AJMERI SAHAKARI BHUMI VIKAS BANK LTD., AJMER V. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, AJMER

ITA 472/JPR/2018

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 3694 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 19 day(s)
• Appeal Type: Income Tax (International Taxation) Appeal
• Pronouncement Date: 29-04-2019
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Assessment Year: 2013-2014
• Appeal Filed On: 09-04-2018
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: VIMLENDU VERMA
• Keywords: Business expenditure; Set aside
• Section: 40A(3); 143(3); 37(1); 6; 263; 2

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; IKWY 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. 472/JP/2018 FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2013-14 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER CUKE VS. ACIT, CIRCLE-2, AJMER JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AABTA1905B VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI SANJEEV JAIN (CA) JKTLO DH VKSJ LS @ REVENUE BY : SHRI VIMLENDU VERMA (CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 28/05/2018 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 31/05/2018 VKNS'K@ ORDER PER: VIKRAM SINGH YADAV, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST TH E ORDER OF LD. PR.CIT, AJMER DATED 13.03.2018 FOR ASSESSMENT Y EAR 2013-14 WHERE THE ASSESSEE HAS CHALLENGED THE ACTION OF THE LD. C IT U/S 263 AGAINST THE ORDER OF THE ASSESSING OFFICER U/S 143(3) OF TH E ACT AND DIRECTING FRESH ASSESSMENT ON TWO ISSUES BEING THE SUBJECT MA TTER OF SHOW CAUSE NOTICE U/S 263 AFTER CONDUCTING PROPER INQUIRIES. 2. THE FIRST ISSUE IS REGARDING PAYMENT OF PENAL IN TEREST AMOUNTING TO RS. 11,22,889/- PAID TO RAJASTHAN STATE LAND DEV ELOPMENT BANK (RSLDB). IN THIS REGARD, THE LD. PR. CIT OBSERVED T HAT REGARDING ITA NO. 472/JP/2018 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER V S. CIT, AJMER 2 ASSESSEES CLAIM OF ALLOWABILITY OF PENAL INTEREST U/S 36(1)(III), WHAT IS REQUIRED IS THAT IT SHOULD BE INTEREST PAYMENT AND NOT PENAL INTEREST AND SECONDLY, IT SHOULD BE IN RESPECT OF CAPITAL BORROW ED BUT ASSESSEE HAS NEITHER CLARIFIED NOR FILE ANY EVIDENCE WITH ANY SU PPORTING DOCUMENTS THAT PROVES THAT IT WAS FOR CAPITAL BORROWED EXCEPT A MERE STATEMENT AND FOR WANT OF THAT, IT COULD NOT BE INQUIRED INTO AT THIS STAGE. REFERRING TO THE CASE LAWS, THE LD. PR.CIT OBSERVED THAT THE CLAIM HAS TO BE INQUIRED INTO BY THE ASSESSING OFFICER. IT WAS F URTHER OBSERVED BY LD. PR.CIT THAT NON-PAYMENT OF ANY INSTALLMENT/DUES WHI CH ATTRACTS PENAL INTEREST/CHARGE CANNOT BE TERMED AS LEGITIMATE BUSI NESS ACT OF THE ASSESSEE AND PENAL INTEREST/CHARGES IN CONSEQUENCES THEREOF CANNOT BE TERMED AS ALLOWABLE BUSINESS EXPENDITURE. 3. REGARDING THE SECOND ISSUE, IT RELATES TO PAYMEN T OF ADVERTISEMENT EXPENSES OF RS. 33,295/- ON 11.07.201 2 AND RS. 48,522 ON 06.08.2012 IN CASH ON A SINGLE DAY IN VIOLATION OF SECTION 40A(3) OF THE ACT. THE LD. PR. CIT WHILE REFERRING TO THE ASS ESSEES SUBMISSION THAT THE SAID ADVERTISEMENT EXPENSES HAVE BEEN PAID BY A CCOUNT PAYEE CHEQUES AND DETAILS THEREOF FIND MENTION IN PARA 4. 2 OF THE ORDER OF LD. PR. CIT, OBSERVED THAT THE ASSESSEE HAS FILED CERTA IN DOCUMENTS I.E. COPY OF LEDGER ACCOUNT AND BANK STATEMENT IN SUPPOR T OF ITS CLAIM THAT THE PAYMENTS WERE NOT MADE IN CASH. THE LD. PR CIT OBSERVED THAT IT MAY NOT BE COMPLETELY OUT OF PLACE THAT WHAT HAVE B EEN ON RECORD APPARENTLY DO NOT INDICATE ABOUT THE ALLOWABILITY A ND WHAT HAS NOW BEEN SUBMITTED CAST SHADOW ON WHAT HAD BEEN ON THE RECORDS UNDER SUCH CIRCUMSTANCES, NO CONFIRMED VIEW IS POSSIBLE W ITHOUT GOING INTO THE INQUIRIES. THEREOF, THE ASSESSMENT ORDER PASSED BY THE AO U/S 143(3) HAS TO BE CONSIDERED ERRONEOUS IN SO FAR AS IT IS PREJUDICIAL TO THE ITA NO. 472/JP/2018 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER V S. CIT, AJMER 3 INTEREST OF THE REVENUE. AGAINST THE SAID ORDER OF THE LD. PR CIT, THE ASSESSEE IS NOW IN APPEAL BEFORE US. 4. DURING THE COURSE OF HEARING, LD. AR SUBMITTED T HAT THE PENAL INTEREST PAID TO RSLDB DOES NOT REPRESENT ANY EXPEN DITURE INCURRED FOR ANY PURPOSE WHICH IS AN OFFENCE OR PROHIBITED BY LA W. THE PENAL INTEREST HAS BEEN PAID DUE TO DELAY IN REPAYMENT OF BORROWED AMOUNT FROM RSLDB AND IS COMPENSATORY IN NATURE. IT WAS SU BMITTED THAT THE PENAL INTEREST HAS BEEN PAID ON THE AMOUNT BORROWED FROM RSLDB FOR THE PURPOSE OF ITS BUSINESS I.E. MAKING ADVANCE TO ITS MEMBERS FOR AGRICULTURAL AND ALLIED ACTIVITIES, HENCE FULLY ALL OWABLE U/S 36(1)(III) OF THE ACT. 5. IN THIS REGARD, OUR REFERENCE WAS DRAWN TO THE Q UERY LETTER DATED 24.11.2015 ISSUED BY THE ASSESSING OFFICER WHEREIN A SPECIFIC QUERY HAS BEEN RAISED REGARDING PENAL INTEREST PAID TO RSLDB AMOUNTING TO RS. 11,22,889/- AND THE ASSESSEE WAS ASKED TO FURNI SH THE LEDGER ACCOUNT AND THE EXPLANATION IN SUPPORT OF THE SAID INTEREST PAYMENT WHICH WAS DEBITED IN THE PROFIT LOSS ACCOUNT. OUR R EFERENCE WAS FURTHER DRAWN TO THE SUBMISSION FILED BY THE ASSESSEE DATED 02.07.2011, IN RESPONSE TO THE SAID QUERY LETTER, WHEREIN THE ASSE SSEE HAS STATED AS UNDER:- (1)THAT THE ASSESSEE IS A RURAL DEVELOPMENT COOPER ATIVE REGISTERED UNDER THE COOPERATIVE SOCIETY ACT & IS GOVERNED BY THE NORMS OF RSLDB. LIKE THE OTHER BANKS ARE GOVERNED BY RBI/NAB ARD ETC., THE ASSESSEE IS NOT A BANK BUT STATE FINANCING SOCIETY & IS GOVERNED BY RSLDB FOR FUNDING. THE AIM OF THESE SOCIETIES IS TO FINANCE TO AGRICULTURIST IN RAJASTHAN AS A SCHEME OF RURAL LAN D DEVELOPMENT. THAT REGARDING THE ISSUE OF PENAL INTEREST OF RS. 11,22, 889/-AS PAID/PAYABLE ITA NO. 472/JP/2018 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER V S. CIT, AJMER 4 TO RSLDB AS DEBITED TO INCOME & EXP. ACCOUNT, THE S AME IS IN THE NATURE OF INTEREST IN ADDITION TO THE NORMAL INTERE ST CHARGED BY THEM ON FUNDS LENDED WHEN THE ORIGINAL AMOUNT OF INTEREST & LOAN IS NOT REPAID IN STIPULATED TIME BY THE ASSESSEE AS PER THE TERMS OF THE BORROWING FROM YEARS. NEEDFUL COPY OF THEIR CONFIRMATION OF I NTEREST INCLUDING PENAL INTEREST AS CHARGED/CHARGEABLE FOR THE YEAR B Y RSLDB ALREADY SUBMITTED VIDE OUR EARLIER SUBMISSION. THE FUNDS AR E BORROWED FOR THE BUSINESS PURPOSES AND ARE DEDUCTABLE AS PER PROV. O F SECTION 36(1)(III) OF THE I. TAX ACT, 1961. THE NATURE OF THIS PENAL INTEREST IS NOT PENALTY RA THER IS A COMPENSATORY IN NATURE AND IS PAID FOR BREACH OF A TERM OF A CON TRACT OR STATUE (NOT BEING ONE WHICH IS TREATED AS AN OFFENCE OR PROHIBI TED BY THE LAW) & HENCE IS DEDUCTABLE. THE COPY OF CASE LAW ENCLOSED TO JUSTIFY IN SUPPORT OF CLAIM FOR DEDUCTION. 6. IT WAS ACCORDINGLY SUBMITTED THAT THE MATTER HAS BEEN DULY EXAMINED BY THE ASSESSING OFFICER WITH REFERENCE TO THE QUERY RAISED AND THE DETAILS SUBMITTED BY THE ASSESSEE AND AFTER HAVING FULLY SATISFIED ABOUT THE CLAIM OF THE ASSESSEE, THE ASSE SSING OFFICER ALLOWED THE SAME. 7. REGARDING THE ADVERTISEMENT EXPENSES, IT WAS SU BMITTED BY THE LD AR THAT THE PAYMENTS WERE MADE BY CHEQUE AND THE DETAILS OF THE PAYMENT I.E. LEDGER ACCOUNT WAS AVAILABLE ON THE FI LE OF THE ASSESSING OFFICER. IT WAS SUBMITTED THAT THE SAID DETAILS WER E ALSO DULY EXAMINED BY THE ASSESSING OFFICER AND AFTER VERIFICATION THE REOF, HE FOUND THE SAME ADMISSIBLE AND ALLOWED THE SAME. ITA NO. 472/JP/2018 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER V S. CIT, AJMER 5 8. IT WAS SUBMITTED BY THE LD AR THAT WHAT THE LD. PR. CIT HAS NOW DIRECTED IS THE RE-EXAMINATION OF THE CLAIM OF THE ASSESSEE REGARDING ADMISSIBILITY OF PENAL INTEREST AND ADVERTISEMENT E XPENSES WHICH IS NOT EMPHASIZED IN THE SCHEME OF SECTION 263 OF THE ACT. IT WAS SUBMITTED THAT IT IS NOT A CASE WHERE THE AO DID NOT EXAMINE THE CLAIM OF PENAL INTEREST AND ADVERTISEMENT EXPENSES AND THE AO AFTE R DETAILED ENQUIRY ABOUT THE CLAIM OF PENAL INTEREST AND ADVERTISEMENT EXPENSES AND HAVING FULLY SATISFIED WITH THE EXPLANATION WITH TH E ASSESSEE, HAS ALLOWED THE CLAIM OF THE ASSESSEE, TAKING ONE OF TH E POSSIBLE VIEW WITH THE PRUDENT APPROACH. IT WAS SUBMITTED THAT THE LD. PR. CIT NOW TAKING A DIFFERENT VIEW ON THE ADMISSIBILITY OF THE CLAIM OF THE ASSESSEE AND DIRECTING THE AO TO RE-EXAMINE THE CLAIM OF THE ASS ESSEE IS NOT PERMISSIBLE WITHIN THE POWER OF LD. PR CIT AS EMPHA SIZED U/S 263 OF THE ACT. 9. IN SUPPORT, THE LD. AR HAS RELIED ON DECISIONS I N CASE OF MALABAR INDUSTRIAL CO. LTD. V. CIT [2000] 109 TAXMANN 66 (S C), HARYANA STATE CO-OP. SUPPLY & MARKETING FEDERATION LTD. V. CIT [2 004] 90 ITD 551 (CHD.) CIT V. GOKULDAS EXPORTS [2011] 333 ITR 214 ( KAR.) FOR THE PROPOSITION THAT EVERY LOSS OF REVENUE AS A CONSEQU ENCE OF AN ORDER THE ASSESSING OFFICER CANNOT BE TREATED AS PREJUDICIAL TO THE INTEREST OF THE REVENUE. FOR INSTANCE WHEN AN AO ADOPTS ONE OF THE COURSES PERMISSIBLE IN LAW AND IT HAS RESULTED IN LOSS OF R EVENUE, OR WHERE TWO VIEWS ARE POSSIBLE AND THE ASSESSING OFFICER HAS TA KEN ONE VIEW WITH WHICH THE COMMISSIONER DOES NOT AGREE, IT CANNOT BE TREATED AS AN ERRONEOUS ORDER PREJUDICIAL TO THE INTEREST OF THE REVENUE UNLESS THE VIEW TAKEN BY THE ASSESSING OFFICER IS UNSUSTAINABL E IN LAW. ITA NO. 472/JP/2018 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER V S. CIT, AJMER 6 10. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. REGARDING THE FIRST ISSUE IN RESPECT OF PAYMENT OF PENAL INTEREST AMOUNTING TO RS. 11,22,889/- TO RAJA STHAN STATE LAND DEVELOPMENT BANK, IT IS NOTED THAT THE MATTER WAS S PECIFICALLY ENQUIRED AND EXAMINED BY THE ASSESSING OFFICER. IT IS THERE FORE NOT A CASE OF LACK OF ENQUIRY OR LACK OF ADEQUATE ENQUIRY. 11. REGARDING LEGALITY OF THE VIEW TAKEN BY THE ASS ESSING OFFICER, WE FIND THAT THE DEFINITION OF INTEREST AS DEFINED IN SECTION 2(28A) OF THE ACT IS WIDE ENOUGH TO INTEREST ON DELAYED PAYMENT OF BO RROWED SUM OF MONEY. THE SAID DEFINITION READS AS UNDER: INTEREST MEANS INTEREST PAYABLE IN ANY MANNER IN R ESPECT OF ANY MONEYS BORROWED OR DEBT INCURRED (INCLUDING A DEPOS IT, CLAIM OR OTHER SIMILAR RIGHT OR OBLIGATION) AND INCLUDES ANY SERVI CE FEE OR OTHER CHARGE IN RESPECT OF THE MONEYS BORROWED OR DEBT INCURRED OR IN RESPECT OF ANY CREDIT FACILITY WHICH HAS NOT BEEN UTILIZED. 12. IN LIGHT OF ABOVE, THE VIEW TAKEN BY THE ASSESS ING OFFICER IS A PLAUSIBLE VIEW WHEREIN HE HAS ALLOWED THE CLAIM OF DEDUCTION OF PENAL INTEREST UNDER SECTION 36(1)(III) OF THE ACT. 13. IT IS RELEVANT TO NOTE THAT THE ASSESSEE HAS CL AIMED BOTH INTEREST AMOUNTING TO RS 1,53,20,759 AS WELL AS PENAL INTERE ST AMOUNTING TO RS 11,22,889, BOTH IN RESPECT OF BORROWINGS FROM SL DB, UNDER SECTION 36(1)(III) OF THE ACT, AS APPARENT FROM PERUSAL OF RECORDS, AND WHICH HAS BEEN EXAMINED AND ALLOWED BY THE ASSESSING OFFICER. THEREFORE, THE FINDINGS OF THE LD PR. CIT WHERE HE HAS HELD PENAL INTEREST AS NOT AN ALLOWABLE EXPENDITURE AND AT THE SAME TIME, ACCEPTI NG THE CLAIM OF INTEREST AS AN ALLOWABLE EXPENDITURE CANNOT BE ACCE PTED. BOTH THE INTEREST PAYMENTS ARE ARISING IN RESPECT OF MONEY B ORROWED FROM SLDB. ITA NO. 472/JP/2018 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER V S. CIT, AJMER 7 14. IT SEEMS THAT THE LD PR. CIT HAS BEEN GUIDED BY THE NOMENCLATURE OF PENAL INTEREST RATHER THAN SUBSTANCE AND NATURE OF THE TRANSACTION. THE INTEREST ON DELAYED PAYMENT OF THE BORROWED CAP ITAL IS ARISING OUT OF TERMS OF THE CONTRACT BETWEEN THE ASSESSEE AND S LDB AND THE SAME IS LEVIED FOR NOT MEETING THE TIMELY REPAYMENT OF B ORROWED CAPITAL. IT IS THEREFORE A CONTRACTUAL PAYMENT AND NOT A PAYMENT F OR INFRACTION OF ANY LAW WHICH CAN BE DISALLOWED UNDER SECTION 37(1) OF THE ACT. 15. IN LIGHT OF ABOVE DISCUSSIONS, WE ARE OF THE CO NSIDERED VIEW THAT THE ASSESSING OFFICER HAS EXAMINED THE SUBJECT TRAN SACTION AND HAS TAKE A PLAUSIBLE VIEW IN THE MATTER AND THEREFORE, THE E XERCISE OF JURISDICTION BY THE LD PR. CIT UNDER SECTION 263 CANNOT HELD VAL ID IN LAW. 16. REGARDING PAYMENT OF ADVERTISEMENT EXPENSES, TH E LD AR HAS CONTENDED THAT NECESSARY DETAILS LIKE COPY OF THE L EDGER ACCOUNT IS ON RECORD AND BASIS THAT, IT WAS SUBMITTED THAT THE AO HAS EXAMINED THE CLAIMED OF THE ASSESSEE AND HAS ALLOWED THE SAME. MERELY THE FACT THAT THE DETAILS WERE AVAILABLE ON RECORD, A PRESUMPTION CANNOT BE DRAWN THAT THE ASSESSING OFFICER MUST HAVE EXAMINED EACH AND EVERY DETAIL AVAILABLE ON RECORD AND APPLIED HIS MIND THEREON. FURTHER, WE FIND THAT THERE IS NO MATERIAL ON RECORD IN TERMS OF ANY SPEC IFIC QUERY BEING RAISED BY THE AO AND ANY RESPONSE WHICH HAS BEEN FI LED BY THE ASSESSEE REGARDING PAYMENT OF ADVERTISEMENT EXPENDI TURE. IT IS THEREFORE A CASE WHERE THE ASSESSING OFFICER FAILS TO CONDUCT AN ENQUIRY WHICH IS CALLED FOR AND IN THE GIVEN CIRCUMSTANCES, THE LD PR. CIT IS EMPOWERED TO SET ASIDE THE ASSESSMENT ORDER BY TREA TING IT AS ERRONEOUS AND PREJUDICIAL TO THE INTERESTS OF THE R EVENUE. IN SUCH CIRCUMSTANCES, THE ASSESSING OFFICER CAN'T BE SAID TO HAVE TAKEN A POSSIBLE VIEW AND IT IS NOT FURTHER REQUIRED ON THE PART OF THE LD PR. CIT ITA NO. 472/JP/2018 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER V S. CIT, AJMER 8 TO EXPRESSLY SHOW WHERE THE ASSESSMENT ORDER WENT W RONG. THE VERY FACT THAT NO ENQUIRY WAS CONDUCTED IN THE REQUIRED CIRCUMSTANCES, IS SUFFICIENT IN ITSELF TO INVOKE THE PROVISIONS OF SE CTION 263. 17. THE LD PR. CIT HAS HELD THAT THE PAYMENTS WERE MADE IN CASH AND HENCE, DISALLOWABLE UNDER SECTION 40A(3). IN RESPO NSE, THE ASSESSEE HAS SUBMITTED THAT ALL THE PAYMENTS WERE MADE IN CH EQUE AND THE DETAILS THEREFORE WERE SUBMITTED DURING THE COURSE OF THE REVISIONARY PROCEEDINGS. THEREFORE, WHERE THE LD PR. CIT OBSERV ED THAT WHAT HAVE BEEN ON RECORD APPARENTLY DO NOT INDICATE ABOUT THE ALLOWABILITY AND WHAT HAS NOW BEEN SUBMITTED CAST SHADOW ON WHAT HAD BEEN ON THE RECORDS UNDER SUCH CIRCUMSTANCES, NO CONFIRMED VIEW IS POSSIBLE WITHOUT GOING INTO THE INQUIRIES AND MATTER WAS SET -ASIDE TO EXAMINE THE SAID CLAIM OF THE ASSESSEE, WE DONOT SEE ANY IN FIRMITY IN THE ORDER OF THE LD PR. CIT TO THIS EXTENT WHERE HE HAS HELD THE ASSESSMENT ORDER PASSED BY THE AO U/S 143(3) HAS TO BE CONSIDERED ER RONEOUS IN SO FAR AS IT IS PREJUDICIAL TO THE INTEREST OF THE REVENUE . 18. IN THE ENTIRETY OF FACTS AND CIRCUMSTANCES OF T HE CASE, WE HEREBY RESTRICT THE EXERCISE OF JURISDICTION BY THE LD PR. CIT UNDER SECTION 263 IN THE PRESENT CASE AND LIMIT IT TO EXAMINATION OF PAY MENT OF ADVERTISEMENT EXPENDITURE AFRESH AFTER CONDUCTING P ROPER ENQUIRY BY THE ASSESSING OFFICER. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS PARTLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 31/05/2018. ITA NO. 472/JP/2018 AJMER SAHAKARI BHUMI VIKAS BANK LTD., AJMER V S. CIT, AJMER 9 SD/- SD/- FOT; IKWY JKO FOE FLAG ;KNO (VIJAY PAL RAO) (VIKRAM SINGH YADAV) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 31/05/2018 * GANESH KR. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- AJMER SAHAKARI BHUMI VIKAS BANK LTD. , AJMER 2. IZR;FKHZ@ THE RESPONDENT- 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. 472/JP/2018} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR