SHRI LALIT KUMAR GUPTA, JAIPUR V. INCOME TAX OFFICER, JAIPUR

ITA 395/JPR/2018

• Counselvise Citation: [2018] 125 COUNSELVISE.COM (IT) 0240 (ITAT-JAIPUR)
• Duration Of Justice: 5 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-09-2018
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2009-2010
• Appeal Filed On: 28-03-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: J C KULHARI
• Assessee Lawyers: S K SHARMA
• Keywords: Salary income; Opportunity of being heard; Cost of acquisition; Corroborative evidences; Valuation report; Reason to believe
• Section: 148

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 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. 395/JP/2018 FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2009-10 LALIT KUMAR GUPTA, PLOT NO. 12, RAMESWAR DHAM, OPP. KEDIA PALACE, MURLIPURA, JAIPUR CUKE VS. INCOME TAX OFFICER WARD 5(4), JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: ABRPG5969Q VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI S. K. SHARMA (CA) JKTLO DH VKSJ LS @ REVENUE BY : SHRI J. C. KULHARI (JCIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 10/09/2018 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 14/09/2018 VKNS'K@ ORDER PER: VIKRAM SINGH YADAV, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST TH E ORDER OF LD. CIT(A)-2, JAIPUR DATED 25.01.2018 FOR ASSESSMEN T YEAR 2009-10 WHEREIN THE ASSESSEE HAS RAISED FOLLOWING GROUNDS O F APPEAL:- ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LEARNED CIT (A) HAS ERRED:- 1. IN NOT TREATING THE NOTICE ISSUED U/S 148 ILLEGAL A ND VOID-AB-INITIO. 2. IN PARTLY DISALLOWING THE COST OF CONSTRUCTION AMOU NTING TO RS. 1,80,150/- MERELY ON ACCOUNT OF NON PRODUCING OF TH E CONTRACTOR ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 2 AND THE SOURCES OF CONSTRUCTION WERE NOT EXPLAINED. FURTHER, THE REPORT OF APPROVED VALUER WAS ALSO NOT ACCEPTED. 2. IN GROUND NO. 1, THE ASSESSEE HAS CHALLENGED THE ISSUANCE OF NOTICE U/S 148 OF THE ACT. 3. BRIEFLY STATED, THE FACTS OF THE CASE ARE THAT THE ASSESSEE FILED HIS RETURN OF INCOME ON 29.07.2009 WHICH WAS PROCESSED U/S 143(1) OF THE ACT. THEREAFTER, THE NOTICE U/S 148 WAS ISSUED ON 3 0.03.2016 WHICH READS AS UNDER:- AS PER AIR INFORMATION FOR THE FY 2008-09, THE AS SESSEE HAS SOLD IMMOVABLE PROPERTY FOR RS. 7,00,000/- AND FROM VERI FICATION OF THE INCOME TAX RETURN, IT IS FOUND THAT ASSESSEE HAS D ECLARED THE ONLY SALARY INCOME AND HAS NOT DECLARED ANY CAPITAL GAIN /LOSS IN THE ORIGINAL RETURN FILED AS ON 29.07.2009. 4. THE LD. AR HAS CONTENDED THAT THE ASSESSEE HAS FILE D THE RETURN PURSUANT TO ISSUANCE OF NOTICE U/S 148 ALONG WITH I TS LETTER DATED 10.06.2016 AND IT WAS SUBMITTED THAT THE AO DID NOT SUPPLY THE REASONS RECORDED EITHER AT THE STAGE OF ASSESSMENT PROCEEDI NGS OR EVEN AFTER COMPLETION OF ASSESSMENT PROCEEDINGS WHICH SHOWS TH E INVALIDITY OF THE REOPENING PROCEEDINGS INITIATED BY THE AO. IN SUPPO RT, RELIANCE WAS PLACED ON THE DECISION OF HONBLE SUPREME COURT IN CASE OF G.K.N DRIVESHAFTS (INDIA) LTD. VS. ITO (2003) 259 ITR 19 (SC). IT WAS FURTHER CONTENDED THAT THE AO HAS NOT MENTIONED THE AMOUNT OF INCOME WHICH HAS ESCAPED ASSESSMENT AND MERELY STATING THAT THE SALE OF THE PROPERTY HAS BEEN MADE BY THE ASSESSEE CANNOT BE TH E REASON TO BELIEVE THAT INCOME HAS ESCAPED ASSESSMENT. IT WAS SUBMITTED THAT BEFORE INVOKING SECTION 147, THE AO MUST HAVE REASO N TO BELIEVE AND ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 3 NOT REASON TO SUSPECT THAT INCOME CHARGEABLE TO TAX HAS ESCAPED ASSESSMENT AND IT WAS SUBMITTED THAT ONLY REASON SO RECORDED BY THE AO IS THAT THE ASSESSEE HAS NOT DECLARED ANY CAPITA L GAIN/ LOSS IN THE ORIGINAL RETURN WHICH SHOWS THAT THE AO WAS NOT CON FIDENT ABOUT THE CAPITAL GAIN WHICH HAS ESCAPED TAXATION. 5. THE LD. DR IS HEARD WHO HAS RELIED ON THE ORDER OF THE LOWER AUTHORITIES. 6. WE HAVE HEARD THE RIVAL CONTENTIONS AND PURUSED THE MATERIAL AVAILABLE ON RECORD. WE FIND THAT THERE IS NOTHING ON RECORD WHICH SHOWS THAT THE ASSESSEE HAS SOUGHT THE REASONS SO R ECORDED BY THE AO BEFORE ISSUING OF THE NOTICE U/S 148 OF THE ACT DUR ING THE COURSE OF ASSESSMENT PROCEEDINGS. THEREFORE, THE DECISION OF THE SUPREME COURT SO RELIED BY THE LD. AR DOES NOT SUPPORT THE CASE O F THE ASSESSEE AS THE SAID DECISION CAN COME TO THE ASSISTANCE OF THE ASS ESSEE ONLY WHEN THE ASSESSEE HAS SOUGHT THE REASONS AND THE AO HAS FAIL ED TO SUPPLY THE REASONS SO RECORDED. THEREFORE, MERELY NOT SUPPLY OF THE REASONS CANNOT BE BASIS TO INVALIDATE THE PRESENT PROCEEDIN GS. FURTHER, THE FACT OF THE SALE OF THE IMMOVABLE PROPERTY FOR RS. 7,000 ,00/- AND THE FACT THAT SALE OF PROPERTY ATTRACTS CAPITAL GAINS HAS NO T BEEN DISPUTED BY THE ASSESSEE AND THEREFORE, THERE IS A LIVE LINK AND NE XUS FOR FORMATION OF A PRIMA FACIE BELIEF THAT THE INCOME FROM SALE OF THE SAID PROPERTY HAS ESCAPED ASSESSMENT. IN TERMS OF QUANTIFYING THE EXA CT AMOUNT OF CAPITAL GAINS WHICH HAS ESCAPED ASSESSMENT, THE SAM E IS MATTER OF DETAIL EXAMINATION AND THE SAME CANNOT BE TAKEN AS A BASIS FOR CHALLENGING THE JURISDICTION OF THE AO U/S 148 OF T HE ACT. THE DECISION RELIED UPON BY THE LD AR ARE DISTINGUISHABLE ON FAC TS AND THUS DOESNT ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 4 SUPPORT THE CASE OF THE ASSESSEE. IN THE RESULT GR OUND NO. 1 OF THE ASSESSEE IS DISMISSED. 7. REGARDING GROUND NO. 2, THE LD. AR HAS SUBMITTED THAT THE LD. CIT(A) GROSSLY ERRED IN CONFIRMING THE ADDITION OF RS. 1,8 0,150/- TOWARDS COST OF CONSTRUCTION IN THE F.Y. 1997-98 WITHOUT CONSIDE RING THE SUBMISSION AND DOCUMENTARY EVIDENCE, FOR THE FOLLOWING REASONS : IT IS EVIDENT FROM THE ALLOTMENT LETTER ISSUED BY T HE RHB ALONGWITH MAP ANNEXED THERETO THAT ONE ROOM, KITCHE N AND LAT-BATH WERE CONSTRUCTED BY THE RHB. THIS ACCOMMOD ATION WAS NOT SUFFICIENT FOR THE FAMILY OF THE APPELLANT, THEREFORE BY DISMANTLING/ MODIFYING THE EXISTING CONSTRUCTION THE APPELLANT CONSTRUCTED GROUND FLOOR, FIRST FLOOR AND A SINGLE ROOM AND LAT-BATH ON SECOND FLOOR. THESE FACTS ARE AVAILABLE IN THE SALE DEED AND MAP ATTACHED THEREWITH SOME OF THE CONTENTS ARE REPRODUCED HEREIN BELOW: AT PAGE NO. 2 OF SALE DEED MDR EDKU ESA ESAUS XZKM.M Q~YKSJ] QLVZ Q~~YKSJ O LS FD.M Q~~YKSJ IJ ,D DEJK O YSVCKFK DK FUEKZ.K DJOKDJ UY FCTYH DS DUSDKU VIUS UKE LS IZKIR DJ FY;S FKSA AT PAGE NO. 5 OF SALE DEED MDR EDKU ESA FD;K X;K FUEKZ.K DK;Z 11&12 OKZ IQJKU K GS FTLDK DQY DOMZ ,FJ;K 1050 OXZ QQV GS THE ABOVE FACTS SHOW THAT THE PROPERTY SOLD CONSIST OF GROUND FLOOR, FIRST FLOOR AND A SINGLE ROOM AND LAT -BATH ON SECOND FLOOR AND CONSTRUCTION WAS 11-12 YEARS OLD. THE ASSESSEE SUBMITTED A BILL OF CONTRACTOR (COPY OF WH ICH IS ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 5 PLACED AT PAGE NO. 7 OF PB), PERUSAL OF THE BILL SH OWS THAT THE NAME OF CONTRACTOR IS SHRAWAN LAL AND HIS FATHE R'S NAME IS RAM CHANDRA R/O LALSOT. THE APPELLANT IS NOT IN TOUCH AFTER COMPLETION OF CONSTRUCTION OF HOUSE AND MAKIN G PAYMENT TO HIM AFTER FINAL BILL, THEREFORE HE COULD NOT BE PRODUCED BEFORE THE AO AFTER 18 YEARS. THE APPELLAN T HAD GIVEN IN WRITING TO REFER THE MATTER TO THE DVO BUT THE AO WAS IN VERY HURRY TO COMPLETE THE ASSESSMENT. (COPY OF LETTER IS PLACED AT PAGE 8 OF PB.) THE EVIDENCE RELATING TO SOURCE OF CONSTRUCTION OF 18 YEARS OLD WAS NOT PRACTICABLE / FEASIBLE. THE BANK REFUSE D TO SUPPLY THE STATEMENT OF THAT TIME BEING TIME BARRED. UPTO F.Y. 2005- 06 SALARY WAS RECEIVED IN CASH FROM THE GOVERNMENT. THE LD. CIT(A) IGNORED THE ACCUMULATED PAST SAVINGS OF THE APPELLANT AS MENTIONED IN THE LETTER FILED BEFORE THE AO. SO FAR AS LOANS FROM FRIENDS AND RELATIVES ARE CONCERNED THESE LOAN S WERE SHORT TERM / TEMPORARY LOANS AND THE SAME HAD BEEN PAID OUT AND NO OUTSTANDING TILL THE DATE OF SALE. THE APPEL LANT WAS WORKING IN RAJASTHAN STATE ELECTRICITY BOARD SINCE 1978 THEREFORE PAST ACCUMULATED SAVINGS CANNOT BE IGNORE D. YOUR GOODSELF WILL APPRECIATE THAT ASSESSEE DRAWN T HE SALARY OF RS. 2,72,721/- IN THE YEAR UNDER CONSIDERATION F ROM JVVNL WHICH IS EVIDENT FROM THE FORM-16 AND IT IS ALSO EV IDENT FROM THE RETURN OF INCOME FILLED BY ASSESSEE ON 29.07.09 KINDLY REFER PAGE NO. 6 OF PB. IT IS ALSO PERTINENT TO NOT E THAT ASSESSEE DRAWN THE SALARY OF RS. 3,78,318/- IN A.Y. 2016-17 KINDLY REFER PAGE NO. 10 OF PB,- IT SHOWS THAT ASSE SSEE WAS ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 6 VERY MUCH IN CAPACITY TO INVEST SUCH A MEAGER AMOUN T OF RS. 3,15,820/- IN PHASES. IT IS FURTHERER SUBMITTED THA T SUFFICIENT EVIDENCE IS AVAILABLE IN THE SALE DEED AS WELL AS F ROM THE ESTIMATION MADE BY THE APPROVED VALUER. THE HOUSE WHICH HAD BEEN ALLOTTED BY RHB CONSISTS O F ONE ROOM, KITCHEN AND LAT-BATH. THE QUALITY OF CONSTRUC TION WAS SO POOR THAT THE CONSTRUCTION OF FURTHER FLOORS THE REON MIGHT BE DANGEROUS IN ADDITION THERETO THE BUILDINGS WERE CONSTRUCTED IN UNIFORM MANNER THEREFORE ACCORDING T O THE NEEDS OF THE FAMILY THE APPELLANT DEMOLISHED/MODIFI ED THE BUILDING ALLOTTED BY RHB. THE DEMOLITION WORD DOES NOT EXIST IN THE ASSESSMENT ORDER BUT THE LD. CIT(A) USED AGA INST THE APPELLANT FROM THE LETTERS SUBMITTED BEFORE THE AO FILED IN PAPER BOOK FILED BEFORE CIT(A). THE VALUATION REPORT (KINDLY REFER PAGE NO. 11 TO 2 9 OF PB) WAS NOT ACCEPTED BY THE LD. CIT(A) BECAUSE NO REASO N FOR NOT SUBMITTING BEFORE AO WAS SUBMITTED. IN THIS REG ARD WE REPRODUCE THE RELEVANT PORTION OF THE WRITTEN SUBMI SSION FILED BEFORE THE LD. CIT(A) AS UNDER 'IT IS SUBMITTED THAT THE AO FOR THE BEST REASON KN OWN TO HIM NOT ALLOWED THE TIME TO SUBMIT THE SUPPORTING EVIDENCE, IT IS THEREFORE PRAYED THAT VALUATION REP ORT FILLED NOW MAY KINDLY BE CONSIDERED AFTER ACCEPTING THE SA ME U/ R 46A OF THE INCOME TAX RULES, 1962. NOW WE ARE PRODUCING THROUGH THE FOLLOWING TABLE WH ICH SHOWS THAT HOW THE LD. AO WAS IN HURRIEDNESS IN COM PLETION OF THE ASSESSMENT. ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 7 S. NO. DESCRIPTION OF NOTICE/ LETTER DATE OF NOTICE / LETTER DATE FIXED IN THE NOTICE PERIOD (TIME ALLOWED BY AO) 1 NOTICE U/S 148 ISSUED BY THE AO 30.03.16 ONE MONTH 2 LETTER FOR CALLING INFORMATION ISSUED BY THE AO 02.06.16 09.06.16 7 DAYS 3 ASSESSEE FILEDITR AND THE OTHER DETAILS IN RESPONSE TO LETTER DATED 02.06.16 10.06.16 4 SHOW CAUSE LETTER ISSUED BY THE AO 20.06.16 24.06.16 4 DAYS 5 ASSESSEE FILED REPLY OF SHOW CAUSE LETTER 24.06.16 6 NOTICE U/S 143(2) ISSUED BY THE AO 22.07.16 29.07.16 7 DAYS 7 ASSESSMENT ORDER PASSED 29.07.16 IT IS SUBMITTED THAT THE ASSESSE WAS ISSUED NOTICE U/S 148 ON 30/03/2016 AND ASSESSMENT PROCEEDINGS WERE STARTED FROM NOTICE U/S 143(2) DATED 22/07/2016 FOR FIXING THE HEARING ON 2 9/07/2016. ASSESSMENT WAS COMPLETED ON THE SAME DATE. IT IS EV IDENT FROM THE ORDER AND LAST NOTICE U/S 143(2) DATED 22/07/2016 I N WHICH CASE WAS FIXED FOR 29/07/2016 AND ON THE SAME DAY THE ASSESS MENT WAS COMPLETED THUS THE ASSESSEE WAS NOT PROVIDED PROPER OPPORTUNITY OF BEING HEARD. CONSIDERING THE FACTS THE LD. CIT(A) E RRED IN NOT ACCEPTING THE VALUATION REPORT UNDER RULE 46A OF THE INCOME T AX RULES, 1962. ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 8 8.THE FINDINGS OF THE LD. CIT(A) ARE AT PARA 3.3 WH ICH IS REPRODUCED AS UNDER:- 3.3 I HAVE PERUSED THE FACTS OF THE CASE, THE ASSE SSMENT ORDER AND THE SUBMISSIONS OF THE APPELLANT. THE AO NOTED THAT THE APPELLANT HAD PURCHASED THE PROPERTY FROM RAJASTHAN HOUSING BOARD AND BESIDES CLAIMING THE COST OF LAND HAD ALSO CLAIMED COST OF CONSTRUCTION AT RS. 1,35,670/- IN ASSESSMENT YEAR 1996-97 AND RS. 1,80, 150/- IN FINANCIAL YEAR 1997-98 WHICH AFTER INDEXATION STOOD AT RS. 5, 75,644/-. THE APPELLANT COULD NOT PRODUCE THE DETAILS OF CONSTRUC TION EXCEPT A BILL OF A CONTRACTOR ON A PLAIN PAPER BUT WAS UNABLE TO PROVI DE THE COMPLETE POSTAL ADDRESS OF THE CONTRACTOR FOR VERIFICATION. FURTHER, THE SOURCES FOR SUCH CONSTRUCTION WERE ALSO NOT EXPLAINED AND IT WA S STATED THAT THE SAME WERE FILED. THE AR FURTHER SUBMITTED THAT THE SALE DEED RECORDS THE CONSTRUCTION OF GROUND, 1 ST AND 2 ND FLOOR AND HENCE THE SAME SHOULD BE ALLOWED. IT IS SEEN THAT THE RHB HAS CHARGED AN AMOUNT OF RS. 59,366/- FOR CONSTRUCTION AND THE MAP ANNEXED ALSO SHOWS CONSTRUCTION ON THE GROUND FLOOR. HOWEVER, IT IS SUBMITTED THAT THE SAME WAS DEMOLISHED BUT NO EVIDENCE FOR THIS DEMOLITION HAS BEEN PRODUCED. FURTHER NO EVIDENCE FOR COST OF CONSTRUCTION AND SO URCES OF CONSTRUCTION HAVE BEEN FILED. IN THE PRESENT PROCEEDINGS A REPOR T OF THE APPROVED VALUER WAS FILED BUT NO REASONS FOR NOT SUBMITTING IT BEFORE THE AO HAVE BEEN SUBMITTED AND THE SAME CANNOT BE ACCEPTED AT T HIS STAGE. FURTHER AS SOME CONSTRUCTION OVER AND ABOVE THE CONSTRUCTIO N TO THE PROPERTY PURCHASED FROM RHB WOULD HAVE BEEN MADE, THE COST O F CONSTRUCTION OF RS. 1,35,670/- IN FINANCIAL YEAR 1996-97 IS ALLOWED . THE BALANCE COST OF CONSTRUCTION DISALLOWED BY THE AO IS CONFIRMED. GRO UND OF APPEAL IS PARTLY ALLOWED. THE AR ALSO SUBMITTED THAT THE FIGU RE OF COST OF ACQUISITION TAKEN BY THE AO AT RS. 62,246/- IS INCO RRECT AS THE CORRECT ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 9 COST AS PER THE CERTIFICATE OF THE RAJASTHAN HOUSIN G BOARD IS RS. 85,346/- THE SUBMISSION OF THE AR APPEARS CORRECT, AO TO VERIFY AND MODIFY ACCORDINGLY. 9. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. ON PERUSAL OF THE SALE DEED, I T IS NOTED THAT THE PROPERTY SALE CONSIST OF GROUND FLOOR, 1 ST FLOOR AND A ROOM WITH ATTACHED TOILET AND BATHROOM ON THE 2 ND FLOOR. REGARDING COST OF CONSTRUCTION, THE ASSESSEE HAS SUBMITTED THAT SINCE THE CONSTRUCTION WAS CARRIED OUT COUPLE OF YEARS BACK, IT WAS NOT FEASIBLE TO PRODUC E THE CONTRACTOR OR THE RELEVANT RECORDS, HOWEVER, A VALUATION REPORT H AS BEEN SUBMITTED WHICH HAS NOT BEEN CONSIDERED BY THE LOWER AUTHORIT IES. WE FIND MERIT IN THE CONTENTION OF THE LD AR AND DEEM IT APPROPRI ATE THAT THE VALUATION REPORT SO SUBMITTED BY THE ASSESSEE BE EX AMINED AND THE MATTER RELATING TO COST OF CONSTRUCTION BE EXAMINED A FRESH AFTER CONSIDERING THE VALUATION REPORT. WE ACCORDINGLY R EMAND THE MATTER TO THE FILE OF THE LD. CIT(A) WHO SHALL EXAMINE THE SA ID VALUATION REPORT AFTER PROVIDING REASONABLE OPPORTUNITY TO THE ASSES SEE. IN THE RESULT, GROUND IS ALLOWED FOR STATISTICAL PURPOSES. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOWE D FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 14/09/2018. SD/- SD/- FOT; IKY JKO FOE FLAG ;KNO (VIJAY PAL RAO) (VIKRAM SINGH YADAV) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER ITA NO. 395/JP/2018 SHRI LALIT KUMAR GUPTA, JAIPUR VS. ITO, JAIP UR 10 TK;IQJ@ JAIPUR FNUKAD@ DATED:- 14/09/2018 * GANESH KR VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- LALIT KUMAR GUPTA, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- ITO, 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. 395/JP/2018} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR