M/S SHRI DASHRATH BALAI, JAIPUR V. INCOME TAX OFFICER, JAIPUR

ITA 427/JPR/2018

• Counselvise Citation: [2019] 113 COUNSELVISE.COM (IT) 6343 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 7 month(s) 3 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 06-11-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2007-2008
• Appeal Filed On: 03-04-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ABHISHEK SHARMA CIT DHK
• Assessee Lawyers: S K GOGRA
• Keywords: Unexplained investment; Search and seizure; Opportunity of being heard; Set aside
• Section: 143(3); 148; 144

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCH SMC, JAIPUR JH FOT; IKY JKWO] U;KF;D LNL; DS LE{K BEFORE: SHRI SHRI VIJAY PAL RAO, JUDICIAL MEMBER VK;DJ VIHY LA-@ ITA NO. 427/JP/2018 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2007-08. SHRI DASHRATH BALAI, S/O SHRI SHARWAN LAL BALAI, B-60, GANGA SAGAR COLONY, VAISHALI NAGAR, JAIPUR. CUKE VS. THE INCOME TAX OFFICER, WARD 4(3), JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. ANSPV 0185 E VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI S.K. GOGRA (CA) JKTLO DH VKSJ LS@ REVENUE BY : SHRI ABHISHEK SHARMA (ADDL. CIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 03.10.2019. ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 06/11/2019. VKNS'K@ ORDER PER VIJAY PAL RAO, JM : THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST TH E ORDER DATED 22.01.2018 OF LD. CIT (APPEALS), AJMER FOR THE ASSESSMENT YEAR 20 07-08. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS OF APPEAL :- 1. THAT LD.AO HAS ERRED IN PASSING OF BEST JUDGME NT ASSESSMENT ORDER U/S 144 READ WITH SECTION 148 WHICH MAY PLEAS E BE DECLARED AS ILLEGAL AND BE SET ASIDE. THERE IS NO REAL OPPORTUNITY OF BEING HEARD WAS PROVIDED TO APPELLAN T AND ALL NOTICES WERE BEING SENT AT JAIPUR ADDRESS OF WHICH HE WAS NOT AT ALL AWARE WHEREAS HIS ACTUAL AND CORRECT ADDRESS IS OF 42KHA, BALAI MOHALLA, MUNDIYAGADH, THE: PHULERA, DISTT: JA IPUR ON SUPPORT OF SAME COPY OF ELECTION CARD NO.:R1/13/045 /65155 WAS SUBMITTED. 2. THAT LD. AO HAS ERRED IN TREATING TRANSACTION OF PURCHASE OF AGRICULTURAL LAND SITUATED AT KHASRA NO.: 64, 65, 6 8, 69, 70, 72, 2 ITA NO. 427/JP/2018 SHRI DASHRATH BALAI, JAIPUR. 73, 74/553 TOTAL 08 KITA TOTAL RAKBA 1.84 PURCHASED BY MR. RATAN LAL RANKA THROUGH REGISTERED SALE DEED, REGIS TERED WITH SUB REGISTRAR JAIPUR-VII, JAIPUR VIDE REGN. NO.: 20 0740000050 DT. 6.2.2007 FOR RS. 27,27,000/- + REGISTRATION CHA RGES RS. 2,16,100/- AND FOR WHICH PAYMENT WAS MADE BY MR. RA TAN LAL RANKA AND WAS PROPERTY SHOWN IN HIS BOOKS OF ACCOUN TS AND IN INCOME TAX RETURNS ALSO. THAT THIS LAND WAS SURREND ERED BY MR. RATAN LAL RANKA IN SEARCH PROCEEDINGS AS UNDERTAKEN BY I.T. DEPARTMENT ON DT. 24.8.2006 AND IN WHICH ENTIRE TRA NSACTION IN LAND WAS SURRENDERED AND COPY OF ALL THESE RELEVANT SEARCH RECORDS AND DOCUMENTS HAVE ALSO BEEN SUBMITTED. THU S BOTH THE LOWER AUTHORITIES HAS ERRED IN NOT PROPER APPRE CIATING THE FACTS OF THE CASE WHICH MAY PLEASE BE DECLARED AS I LLEGAL & UNJUSTIFIED IN THE FACTS & CIRCUMSTANCES OF THE CAS E. 3. THAT LD. AO HAS ERRED IN NOT APPRECIATING THE AF FIDAVITS OF MR. RATAN LAL RANKA, SEARCH STATEMENTS & SEARCH RECORDS , INCOME TAX RETURNS OF MR. RATAN LAL RANKA, BANK ACCOUNT ST ATEMENTS, AFFIDAVIT OF MR. BHAGWAN SAHAI MEENA AND SALE DEED IN WHICH INVARIABLY IT HAS BEEN WRITTEN THAT PURCHASE PAYMEN T HAS ALREADY BEEN GIVEN THROUGH MR. BHAGWAN SAHAI MEENA. THUS WITHOUT APPRECIATING THESE CRUCIAL FACTS OF CASE AD DITION IN TO TOTAL INCOME IS A GROSSLY ERRONEOUS ACTION ON PART OF BOTH THE LOWER AUTHORITIES WHICH MAY PLEASE BE DECLARED AS I LLEGAL & UNJUSTIFIED IN THE FACTS & CIRCUMSTANCES OF THE CAS E. 4. THAT THE APPELLANT CRAVES LEAVE TO ADD, AMEND OR ALTER ANY OF THE GROUND TO THIS APPEAL WITH THE REQUEST TO ALLOW TO SUBMIT WRITTEN SUBMISSION AT THE TIME OF HEARING OF APPEAL . 2. THE AO WHILE PASSING THE ASSESSMENT ORDER UNDER SECTION 148 READ WITH SECTION 144 OF THE ACT ON 27.03.2015 MADE AN ADDITI ON OF RS. 29,18,360/- ON ACCOUNT OF UNEXPLAINED INVESTMENT IN THE LAND SITUA TED AT VILLAGE CHATARPURA, DANTLI, TEHSIL SANGANER, DISTRICT JAIPUR VIDE REGISTERED SA LE DEED DATED 27 TH JANUARY, 2007. SINCE THE ASSESSEE DID NOT APPEAR BEFORE THE AO AND NO DETAILS OR REPLY WAS FILED, THEREFORE, THE AO PASSED THE ASSESSMENT ORDER UNDER SECTION 144. BEFORE THE LD. CIT (A), THE ASSESSEE HAS SUBMITTED THAT THE PROPERTY W AS PURCHASED BY ONE SHRI RATAN 3 ITA NO. 427/JP/2018 SHRI DASHRATH BALAI, JAIPUR. LAL RANKA IN THE NAME OF THE ASSESSEE AND SHRI RANK A ALSO DISCLOSED THE INCOME DURING THE SEARCH AND SEIZURE PROCEEDINGS WHICH INC LUDES THE UNDISCLOSED INVESTMENT IN THE SAID PROPERTY. HOWEVER, THE LD. CIT (A) DID NOT ACCEPT THIS CONTENTION OF THE ASSESSEE ON THE GROUND THAT THERE IS NO MENTION ABOUT THIS PARTICULAR PROPERTY IN THE STATEMENT OF SHRI RATAN LAL RANKA RECORDED UNDER SECTION 132(4) OF THE IT ACT. 3. BEFORE THE TRIBUNAL, THE LD. A/R OF THE ASSESSEE HAS REITERATED HIS CONTENTION THAT THE PROPERTY WAS ACTUALLY PURCHASED BY SHRI RA TAN LAL RANKA IN THE NAME OF THE ASSESSEE AND SUBSEQUENTLY THE SAID PROPERTY WAS SOL D BY SHRI RANKA DURING THE FINANCIAL YEAR 2009-10 AND OFFERED TO TAX FOR THE A SSESSMENT YEAR 2010-11. THE LD. A/R HAS FILED THE COPY OF THE ASSESSMENT ORDER DATE D 30.12.2017 IN CASE OF SHRI RATAN LAL RANKA PASSED UNDER SECTION 147/143(3) FOR THE ASSESSMENT YEAR 2010-11. THUS THE LD. A/R HAS CONTENDED THAT ONCE THE AO HAS MADE THE SUBSTANTIVE ADDITION OF INCOME ARISING FROM SALE OF THE SAME PROPERTY IN THE HANDS OF SHRI RATAN LAL RANKA, THEN THE ADDITION ON ACCOUNT OF UNEXPLAINED INVESTMENT IN THE SAME PROPERTY CANNOT BE MADE IN THE HANDS OF THE ASSESSEE. THUS THE LD. A/R HAS PRAYED THAT THE ADDITION MADE BY THE AO AND CONFIRMED BY THE LD. CI T (A) MAY BE DELETED. 4. ON THE OTHER HAND, THE LD. D/R HAS RELIED UPON T HE ORDERS OF THE AUTHORITIES BELOW AND SUBMITTED THAT THE LD. CIT (A) HAS CONSID ERED ALL THESE CONTENTIONS OF THE ASSESSEE AND GIVEN THE FINDING THAT THERE IS NO MEN TION ABOUT THE UNEXPLAINED INCOME IN THE PROPERTY IN QUESTION BY SHRI RATAN LA L RANKA WHILE MAKING STATEMENT UNDER SECTION 132(4) OF THE ACT. FURTHER, FOR THE A SSESSMENT YEAR 2010-11 THE AO HAS ALSO MADE AN ADDITION IN THE HANDS OF THE ASSES SEE THOUGH ON PROTECTIVE BASIS 4 ITA NO. 427/JP/2018 SHRI DASHRATH BALAI, JAIPUR. AS SUBSTANTIVE ADDITION WAS MADE IN THE HANDS OF SH RI RATAN LAL RANKA. THUS THE LD. D/R HAS SUBMITTED THAT UNTIL AND UNLESS THE ISSUE A TTAINS THE FINALITY AS TO WHO TAKES THE ONUS OF INVESTMENT AND ALSO SALE OF THE PROPERT Y IN QUESTION, IT CANNOT BE DECIDED, WHO HAS ACTUALLY MADE THIS UNEXPLAINED INV ESTMENT IN THE PROPERTY IN QUESTION. 5. I HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WELL AS THE RELEVANT MATERIAL ON RECORD. THE ONLY DISPUTE IN THIS APPEAL OF THE ASS ESSEE IS REGARDING THE ADDITION MADE BY THE AO ON ACCOUNT OF UNEXPLAINED INVESTMENT IN THE LAND SITUATED AT VILLAGE CHATARPURA, DANTLI, TEHSIL SANGANER, DISTRICT JAIPU R VIDE REGISTERED SALE DEED DATED 27.01.2007. THE ASSESSEE CLAIMED THAT THE PROPERTY WAS PURCHASED BY SHRI RATAN LAL RANKA THOUGH IN THE NAME OF THE ASSESSEE AND FU RTHER SUBMITTED THAT SHRI RANKA ALSO DISCLOSED INCOME ON ACCOUNT OF INVESTMENT IN T HE PROPERTY DURING THE SEARCH AND SEIZURE ACTION AND IN THE STATEMENT RECORDED UN DER SECTION 132(4) OF THE IT ACT. SINCE SHRI RANKA HAS DISCLOSED THE INCOME AND PAID TAX ON THE SAME, THEREFORE, THE SAID INCOME CANNOT BE ASSESSED TO TAX IN THE HANDS OF THE ASSESSEE. IT IS PERTINENT TO NOTE THAT THE LD. CIT (A) HAS NEGATED THIS CONTE NTION OF THE ASSESSEE ON THE GROUND THAT THERE IS NO MENTION IN THE STATEMENT OF SHRI RANKA ABOUT THE INVESTMENT MADE IN THE PROPERTY IN QUESTION. THE R ELEVANT FINDING OF THE LD. CIT (A) ON THIS ISSUE IN PARA 5.3 AS UNDER :- 5.3. I HAVE GONE THROUGH THE ASSESSMENT ORDER, ST ATEMENT OF FACTS, GROUNDS OF APPEAL AND WRITTEN SUBMISSION CAREFULLY. IT IS SEEN THAT THE APPELLANT HAD PURCHASED THE LAND SITUATED AT VILLAG E : CHATARPURA, DANTALI, THE: SANGANER, DISTT: JAIPUR FOR THE CONSI DERATION OF RS. 27,27,000/- VIDE REGISTERED SALE DEED DATED 27.01.2 007. THE APPELLANT 5 ITA NO. 427/JP/2018 SHRI DASHRATH BALAI, JAIPUR. HAS CONTENDED THAT THIS LAND WAS PURCHASED BY SHRI RATAN LAL RANKA AND SHRI RATAN LAL RANKA HAS OFFERED FOR TAXATION, THE AMOUNT OF INVESTMENT MADE IN PURCHASE OF THIS LAND IN RETURN OF INCOME FILED BY SHRI RATAN LAL RANKA. ACCORDING TO THE APPELLANT SH RI RATAN LAL RANKA HAS ALSO INCLUDED THIS INVESTMENT IN THE TOTAL SURR ENDER OF RS. 12 CRORE MADE BY HIM U/S 132(4). ACCORDING TO THE APPELLANT, THE SUM OF RS. 27,27,000/- IS INCLUDED IN THE AMOUNT OF RS. 1.25 C RORE DECLARED AGAINST LAND C BLOCK (BHAGWAN SAHAI, SC, ST LAND ). THE APPELLANT HAS ALSO FILED THE COPY OF BALANCE SHEET DATED 31.0 3.2007 OF SHRI RATAN LAL RANKA, IN SUPPORT OF HIS CLAIM THAT LAND PURCHASED IN THE NAME OF APPELLANT WAS SHOWN AS CLOSING STOCK IN THE BOOKS OF SHRI RATAN LAL RANKA. I HAVE GONE THROUGH THE STATEMENT OF SHRI RATAN LAL RANKA, THE CONTENTS OF THE LETTER DATED 04.09.2006 SUBMITTED BY SHRI RATAN LAL RANKA & OTHERS BEFORE THE ADIT GIVING BRE AK UP OF THE ADDITIONAL INCOME OF RS. 12 CRORE OFFERED U/S 132(4 ) AND BALANCE SHEET DATED 31.03.2007 OF SHRI RATAN LAL RANKA. THERE IS NO MENTION OF THE LAND PURCHASED BY THE APPELLANT AT VILLAGE: CHATARP URA, DANTALI, THE: SANGANER, DISTT: JAIPUR IN ANY OF THESE DOCUMENTS/S TATEMENTS. THEREFORE, THE CONTENTION OF THE APPELLANT THAT THE LAND SITUATED AT VILLAGE : CHATARPURA, DANTALI, THE: SANGANER, DISTT : JAIPUR WAS PURCHASED BY SHRI RATAN LAL RANKA IN THE NAME OF AP PELLANT AND THE INVESTMENT MADE IN PURCHASE OF THIS LAND WAS OFFERE D FOR TAXATION BY SHRI RATAN LAL RANKA, IS NOT FOUND TO BE SUBSTANTIA TED BY THE EVIDENCES FURNISHED BY THE APPELLANT. AS PER THE REGISTERED S ALE DEED DATED 27.01.2007, THE LAND WAS PURCHASED BY THE APPELLANT FOR CONSIDERATION OF RS. 27,27,000/- IN HIS NAME. THE APPELLANT WAS A BSOLUTE OWNER OF THE LAND HAVING COMPLETE LEGAL TITLE OVER THE LAND. AS THE APPELLANT HAS FAILED TO EXPLAIN SATISFACTORILY THE SOURCE OF INVE STMENT OF RS. 29,18,360/- (RS. 27,27,000 + RS. 1,91,360), THEREFO RE THE ADDITION OF RS. 29,18,360/- MADE BY THE AO IS HEREBY CONFIRMED. 6 ITA NO. 427/JP/2018 SHRI DASHRATH BALAI, JAIPUR. THUS THE LD. CIT (A) HAS DECLINED TO ACCEPT THIS CO NTENTION OF THE ASSESSEE ON THE GROUND THAT IN THE BREAK UP ADDITIONAL INCOME OFFER ED BY SHRI RANKA DURING THE STATEMENT RECORDED UNDER SECTION 132(4) THERE IS NO MENTION OF LAND IN QUESTION PURCHASED BY THE ASSESSEE. NOW THE LD. A/R OF THE ASSESSEE HAS FILED THE ASSESSMENT ORDER DATED 30.12.2017 IN CASE OF SHRI R ATAN LAL RANKA FOR THE ASSESSMENT YEAR 2010-11 WHEREIN THE AO HAS ASSESSED THE INCOME ON ACCOUNT OF CAPITAL GAIN ARISING FROM SALE OF THE SAME PROPERTY ON SUBSTANTIVE BASIS IN THE HANDS OF SHRI RATAN LAL RANKA. THE AO HAS ALSO MENTIONED THE FACT THAT THE SAID INCOME HAS ALSO BEEN ASSESSED IN THE HANDS OF THE ASSESSEE ON PROTECTIVE BASIS. THE RELEVANT FINDING OF THE AO IN CASE OF SHRI RATAN LA L RANKA FOR THE ASSESSMENT YEAR 2010-11 IN PARA 5 & 6 AS UNDER :- 5. AFTER CONSIDERING THE ABOVE WRITTEN SUBMISSION MADE BY ASSESSEE AND EXAMINATION RS. 80,00,000/- RECEIVED BY SHR RATAN L AL RANKA AND SAME ACCEPTED BY SHRI RATAN LAL RANKA AS PER SALE DEED P AGE NO. 5 AND MADE SIGN ON SALE DOCUMENT AS WITNESS. SH. RATAN LAL RANKA ALSO ACCEPTED VIDE LETTER DATED 19.02.2016 THAT THIS SALE DEED WAS ACTUALLY EXECUTED BY SHRI DASHRA TH BALAI AS SELLER BUT THE ACTUAL BENEFICIAL OWNER OF THE LAND WAS SHRI RATAN LAL RANKA. THEREFORE THE SALES CONSIDERATION OF THE LAND WAS RECEIVED IN THE NAME OF SHRI RATAN LAL RANKA, THE SALES OF LAND RECORDED BY SHRI RATAN LAL RANKA IN HIS BOOKS OF ACCOUNTS AND THE TAX ON THIS TRANSACTION HAS ALSO B EEN PAID BY SHRI RATAN LAL RANKA. THE ASSESSMENT OF SHRI RATAN LAL RANKA OF AY 2010-11 HAS ALSO BEEN COMPLETED UNDER SECTION 143(3) OF INCOME TAX ACT, 1 961. THE COPY OF ASSESSMENT ORDER, IT IS FOUND THAT THIS ISSUE HAS N OT BEEN DISCUSSED IN ASSESSMENT ORDER. FROM THE ABOVE, IT APPEARS THAT SALE DEED WAS EXECU TED BY THE ASSESSEE, HOWEVER THE CONSIDERATION WAS ACTUALLY RECEIVED BY SHRI RATAN LAL RANKA. THUS ASSESSEE TRIED TO EXPLAIN THAT HE IS BENAMIDAR OF SHRI RATAN LAL RANKA. 7 ITA NO. 427/JP/2018 SHRI DASHRATH BALAI, JAIPUR. SHRI RATAN LAL RANKA ALSO ACCEPTED THE FACTS THAT T HE TRANSACTION BELONGS TO HIM. AFTER CONSIDERING THE ABOVE IT WAS APPARENT THAT TA XATION LIABILITY TO BE LEVIED IN HANDS OF SHRI RATAN LAL RANKA. HOWEVER, A T THE SAME TIME THE SAID INCOME HAS BEEN ASSESSED IN THE HANDS OF SHRI DASHR ATH BALAI ON PROTECTIVE BASIS AND ACCORDINGLY PROTECTIVE ASSESSMENT WAS MAD E ON THE TOTAL INCOME RS. 1,14,70,782/-. 6. RE-ASSESSMENT PROCEEDINGS AND SUBSTANTIVE ADDITI ON IN THE CASE OF SHRI RATAN LAL RANKA : IN LIGHT OF THE ABOVE AND ON RECEIPT OF THE INFORMA TION FROM I & CI, JAIPUR INVESTIGATION WAS STARTED AND IT WAS FOUND T HAT THE ASSESSEE AFTER SEARCH HAS DECLARED THE SAID PROPERTY AND HAS TAKEN IT AS STOCK IN TRADE IN HIS BALANCE SHEET. ALSO THE ASSESSEE HAS BOOKED THE SAL E OF RS. 80 LACS FOR THE PROPERTY SITUATED AT CHATARPURA, DANTLI, TEHSIL SAN GANER, DISTRICT JAIPUR. THUS IT IS CLEAR THAT THE DEPARTMENT HAS TAKEN A ST AND TO ASSESS THE CAPITAL GAIN ARISING FROM SALE OF THE SAID PROPERTY IN THE HANDS OF SHRI RATAN LAL RANKA ON SUBSTANTIVE BASIS AND THE SAID INCOME WAS ALSO ASSE SSED ON PROTECTIVE BASIS IN THE HANDS OF THE ASSESSEE. SINCE THE ISSUE IS STILL NO T FINALIZED AS THE AO HAS MADE THE SUBSTANTIVE ASSESSMENT IN THE HANDS OF SHRI RATAN L AL RANKA AND PROTECTIVE ASSESSMENT IN THE HANDS OF THE ASSESSEE, THEREFORE, UNTIL AND UNLESS THE ISSUE OF ASSESSMENT OF CAPITAL GAIN ARISING FROM SALE OF THE SAID PROPERTY IS FINALLY SETTLED, IT CANNOT BE DECIDED WHO HAS ACTUALLY MADE THIS UNEXPL AINED INVESTMENT IN THE PROPERTY IN QUESTION. THE STATUS OF THE APPEAL, IF ANY, FILED BY THE PARTIES FOR THE ASSESSMENT YEAR 2010-11 IS NOT KNOWN. THEREFORE, IN THE FACTS AND CIRCUMSTANCES WHERE THE AO HAS MADE SUBSTANTIVE ADDITION OF INCOM E FROM SALE OF THE PROPERTY IN THE HANDS OF SHRI RATAN LAL RANKA, THE ISSUE OF ASS ESSMENT OF INCOME ON ACCOUNT OF 8 ITA NO. 427/JP/2018 SHRI DASHRATH BALAI, JAIPUR. UNEXPLAINED INVESTMENT AT THE TIME OF PURCHASE OF P ROPERTY CANNOT BE DECIDED WITHOUT CONSIDERING THE FINAL OUTCOME OF THE PROCEE DINGS FOR THE ASSESSMENT YEAR 2010-11 AS WELL AS THE FINAL STAND OF THE PARTIES R EGARDING THE OWNERSHIP OF THE PROPERTY IN QUESTION. ACCORDINGLY, THE MATTER IS S ET ASIDE TO THE RECORD OF THE LD. CIT (A) FOR DECIDING THE MATTER AFRESH AFTER CONSIDERIN G ALL THESE FACTS AND DEVELOPMENTS IN RESPECT OF THE ASSESSMENT OF INCOME ON SALE OF T HE PROPERTY IN QUESTION FOR THE ASSESSMENT YEAR 2010-11 IN CASE OF ASSESSEE AS WELL AS IN CASE OF SHRI RATAN LAL RANKA. NEEDLESS TO SAY, THE ASSESSEE BE GIVEN AN A PPROPRIATE OPPORTUNITY OF HEARING BEFORE PASSING THE FRESH ORDER. 6. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALL OWED FOR STATISTICAL PURPOSES. ORDER IS PRONOUNCED IN THE OPEN COURT ON 06/10/2 019. SD/- ( FOT; IKY JKWO (VIJAY PAL RAO) U;KF;D LNL;@ JUDICIAL MEMBER JAIPUR DATED:- 06/10/2019. DAS/ VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. THE APPELLANT- SHRI DASHRATH BALAI, JAIPUR. 2. THE RESPONDENT THE ITO WARD 4(3), JAIPUR. 3. THE CIT(A). 4. THE CIT, 5. THE DR, ITAT, JAIPUR 6. GUARD FILE (ITA NO. 427/JP/2018) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR 9 ITA NO. 427/JP/2018 SHRI DASHRATH BALAI, JAIPUR.