IMPACT OF SECTION 145A ON THE PROFIT AND AFTER 6 ITA NO. 352/JP/2019 M/S. UNITED PLYWOOD, AJMER. CONSIDERING THE SAID REPLY AND DETAILS, THE AO WAS SATISFIED WITH THE SAID IMPACT ON THE NET PROFIT DUE TO THE SAID AMOUNT OF RS. 11,04, 944/-. THUS THE LD. A/R HAS CONTENDED THAT ONCE THE AO WAS SATISFIED WITH THE R EPLY AND THE DETAILS FILED BY THE ASSESSEE, THE LD. PCIT WAS NOT JUSTIFIED IN INVOKIN G THE PROVISIONS OF SECTION 263 OF THE ACT ON THIS ISSUE. 4. ON THE OTHER HAND, THE LD. D/R HAS SUBMITTED THA T IT IS NOT CLEAR FROM THE DETAILS AND FROM THE RECORD WHETHER THE ASSESSEE IS A TRADER OR DOING ANY MANUFACTURING ACTIVITY. THE ASSESSEE HAD ALSO NOT F ILED DETAILS BEFORE THE AO TO SHOW THE VARIOUS RATES OF VAT AND CST ON THE PARTIC ULAR PURCHASES AND SALES. THEREFORE, THE AO HAS ACCEPTED THE CLAIM WITHOUT CO NDUCTING VERIFICATION AND ENQUIRY. THIS CASE FALLS IN THE CATEGORY OF LACK O F ENQUIRY ON THE PART OF THE AO WHICH HAS RENDERED THE ORDER OF THE AO AS ERRONEOUS IN SO FAR AS PREJUDICIAL TO THE INTEREST OF THE REVENUE. HE HAS REFERRED TO THE E XPLANATION TO SECTION 263 OF THE ACT AND SUBMITTED THAT IF THE AO HAS NOT CONDUCTED A PROPER ENQUIRY THEN THE ORDER OF THE AO IS ERRONEOUS IN SO FAR AS IT IS PREJUDICI AL TO THE INTEREST OF THE REVENUE. THE LD. PCIT HAS CONSIDERED ALL THE FACTS AS WELL AS TH E REPLY FILED BY THE ASSESSEE AND FOUND THAT WHEN THE ASSESSEE IS NOT MAINTAINING THE STOCK REGISTER THEN THE CALCULATION OF THE ASSESSEE SHOWING NEGATIVE AMOUNT OF VAT AT RS. 11,04,944/- CANNOT BE VERIFIED. THUS THE CLAIM ALLOWED BY THE AO WITHOUT VERIFICATION OF THE RELEVANT FACTS RENDERS THE ORDER OF THE AO ERRONEOU S. HE HAS SUPPORTED THE IMPUGNED REVISION ORDER OF THE LD. PCIT. 5. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WELL AS THE RELEVANT MATERIAL ON RECORD. SO FAR AS THE ORDER PASSED BY THE AO WITHOU T CONDUCTING DUE ENQUIRY, THE SAME WOULD BE ERRONEOUS FOR WANT OF ENQUIRY AND, TH EREFORE, THERE IS NO QUARREL ON 7 ITA NO. 352/JP/2019 M/S. UNITED PLYWOOD, AJMER. THIS POINT THAT THE LACK OF ENQUIRY ON THE PART OF THE AO WOULD RENDER THE ORDER PASSED BY THE AO AS ERRONEOUS IN SO FAR AS IT IS PR EJUDICIAL TO THE INTEREST OF THE REVENUE. HOWEVER, IN THE CASE IN HAND, THE AO HAS I SSUED THE NOTICE RAISING THE QUERY REGARDING THE VALUATION OF CLOSING STOCK AND OPENING STOCK BY GIVING EFFECT OF SECTION 145A OF THE ACT ON ACCOUNT OF VAT. THE ASS ESSEE IN ITS REPLY DATED 30.11.2016 FURNISHED THE DETAILS OF WORKING OF IMPA CT OF SECTION 145A DUE TO HIGHER PAYMENT OF VAT AND MORE IMPACT IN THE OPENING STOCK AS ON 1 ST APRIL, 2013 IN COMPARISON TO THE CLOSING STOCK AS ON 31 ST MARCH, 2014. WE FURTHER NOTE THAT THE ASSESSEE ALSO PRODUCED THE STATEMENT OF IMPACT OF S ECTION 145A ON THE PROFIT AS ANNEXURES C & D TO THE FINANCIAL STATEMENTS WHEREIN THE SUMMARY OF VAT INPUT AND VAT OUTPUT FOR THE ASSESSMENT YEARS 2013-14 AND 201 4-15 WERE GIVEN ALONG WITH THE CALCULATION OF VAT ON CLOSING STOCK. THUS BY C ONSIDERING ALL THESE FACTS, WE ARE SATISFIED THAT IT IS NOT A CASE OF COMPLETE LACK OF ENQUIRY BY THE AO. HOWEVER, THE AO HAS ACCEPTED THE CLAIM OF THE ASSESSEE WITHOUT G OING INTO THE DEEP DETAILS OF THE COMPUTATION OF VAT IMPACT AND VALUATION OF CLOSING STOCK. THEREFORE, THE CORRECTNESS OF THESE DETAILS WERE NOT UNDERTAKEN FO R VERIFICATION BY THE AO BUT ONCE THE ASSESSEE HAS FILED THESE DETAILS IN RESPONSE TO THE NOTICE WHICH WERE ACCEPTED BY THE AO, THEN THE CASE WILL NOT FALL IN THE CATEG ORY OF LACK OF ENQUIRY. THE LD. PCIT WHILE ASSUMING THE JURISDICTION UNDER SECTION 263 H AS PROCEEDED ON THE ASSUMPTION THAT THE REDUCTION OF PROFIT BY A SUM OF RS. 11,04, 944/- ON ACCOUNT OF EFFECT OF SECTION 145A IS NOT ALLOWABLE. DURING THE PROCEEDI NGS UNDER SECTION 263, THE LD. PCIT HAS GIVEN THE EMPHASIS ONLY ON THE POINT THAT THE ASSESSEE IS NOT MAINTAINING STOCK REGISTER. HOWEVER, THE DETAILS FILED BY THE A SSESSEE BEFORE THE AO WERE NOT EXAMINED BY THE LD. PCIT. THEREFORE, THE LD. PCIT H AS NOT POINTED OUT THE DEFECTS IN 8 ITA NO. 352/JP/2019 M/S. UNITED PLYWOOD, AJMER. THE COMPUTATION AND CALCULATION MADE BY THE ASSESSE E AS PER ANNEXURES C & D TO THE FINANCIAL STATEMENTS. THUS THE IMPUGNED ORDER PASSED BY THE LD. PCIT IS BASED ONLY ON THE ASSUMPTION AND PRESUMPTION WITHOUT GOIN G INTO THE FACTUAL ASPECTS OF CORRECTNESS OF THE VARIOUS DETAILS PRODUCED BY THE ASSESSEE. THE LD. A/R HAS PRODUCED FURTHER BIFURCATION OF PURCHASES ATTRACTIN G THE CST & VAT AT DIFFERENT RATES AND HAS COMPUTED THE AVERAGE VAT ON TOTAL PURCHASES @ 3.22%, THE DETAILS AS PRODUCED BY THE LD. A/R ARE AS UNDER :- PARTICULARS AMOUNT IN RS. 2% CST PURCHASE 14,91,96,892 PURCHASE E - 1 TRANSIT SALES 5,61,84,628 14% VAT PURCHASES 5,84,72,396 5% VAT PURCHASES 6,33,312 PURCHASES HIGH SEA SALES 3,69,312 26,48,56,541 LESS : DISCOUNTS/CLAIMS 94,34,610 NET PURCHASES 25,54,21,931 VAT PAID ON PURCHASES : 82,17,801.07 AVERAGE VAT RATE ON TOTAL PURCHASES : 3.22% IN VIEW OF THESE FACTS AND CIRCUMSTANCES, WE FIND T HAT WHEN THE ASSESEE IS ONLY A TRADER IN THE PLYWOOD AND NOT A MANUFACTURER, THEN MAINTAINING A STOCK REGISTER IS NOT MANDATORY AND EVEN NOT POSSIBLE TO SHOW ALL DET AILS OF DAILY PURCHASE AND SALE. ONCE THE ASSESSEE HAS GIVEN THE DETAILS OF OPENING STOCK WHICH IS NOT IN DISPUTE, PURCHASE, SALES AND THEN COMPUTING THE CLOSING STOC K AFTER GIVING EFFECT TO SECTION 145A NOT A MATTER OF DISPUTE THOUGH THE CORRECTNESS OF SUCH COMPUTATION AND DETAILS FURNISHED BY THE ASSESSEE IS REQUIRED TO BE VERIFIED. ACCORDINGLY, WE MODIFY THE IMPUGNED ORDER PASSED BY THE LD. PCIT UNDER SEC TION 263 AND DIRECT THE AO TO 9 ITA NO. 352/JP/2019 M/S. UNITED PLYWOOD, AJMER. VERIFY THE CORRECTNESS OF THE COMPUTATION AND DETAI LS FILED BY THE ASSESSEE AND THEN DECIDE THE ISSUE AFRESH AFTER GIVING AN OPPORTUNITY OF HEARING TO THE ASSESSEE. 6. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 08/08/2019. SD/- SD/- FOE FLAG ;KNO FOT; IKY JKWO (VIKRAM SINGH YADAV) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 08/08/2019. DAS/ VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT-M/S. UNITED PLYWOOD, AJMER. 2. IZR;FKHZ@ THE RESPONDENT-THE PR. CIT, AJMER. 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. 352/JP/2019} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR