BHAGWAN SAHAY KOOLWAL, Jaipur V. ITO, Dausa

ITA 472/JPR/2013

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 99507 (ITAT-JAIPUR)
• Duration Of Justice: 2 year(s) 6 month(s) 9 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 10-11-2015
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2009-2010
• Appeal Filed On: 01-05-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: RAJ MEHRA JCIT DHK
• Assessee Lawyers: S L PODDAR
• Keywords: Relationship of principal and agent
• Section: 40A(3); 143(3)

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR JH VKJ-IH-RKSYKUH] U;KF;D LNL; ,OA JH FOE FLAG ;KN O] YS[KK LNL; DS LE{K BEFORE: SHRI R.P. TOLANI, JM & SHRI VIKRAM SINGH YA DAV, AM VK;DJ VIHY LA-@ ITA NO. 472/JP/2013 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2009-10 SHRI BHAGWAN SAHAY KOOLWAL PROP. M/S. BHAGWAN SAHAY OM PRAKASH, RAJ BAZAR, BANDIKUI, DAUSA CUKE VS. THE ITO WARD- DAUSA DAUSA LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: ACYPK 0243 M VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI S.L. PODDAR, ADVOCATE, JKTLO DH VKSJ LS@ REVENUE BY : SHRI RAJ MEHRA, JCIT LQUOKBZ DH RKJH[K@ DATE OF HEARING : 14/10/2015 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 10 /11/2015 VKNS'K@ ORDER PER R.P. TOLANI, JM:- THIS IS ASSESSEES APPEAL AGAINST THE ORDER OF THE LD. CIT(A), ALWAR DATED 26-02-2013 FOR THE ASSESSMENT YEAR 2009-10; S OLITARY GROUND RAISED IS AS UNDER:- 1. THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE THE LD. CIT(A) HAS ERRED IN CONFIRMING THE DISALLOWANCE OF RS. 23,87,940/- U/S 40A(3) OF THE ACT. 2.1 BRIEF FACTS OF THE CASE ARE ASSESSEE AN OLD PER SON AGED ABOUT 80 YEARS TRADING IN IRON AND STEEL FILED RETURN OF INC OME ON 23-09-09 ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 2 DECLARING TOTAL INCOME OF RS. 2,70,530/-. THE ASSES SMENT WAS FRAMED U/S 143(3) BY MAKING ADDITION OF RS. 23,87,940/- U/S 40 A(3) OF THE ACT. THE ADDITION U/S 40A(3)OF THE ACT WAS MADE BY REJECTING THE ASSESSEE'S EXPLANATION THAT THE PAYMENTS MADE TO AGENT WERE CO VERED BY EXCEPTIONS OF RULE 6DD(J)(K). ASSESSEES PROPRIETORSHIP CONCER N M/S BHAGWAN SAHAI OM PRAKASH HAD APPOINTED HIS SON SHRI RAM AVTAR GUP TA (PROP. M/S RAMU IRON STEEL SALES, SIKANDARA) AS HIS AGENT FOR PURCHASE OF IRON AND STEEL FROM MARKET BY A WRITTEN AGREEMENT DTD. 1-4-2 008. THE CASH PAYMENTS EXCEEDING RS. 20,000/- AGGREGATING TO RS. 23,87,940/- WERE MADE. ASSESSEE FILED A DETAILED EXPLANATION ALONG W ITH COPY OF AGREEMENT STATING THAT AS PER CLAUSE 5 OF THE AGENCY AGREEME NT BY THIS CONTRACTUAL OBLIGATION WITH HIS AGENT I.E. SON HIS SON SHRI RAM AVTAR GUPTA (PROP. M/S RAMU IRON STEEL SALES, SIKANDARA), ASSESSEE WAS UNDER A CONTRACTUAL OBLIGATION TO MAKE CASH PAYMENT OF PURCHASES ON THE SAME DAY. THIS IS SO AS IRON AND STEEL MARKET BEING HIGHLY COMPETITIVE A ND TO ORIENTED M/S RAMU IRON STEEL SALES REQUIRED CASH AMOUNT FOR PURC HASES TO SUPPLY THE GOODS ON THE SAME DAY AT MARKET PRICE WHETHER AVAIL ABLE WITH HIM OR FROM THE MARKET. THE ARRANGEMENT WAS NEEDED FOR BUS INESS EXPEDIENCY ALSO, AS ASSESSEE WAS OLD AND THIS ARRANGEMENT HELP ED HIM IN BEING AN EARNING MEMBER INSTEAD OF SITTING IDLE. HOWEVER LD. AO, WITHOUT APPRECIATING THE MATERIAL AVAILABLE ON RECORD, ARBI TRARILY HELD THAT AS ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 3 FATHER AND SON WERE NOT PRESENT AGREEMENT COULD NOT BE RELIED AND ADDED THE CASH PURCHASES OF RS. 23,87,940/-U/S 40 A 3. 2.2 AGGRIEVED, THE ASSESSEE PREFERRED FIRST APPEAL WHERE ON LD. CIT(A)S DIRECTION, AO SUBMITTED A REMAND REPORT DA TED 26-12-2002 STATING THAT :- (I) THERE WAS AN AGREEMENT AS MENTIONED BY THE ASSESSEE, HOWEVER THE SON AND FATHER WERE NOT PRODU CED FOR EXAMINATION AND WITNESS IN THE AGREEMENT DATED 01-0 4-2008 WAS ANOTHER SON OF THE ASSESSEE. (II) SINCE PARTIES WERE NOT PRODUCED, IT COULD NOT BE VERIFIED THAT THERE WAS PRINCIPAL AND AGENT BETWEEN ASSESSEE AND HIS SON. (III) THE AGREEMENT DOES NOT REFLECT THAT THERE WAS ANY CONDITION WHICH AMOUNTS TO AN EXCEPTION AS PROVIDED UNDER RULE 6DD OF THE INCOME-TAX RULES. THE ASSESSEE EXPLAINED BEFORE THE LD. CIT(A) THAT A SSESSEE AND HIS SON WERE UNABLE TO REMAIN PRESENT BEFORE THE AO THE AS THE ASSESSEE IS OLD PERSON AGED ABOUT 80 YEARS AND DURING THE PERIOD OF PROCEEDING HE WAS VERY SICK AND BEDRIDDEN, SON RAMAVATAR GUPTA WAS AL SO STRUGGLING WITH GASTRO SURGERY PROBLEMS CONSEQUENTLY THEY WERE NOT ABLE TO ATTEND BEFORE THE AO. IT WAS ALSO CONTENDED THAT BOTH THE PERSONS ARE ASSESSED WITH THE SAME AO AND THEIR TRANSACTIONS WERE VERIFIABLE FROM RESPECTIVE BOOKS AND RETURNS OF INCOME. THE ASSESSEE BEING OLD COULD NOT GO TO MARKET OFF AND ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 4 ON AND IT IS NATURAL THAT THE SON WILL OFFER TO HEL P THE FATHER BY ACTING AS AN AGENT; THE AGREEMENT WAS EXECUTED TO AVOID ANY LEGA L PROBLEM WITH MARKET AND LAW. IT WAS CONTENDED BEFORE THE LD. CIT (A) THAT EXISTENCE AND THE VALIDITY OF THIS AGREEMENT IS NOT DENIED THE ON LY ISSUE RAISED BY AO IS TO THE EFFECT THAT THE AS THEY DID NOT ATTEND BEFOR E HIM, AGREEMENT DOES NOT REFLECT THE RELATIONSHIP OF PRINCIPAL AND AGENT WIT HOUT EVEN REFERRING TO THE CLAUSE 5 OF THE AGREEMENT. THE LD. CIT(A) HOWEVER, CONFIRMED THE ADDITION BY HOLDING THAT THE SALES ARE GENUINE BUT BY THE FINDINGS OF THE AO IT DOES NOT HELP THE ASSESSEE'S CASE. 2.3 AGGRIEVED AGAINST THE ORDER OF THE LD. CIT(A), THE ASSESSEE IS IN SECOND APPEAL. 2.4 THE LD. COUNSEL FOR THE ASSESSEE CONTENDS THAT :- (I) BOTH THE LOWER AUTHORITIES HAVE ACCEPTED THE EX ISTENCE AND VALIDITY OF THE AGREEMENT WHICH WAS PRODUCED BEFORE DURING THE ASSESSMENT ITSELF. MERELY BECAUSE OF NON ATTENDANCE AND ASSESSEE'S OTHER SONS HAVING SIGNED AS A WITNESS, AN ADVERSE I MPLICATION HAS BEEN DRAWN AT DISREGARDING THE MATERIAL AVAILABLE O N RECORD. (II) THE ENTIRE METHODOLOGY OF PURCHASES AND CASH PAYMENT TRANSACTIONS TALLY WITH CLAUSES FROM 1 TO 7 OF THE AGREEMENT. BOTH THE LOWER AUTHORITIES HAVE HELD THA T SALES ARE GENUINE BUT NO COGENT REASON HAS BEEN GIVEN AS TO W HY THE RELATIONSHIP OF PRINCIPAL AND AGENT IS NOT REFLECTE D BY THE AGREEMENT. ONLY SOME VAGUE REFERENCE OF ASSESSEE'S OTHER SON ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 5 BEING THE WITNESS AND THERE BEING NO BUSINESS EXPED IENCY ARE PRESUMED TO SOMEHOW MAKE THE ADDITION. BUSINESS EX PEDIENCY IS VERY MUCH REFLECTED BY THE AGREEMENT INASMUCH AS IT SHOULD HAVE BEEN APPRECIATED THAT THE ASSESSEE BEING 80 YEARS O LD BEING FIT WAS EARNING MEMBER AND PROMOTING HIS BUSINESS WITH THE HELP OF HIS SON. THESE APPRECIABLE CIRCUMSTANCES THEMSELVES CLE ARLY DEMONSTRATE BUSINESS EXPEDIENCY AND IT HAS BEEN ARB ITRARILY HELD BY LOWER AUTHORITIES THAT THERE IS NO BUSINESS EXPEDIE NCY FOR AGREEMENT. KEEPING THIS AGREEMENT ALL THE TERMS OF SECTION 40A(3) OF RULE 6DD(K) ARE COMPLIED WITH AND NO ADDITION IS REQUIRED TO BE MADE. THE LD. AR SUBMITTED THAT THE AO DOUBTED THE AGREEM ENT SIMPLY ON THE GROUND THAT THE ASSESSEE AND HIS SON COULD NOT ATTE ND HIS OFFICE WITHOUT APPRECIATING THAT THE INABILITY DUE TO MEDICAL GROU NDS WAS WELL COMMUNICATED TO LD. AO. IT IS CONTENDED THAT THE AS SESSEE IS LOCATED IN BANDIKUI WHICH IS TOWN IN THE DISTRICT OF DAUSA AND SONS BUSINESS I.E. M/S RAMU IRON & STEEL SALES IS LOCATED IN SIKANDARA WHICH IS NEARLY 15 KMS AWAY FROM BANDIKUI THIS NECESSITATED CASH PURC HASES. IN VIEW OF THIS THE PROVISION OF SECTION 40A(3) READ WITH RULE 6DD( K) STAND COMPLIED WITH. BOTH THE AO AND THE LEARNED CIT(A) HAVE ERRE D IN APPRECIATING THE FACTS. THE RELIANCE IS PLACED BY THE LD. AR OF THE ASSESSEE IN THE CASE OF SMT. HARSHILA CHORDIA VS. ITO (2007) 2008 CTR 20 8 (RAJ.) WHEREIN HON'BLE HIGH COURT HELD THAT ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 6 14. IN THESE CIRCUMSTANCES, WE ARE OF THE OPINION THAT THE CONCLUSION REACHED BY THE CIT (A) WAS CORRECT AND T HE TRIBUNAL BY IGNORING THE SCOPE OF CL. (J) OF R.6DD AS EXPLAINED BY THE BOARDS CIRCULAR HAS ERRED IN REVERSING THE FINDING REACHED B THE CIT (A) ON HYPER-TECHNICAL VIEW. WE THEREFORE, ALLOW THIS A PPEAL AND SET ASIDE THE ORDER OF THE TRIBUNAL TO THE EXTENT IT SU STAINS THE ADDITION OF RS. 40,13,000/- U/S 40A(3). THE LD. AR OF THE ASSESSEE FURTHER RELIED ON FOLLOW ING CASE LAWS:- (I) KANTI LAL PURSHOTTAM & CO. VS. CIT, (1985), 155 ITR 519 (RAJ.) (II) CIT VS. NIKKO AUTO LTD. (2002) 256 ITR 476 ( P&H) (III) JANAMBHUMI VS. CIT (1977) 225 ITR 517 (GAU. ) THE LD. AR FURTHER CONTENDS THAT HON'BLE FINANCE MI NISTER WHILE INTRODUCING SECTION 40A(3) HAS DECLARED ITS PURPOSE BY FOLLOWING SPEECH AS UNDER:- 'TAX LIABILITY IS SOMETHING ARTIFICIALLY REDUCED BY DIVERTING PROFITS TO RELATIVES AND ASSOCIATE CONCERNS IN THE FORM OF EXCESSIVE PAYMENTS FOR GOODS AND SERVICES. CLAIMS ARE ALSO MA DE FOR DEDUCTION OF EXPENSES IN LARGE AMOUNTS SHOWN TO HAVE BEEN PAI D IN CASH, OFTEN WITH A VIEW TO FRUSTRATING INVESTIGATION AS TO THE IDENTITY OF THE RECIPIENTS AND THE GENUINENESS OF THE CLAIM. TO PLU G THESE LOOPHOLES, I PROPOSE TO PROVIDE THAT PAYMENTS MADE IN BUSINESSES AND PROFESSIONS TO RELATIVES OR ASSOCIATE CONCERNS WILL HAVE TO PAS S THE TEST OF REASONABLENESS IN ORDER TO QUALIFY FOR DEDUCTION. F URTHER, I PROPOSE TO PROVIDE THAT PAYMENTS MADE IN AMOUNTS EXCEEDING RS. 2,500 AFTER A DATE TO BE NOTIFIED LATER WILL BE ALLOWED AS A DEDU CTION ONLY IF THESE ARE MADE BY CROSSED CHEQUES OR BY CROSSED BANK DRAFTS.' ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 7 THUS THE VERY PURPOSE OF INTRODUCING THIS NEW SECTI ON WAS TO HAVE A CHECK OVER THE DISHONEST ASSESSEE WHO WANTS TO MAKE FALSE DEDUCTIONS ON ACCOUNT OF EXPENDITURE INCURRED IN CASH. THE SPEECH CLEARLY LAYS STRESS THAT IN ORDER TO ASCERTAIN THE IDENTITY OF THE RECI PIENTS AND THE GENUINENESS OF THE EXPENDITURE, THE AFORESAID PROVISION WAS BRO UGHT ON STATUE. IN OTHER WORDS IF THE IDENTITY OF THE RECIPIENT AND THE GENU INENESS OF THE EXPENDITURE IS ESTABLISHED, THE SPIRIT OF THE PROVI SIONS WOULD STAND COMPLIED WITH. IN THE CASE OF THE ASSESSEE THE IDEN TITY OF M/S RAMU IRON & STEEL SALES, SIKARANDARA IS NOT IN DOUBT. THE GEN UINENESS OF THE PURCHASES HAS ALSO NOT BEEN DOUBTED. IN FACT THE LE ARNED ASSESSING OFFICER HAS NOT DISTURBED THE TRADING ACCOUNT WITH RESPECT TO PURCHASES. IN VIEW OF THIS IT IS SUBMITTED THAT UNDER THE FACTS A ND CIRCUMSTANCES OF THE CASE NO ADDITION WAS CALLED FOR. IT IS PLEADED THAT THE PAYMENT BEING GOVERNED BY DULY EXECUTED AGREEMENT CLEARLY DEMONST RATES THE RELATIONSHIP OF PRINCIPAL AND AGENT BETWEEN THE ASS ESSEE AND HIS SON WHICH READS AS UNDER:- 6DD. NO DISALLOWANCE UNDER SUB-SECTION (3) OF SECTION 40A SHALL BE MADE AND NO PAYMENT SHALL BE D EEMED TO BE THE PROFITS AND GAINS OF BUSINESS OR PROFESSION UND ER SUB-SECTION (3A) OF SECTION 40A WHERE A PAYMENT OR AGGREGATE OF PAYMENTS MADE TO A PERSON IN A DAY, OTHERWISE THAN BY AN ACC OUNT PAYEE CHEQUE DRAWN ON A BANK OR ACCOUNT PAYEE BANK DRAFT, EXCEEDS TWENTY THOUSAND RUPEES IN THE CASES AND CIRCUMSTANC ES SPECIFIED HEREUNDER, NAMELY:- ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 8 (A).. TO ) (J) (K) WHERE THE PAYMENT IS MADE BY ANY PERSON TO HIS AGENT WHO IS REQUIRED TO MAKE PAYMENT IN CASH FOR GOODS OR SERVICE ON BEHALF OF SUCH PERSON. THE ASSESSEES CASH PAYMENT IN QUESTION BEING FULLY COVERED BY EXCEPTION CARVED OUT IN SECTION 6DD (K) CANNOT BE ADDED U/S 4 0A(3)OF THE ACT. 2.5 THE LD. DR RELIED ON THE ORDERS OF THE AUTHORIT IES BELOW AND CONTENDED THAT WHEN THE AO IN REMAND PROCEEDINGS AS KED THE ASSESSEE TO REMAIN PRESENT BUT THEY DID NOT AVAIL OF THE OPPORT UNITY. THEREFORE, ADVERSE INFERENCE HAD BEEN DRAWN AND THE ADDITION M ADE IS JUSTIFIED. 2.6 THE LD. COUNSEL FOR THE ASSESSEE IN REJOINDER C ONTENDS THAT THE ASSESSEE BEFORE THE AO ONLY EXPLAINED HIS INABILITY FOR ATTENDANCE DUE TO MEDICAL ILLNESS WHICH HAS NOT BEEN DISPUTED BY ANY OF THE LOWER AUTHORITIES. BESIDES ALL THE TRANSACTIONS AS TO REL ATIONSHIP BEING PRINCIPAL AND AGENT ARE EVIDENT FROM THE OTHER MATERIAL AVAIL ABLE ON RECORD WHICH WAS VERIFIABLE IN THE ORIGINAL PROCEEDINGS U/S 143( 3) OF THE ACT NAD HAS NOT BEEN OBJECTIVELY CONTROVERTED. 2.7 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. THE FACT AS EMERGE FROM THE RE CORD ARE THAT THE ASSESSEE IS AN AGED PERSON OF AROUND 80 YEARS AND W AS DOING BUSINESS OF IRON AND STEEL, HIS SON WAS ALSO IN THE SAME TRADE; BOTH ARE ASSESSED TO ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 9 INCOME TAX. EXCEPT DRAWING AN ASSUMED ADVERSE INFER ENCE DUE TO THE NON- ATTENDANCE OF THE ASSESSEE AND HIS SON IN REMAND PR OCEEDINGS, EXISTENCE AND VALIDITY OF THE AGREEMENT DATED 01-04-2008 HAS NOT BEEN DISPUTED OR DENIED BY THE LOWER AUTHORITIES WITH REFERENCE TO M ATERIAL AVAILABLE ON RECORD AND CONFIRMATION. THUS ON THE BASIS OF AN IN FERENCE AND WITHOUT CONSIDERING THE MATERIAL AVAILABLE ON RECORD, RELAT IONSHIP BETWEEN PRINCIPAL AND AGENT HAS BEEN DENIED. THE REASONS FO R NON-ATTENDANCE HAVE BEEN DULY EXPLAINED BY THE ASSESSEE BEFORE LD. AO B EING AILMENT OF FATHER AND SON WHICH HAS ALSO NOT BEEN DISPUTED. IN OUR CO NSIDERED VIEW THE INTERPRETATION OF THE AGREEMENT INDICATES THE SON W AS APPOINTED AS AN AGENT TO PERFORM THE WORK OF PURCHASING MATERIAL FO R OLD FATHER ON CASH PAYMENTS. NO CIRCUMSTANTIAL INFIRMITY CAN BE ATTRIB UTED IF AN AGED PERSON WHO DESIRES TO REMAIN IN GAINFUL AVOCATION APPOINTS HIS SON AS AN AGENT TO RENDER NECESSARY HELP. IN OUR CONSIDERED VIEW THE A GREEMENT CANNOT BE IGNORED ON IFS AND BUTS; THE SAME CLEARLY STIPULATE S THE RELATIONSHIP BETWEEN THE PRINCIPAL AND AGENT WHICH CANNOT BE RUL ED OUT ON IMPLICATION MORE SO WHEN TRANSACTIONS ARE ON DAY TO DAY BASIS. THE PURCHASES AND SALES ARE NOT IN ANY WAY DOUBTED AND FULLY HELD TO BE GENUINE BY BOTH THE AUTHORITIES BELOW. THUS IN VIEW OF THE FACTS AND CI RCUMSTANCES OF THE CASE, WE HOLD THAT THE ASSESSEE AND HIS SON WERE AC TING IN THE RELATIONSHIP OF PRINCIPAL AND AGENT AND THE IMPUGNED CASH PAYMEN TS ARE CLEARLY ITA NO. 472/JP/2013 SHRI BHAGWAN SAHAY KOOLWAL VS. ITO, DAUSA . 10 COVERED UNDER EXCEPTION CARVED OUT BY RULE 6DD(K). RESPECTFULLY FOLLOWING THE DECISION OF HON'BLE RAJASTHAN HIGH C OURT IN THE CASE OF SMT. HARSHILA CHORDIA VS. ITO (SUPRA) AND OTHER JUD GMENTS CITED ABOVE, WE DELETE THE ADDITION CONFIRMED BY THE LD. CIT(A). THUS THE APPEAL OF THE ASSESSEE IS ALLOWED. 3.0 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS A LLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 10/11/2015. SD/- SD/- FOE FLAG ;KNO VKJ-IH-RKSYKUH (VIKRAM SINGH YADAV) (R.P.TOLANI) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 10 /11/ 2015 *MISHRA VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SHRI BHAGWAN SAHAY KOOLWAL, DAUSA 2. IZR;FKHZ@ THE RESPONDENT- THE ITO, WARD-DAUSA 3. VK;DJ VK;QDRVIHY ) @ CIT(A) 4. VK;DJ VK;QDR@ CIT 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO.472/JP/2013) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR