SHRI LAXMAN DASS BANSAL, Jaipur V. CIT, Alwar

ITA 501/JPR/2011

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 5182 (ITAT-JAIPUR)
• Duration Of Justice: 5 year(s) 26 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 20-06-2016
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 08-12-2011
• Assessment Year: 2006-2007
• Appeal Filed On: 24-05-2011
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: MEENA CIT DHK
• Assessee Lawyers: RAJEEV PANDEY; DAKSHAYANI PANDEY
• Keywords: Business income; Speculation loss; Prejudicial to interest
• Section: 143(3); 263

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 HKKXPAN] YS[KK LNL; ,OA JH YFYR DQEKJ] U;KF;D LN L; DS LE{K BEFORE: SHRI BHAGCHAND, AM & SHRI LALIET KUMAR, JM VK;DJ VIHY LA-@ ITA NO. 501/JP/2011 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2006-07 LAXMAN DASS BANSAL, SANTAR ROAD, DHOLPUR. CUKE VS. COMMISSIONER OF INCOME TAX, ALWAR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: ABMPB 9022 C VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI RAJEEV PANDEY (CA) & SHRI DAKSHAYANI PANDEY (ADV) JKTLO DH VKSJ LS@ REVENUE BY : SHRI M.S. MEENA (CIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 16/06/2016 MN?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 20/06/2016 VKNS'K@ ORDER PER: LALIET KUMAR, J.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER DATED 25/03/2011 PASSED BY THE LD CIT, ALWAR U/S 263 OF THE INCOME TAX ACT, 1961 (IN SHORT THE ACT). THE GROUNDS TAKEN BY THE AS SESSEE IN APPEAL ARE AS UNDER:- 1 ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CA SE, LD. COMMISSIONER OF INCOME TAX ERRED- (I) IN INVOKING PROVISIONS OF SECTION 263 OF IT ACT, 1961 AND IN NOT FOLLOWING PROVISIONS OF LAW. ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 2 (II) IN DIRECTING THE ASSESSMENT ORDER DATED 25/3/2011 PASSED U/S 143(3) TO BE PREJUDICIAL TO INTEREST OF REVENUE AND NOT FOLLOWING PROVISIONS OF LAW. 2. IN HOLDING LOSS INCURRED AMOUNTING TO RS. 18,31 ,596/- TO BE SPECULATIVE LOSS AND IN NOT APPRECIATING FA CTS ALREADY VISITED AND PERUSED BY LD A.O. DURING COURS E OF ASSESSMENT PROCEEDINGS AND NOT FOLLOWING PROVISIONS OF LAW. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE IS PROPRIETOR OF M/S LAXMAN DAS BANSAL & SONS, DHOLPUR AND CARRYING ON B USINESS OF PURCHASE AND SELL OF GRAIN AND OTHER KIND OF AGRICULTURAL ME RCHANDISE FOR PAST MANY YEARS. THE ASSESSEE HAS FILED ORIGINAL RETURN OF INC OME DECLARING TOTAL INCOME OF RS. 1,79,730/- ON 31/10/2006. THE LD ASSES SING OFFICER HAS ISSUED NOTICE U/S 143(2) OF THE ACT ALONGWITH QUESTI ONNAIRE. THE ASSESSEE FILED REPLY TO THE QUESTIONNAIRE AND AFTER CONSIDER ING THE REPLY FILED BY THE ASSESSEE, THE LD ASSESSING OFFICER HAS PASSED AN OR DER ASSESSING THE TOTAL INCOME OF THE ASSESSEE TO AN AMOUNT OF RS. 2,60,010 /-. THE ASSESSEE HAS DRAWN OUR ATTENTION TO THE QUESTIONNAIRE ISSUED BY T HE LD ASSESSING OFFICER UNDER ORIGINAL ASSESSMENT DATED 02/1/2008 WHEREIN IT EM NO. 18 MENTIONED AS UNDER:- 18. PLEASE EXPLAIN THE NCDEX LOSS OF RS. 1831596/- WITH SUPPORTING DOCUMENTARY EVIDENCE. ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 3 THE ASSESSEE FILED REPLY TO THE QUESTIONNAIRE AND SU BMITTED AS UNDER:- SIR, WITH REFERENCE TO ABOVE SUBJECT, WE ARE ENCLOSING TH E NOTES ON NCDEX LOSS, (HEDGING LOSS). IT IS SUBMITTED THAT NCDEX LOSS IS NOT A SPECULATIV E LOSS BUT IT IS BUSINESS LOSS THAT IS OCCURRED ON ACCOUNT OF HEDGING TRANSACTIONS. THE ASSESSEE INCURRED THE LOSS ON HEDGING BUT (NOT) DUE TO SPECULATIVE LOSS. AFTER CONSIDERING THE ASSESSEES REPLY, THE LD ASSE SSING OFFICER HAS PASSED ASSESSMENT ORDER ON 26/12/2008 , WHERE THERE IS NO E VIDENCE OR DISCUSSION ON THE ADJUSTMENT OF LOSSES CAUSED TO TH E ASSESSEE ON ACCOUNT OF SALE AND PURCHASE OF COMMODITIES/SPECULATION OF COMMODITIES. 3. THAT THE LD COMMISSIONER HAD ISSUED A SHOW CAUSE N OTICE U/S 263 OF THE ACT ON 19/8/2010 WHEREBY THE ASSESSEE WAS CALLED UPON TO GIVE REPLY TO THE FOLLOWING GROUNDS:- DURING THE RELEVANT FINANCIAL YEAR 2006-07, YOU WER E ENGAGED IN THE BUSINESS OF SALE AND PURCHASE OF GRAINS AND A SUM OF RS. 18,31,596/- WAS DEBITED IN P&L ACCOUNT AGAINST NCDEX LOSS. YOU WERE NOT A MEMBER OF NCDEX AS NO ACCOUNT STATEME NT FROM NCDEX WAS PRODUCED SO THE LOSS CLAIMED WAS NOT TENABLE. AS PHYSICAL DELIVERY OF COMMODITIES WAS NOT RECEIVED BY YOU SO THE WHOLE TRANSACTION WOULD FALL WITHIN THE PURVIEW ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 4 OF SPECULATIVE LOSS, WHICH CANNOT BE ALLOWED AGAINST NORMAL PROFIT FROM BUSINESS INCOME. THE ASSESSEE FILED A REPLY ON 10/3/2011 STATING AS U NDER:- SIR, YOUR HONOUR HAS ISSUED SHOW CAUSE NOTICE U/S 263 OF THE IT ACT ON THE GROUND THAT THE LD. A.O. HAS ALLOWED CO MMODITY EXCHANGE LOSS OF RS. 1831596/- FROM NORMAL PROFIT O F BUSINESS INCOME WHICH IS ERRONEOUS AND PREJUDICIAL TO THE INT EREST OF THE REVENUE. IN THIS CONTEXT WE RESPECTFULLY SUBMIT THAT: ASSESSEE IS CARRYING ON BUSINESS OF AADAT AND TRADI NG OF FOOD GRAIN, TILHAN AND DALHAN ETC. SINCE 1990. ASSESSEES MAIN SOURCE OF INCOME IS FROM THIS BUSINESS ACTIVITY. THE BOOKS OF ACCOUNT OF THE FIRM HAVE BEEN AUDITED BY A QUALIFIE D CHARTERED ACCOUNTANTS FIRM FOR THE ASSESSMENT YEAR UNDER CONS IDERATION. ASSESSEE FILED RETURN OF INCOME FOR THE ASSESSMENT YEAR 2006- 07 AND DECLARED INCOME OF RS. 179730/-. THE LD. ASSESSING OFFICER ISSUED NOTICE U/S. 143(2) OF THE INCOME TAX ACT. ON 29.03.2007 AND COMPLETED ASSESSME NT ON 26.12.2008 AND ASSESSED THE INCOME AT RS. 260010/- AGAINST THE DECLARED INCOME OF RS. 179730/-. THUS THE LD. A SSESSING OFFICER MADE AN ADDITION OF RS. 80280/- IN THE TOTA L INCOME. THE LD. ASSESSING OFFICER ISSUED QUESTIONNAIRE ON 02 .01.2008 AND ASKED TO THE ASSESSEE AT POINT NO. 18 OF THE SA ID QUESTIONNAIRE THAT PLEASE EXPLAIN THE NCDEX LOSS O F RS. 1831596/- WITH SUPPORTING DOCUMENTARY EVIDENCE. IN COMPLIANCE TO THE QUESTIONNAIRE ASSESSEE SUBMITTED STATEMENT ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 5 OF ACCOUNT AND DETAILED REPLY VIDE LETTER DATED 23. 01.2008 AND 19.11.2008. COPY OF THE DETAILED REPLY DATED 19.11. 2008 IS ENCLOSED HEREWITH FOR YOUR KIND PERUSAL PLEASE. SIR, ASSESSEE HAS ALREADY GIVEN ALL THE EXPLANATION/DETAILS FOR C LAIMING LOSS OF RS. 1831596/-. ASSESSEE ALSO SUBMITTED ALL THE BOOK S OF ACCOUNT AND VOUCHERS ETC. FOR THE VERIFICATION AND THE SAME WERE TEST CHECKED BY THE LD ASSESSING OFFICER. SIR, IT IS ALSO SUBMITTED THAT THE BOOKS OF ACCOUNT FOR THE SAID AS SESSMENT YEAR WERE AUDITED BY THE QUALIFIED CHARTERED ACCOUNT S FIRM. SIR, NEITHER THE LD. ASSESSING OFFICER NOR THE CHARTERED ACCOUNTANT POINTED OUT ANY MISTAKE IN THE BOOKS OF ACCOUNT AND VOUCHERS FOR THE ASSESSMENT YEAR UNDER CONSIDERATION. SIR, T HE LD. ASSESSING OFFICER COMPLETED ASSESSMENT AFTER MAKING NECESSARY ENQUIRIES ON THIS ISSUE AND AFTER SATISFI ED ON THIS ISSUE THE LD. ASSESSING OFFICER ACCEPTED GENUINE LO SS OF RS. 1831596/- AS CLAIMED BY THE ASSESSEE. SIR, WE FURTHER SUBMIT THAT THE ASSESSMENT ORDER PAS SED BY THE LD. A.O. IS NOT ERRONEOUS AND PREJUDICIAL TO INTERE ST OF THE REVENUE. THE LD. A.O. PASSES ASSESSMENT ORDER AFTER MAKING DUE RELEVANT ENQUIRIES AND KEEPING IN VIEW THE SUBMI SSION OF THE ASSESSEE. 3.1 DURING THE PROCEEDINGS BEFORE THE LD. COMMISSIO NER, THE CIT HAS RECORDED THE ORDER SHEET AND ON 17/3/2011, IT WAS RE CORDED AS UNDER:- SH. M.L. MITTAL, C.A. AND SH. LAXMAN DAS BANSAL, A SSESSEE ATTENDED. THE ASSESSEE DEALS IN FORWARDING TRADING OF ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 6 COMMODITY. FILES THE WRITTEN SUBMISSIONS. THE ASSESSE E HAS NOT PRODUCED THE PROOF FOR ACTUAL DELIVERY. THE CASE IS RESERVED. AFTER RECORDING THIS ORDER SHEET ON 17/3/2011, THE LD. COMMISSIONER PASSED AN ORDER ON 25/3/2011 WHEREBY THE LD. COMMISS IONER HAS HELD AS UNDER:- FROM THE FACTS DISCUSSED ABOVE, IT IS ABUNDANTLY C LEAR THAT THE ASSESSEE WAS NOT A MEMBER OF NCDEX AS NO ACCOUNT STATEMENT FROM NCDEX WAS PRODUCED IN SUPPORT. AS PHY SICAL DELIVERY OR COMMODITIES WAS NOT RECEIVED SO THE WHOLE TRANSACTION IS CONSIDERED AS SPECULATIVE LOSS, WHICH CANNOT BE ALLOWED AGAINST NORMAL PROFIT FROM BUSINESS INCOME. HE WAS MERELY ENGAGED IN THE BUSINESS OF SALE AND PURCHASE OF GRAINS SO THE LOSS CLAIMED IS NOT TENABLE. HENCE, THE ASSE SSEE WAS NOT ENTITLED TO CLAIM LOSS AS BUSINESS LOSS AND T HE SAME IS TREATED AS SPECULATIVE LOSS AMOUNTING TO RS. 18,3 1,596/- WHICH WAS CLAIMED BY THE ASSESSEE AND ERRONEOUSLY ALL OWED BY THE A.O. WHILE COMPLETING THE ASSESSMENT. CONSIDE RING THE FACTS OF THE CASE AND CLAIM OF THE ASSESSEE, THE IS SUE REQUIRES PROPER VERIFICATION AT THE LEVEL OF THE ASSESSING O FFICER. ACCORDINGLY, THE ASSESSMENT IS SET ASIDE, BEING PRE JUDICIAL AND ERRONEOUS TO THE INTEREST OF THE REVENUE, TO TREAT THE SAID LOSS AS SPECULATIVE LOSS AND COMPLETE THE ASSESSMENT ACC ORDINGLY. 4. THE LD AR OF THE ASSESSEE BEFORE US HAS SUBMITTE D THAT THE ASSESSEE HAS SUBMITTED ALL THE RECORDS BEFORE THE LD ASSESSI NG OFFICER DURING THE ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 7 ORIGINAL ASSESSMENT PROCEEDINGS IN RESPONSE TO QUES TION NO. 18 OF THE QUESTIONNAIRE AND HAS SUBMITTED THAT THE NCDEX LOSS IS NOT SPECULATIVE LOSS BUT IS A BUSINESS LOSS AND OCCURRED ON ACCOUNT OF HEDGING TRANSACTIONS AND THEREFORE, THE ORDER PASSED BY THE LD ASSESSING OFFICER IN THE ORIGINAL PROCEEDINGS SHOULD NOT HAVE BEEN INTERFERED BY THE LD. COMMISSIONER AFTER PASSING THE IMPUGNED ORDER. 5. ON THE OTHER HAND, THE LD CIT DR HAS SUBMITTED TH AT THE ORDER PASSED BY THE LD ASSESSING OFFICER IS ERRONEOUS AND PREJUDICIAL TO THE INTEREST OF THE REVENUE AND THEREFORE, ORDER PASSED BY THE LD CIT, WHEREBY THE ASSESSMENT PROCEEDINGS WERE SET ASIDE, WERE IN AC CORDANCE WITH LAW. 6. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON THE RECORD. IT IS AN ADMI TTED CASE THAT THE ASSESSEE IS NOT THE MEMBER OF NCDEX AND IT IS ALSO ADMITTED CASE THAT DURING THE 263 PROCEEDINGS BEFORE THE LD COMMISSION ER THAT THE PROFIT OF PHYSICAL DELIVERY OF THE COMMODITIES WERE NOT RECEIV ED BY THE ASSESSEE. HOWEVER DURING THIS PROCEEDINGS, THE ASSESSEE HAD PR ODUCED THE BILLS OF PURCHASE AND SALE OF THE COMMODITIES CASE AND HAD A LSO FILED AN AFFIDAVIT SUPPORT OF HIS CASE, THE EFFECT OF THESE DOCUMENTS AND AFFIDAVIT SHALL BE DEALT BY US IN THE SEPARATE PROCEEDINGS IN THE MATT ER IN APPEAL NUMBER ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 8 446/14. IN OUR VIEW, THE OBSERVATION OF THE LD CIT T HAT LOSS CAUSED TO THE ASSESSEE ON ACCOUNT OF SPECULATIVE BUSINESS AS CONC LUDED BY THE LD CIT ON THE BASIS OF THE MATERIAL AVAILABLE WITH HIM, CANNO T BE PERMITTED TO BE SET OFF U/S 72 OF THE ACT. THEREFORE, IN OUR VIEW, THE OR DER OF THE ASSESSING OFFICER, WHEREBY HE KEPT THE SPECULATION LOSS AS BUS INESS LOSS IS ERRONEOUS AND PREJUDICIAL TO THE INTEREST OF THE REVENUE AS T HE LD ASSESSING OFFICER HAS ALLOWED THE SETTING OF THE SPECULATIVE LOSS OF R S. 18,31,596/- AGAINST THE BUSINESS INCOME OF THE ASSESSEE.. THE HON'BLE S UPREME COURT IN THE CASE OF MALABAR INDUSTRIAL CO. LTD. VS. COMMISSIONER OF INCOME- TAX [2000] 243 ITR 83 (SC) WHEREIN THE HON'BLE SUPRE ME COURT HAS HELD AS UNDER:- IN THE INSTANT CASE, THE COMMISSIONER NOTED THAT THE INCOME-TAX OFFICER PASSED THE ORDER OF NIL ASSESSMENT WITHOUT APPLICATION OF MIND. INDEED, THE HIGH COURT R ECORDED THE FINDING THAT THE INCOME-TAX OFFICER FAILED TO AP PLY HIS MIND TO THE CASE IN ALL PERSPECTIVE AND THE ORDER PASSED BY HIM WAS ERRONEOUS. IT APPEARS THAT THE RESOLUTION PASSED BY THE BOARD OF THE APPELLANT-COMPANY WAS NOT PLACED BEFO RE THE ASSESSING OFFICER. THUS, THERE WAS NO MATERIAL TO SUPP ORT THE CLAIM OF THE APPELLANT THAT THE SAID AMOUNT REPRE SENTED COMPENSATION FOR LOSS OF AGRICULTURAL INCOME. HE ACCEPTED T HE ENTRY IN THE STATEMENT OF THE ACCOUNT FILED BY THE APP ELLANT IN THE ABSENCE OF ANY SUPPORTING MATERIAL AND WITHOUT MAK ING ANY INQUIRY. ON THESE FACTS THE CONCLUSION THAT THE ORDER OF THE INCOME-TAX OFFICER WAS ERRONEOUS IS IRRESISTIBLE. WE A RE, THEREFORE, OF THE OPINION THAT THE HIGH COURT HAS RIG HTLY HELD THAT THE EXERCISE OF THE JURISDICTION BY THE COMMISSIONE R UNDER SECTION 263(1) WAS JUSTIFIED. ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 9 THE SECOND CONTENTION HAS TO BE REJECTED IN VIEW OF THE FINDING OF FACT RECORDED BY THE HIGH COURT. IT WAS N OT SHOWN AT ANY STAGE OF THE PROCEEDINGS, THAT THE AMOUNT IN Q UESTION WAS FIXED OR QUANTIFIED AS LOSS OF AGRICULTURAL INCOME AN D ADMITTEDLY IT IS NOT SO FOUND BY THE TRIBUNAL. THE FU RTHER QUESTION WHETHER IT WILL BE AGRICULTURAL INCOME WITHIN THE MEANING OF SECTION 2(1A) OF THE ACT AS ELUCIDATED BY THI S COURT IN CIT V. RAJA BENOY KUMAR SAHAS ROY [1957] 32 ITR 466 , DOES NOT ARISE FOR CONSIDERATION. IT IS EVIDENT FROM THE ORDER OF THE HIGH COURT THAT THE FINDINGS RECORDED BY THE TRIBUNAL THAT THE APPELLANT STOPPED AGRICULTURAL OPE RATION IN NOVEMBER, 1982, AND THE RECEIPT UNDER CONSIDERATION DI D NOT RELATE TO ANY AGRICULTURAL OPERATION CARRIED ON BY TH E APPELLANT, WERE NOT QUESTIONED BEFORE IT. THOUGH WE DO NOT AGREE WITH THE HIGH COURT THAT THE SAID AMOUNT WAS PAI D FOR BREACH OF CONTRACT AS INDEED IT WAS PAID IN MODIFICATION/RELAXATION OF THE TERMS OF THE CONTRACT, WE HOLD THAT THE HIGH COURT IS JUSTIFIED IN CONCLUDING THAT THE SAID AMOUNT WAS A TAXABLE RECEIPT UNDER THE HEAD INCOME FR OM OTHER SOURCES. WE FIND NO MERIT IN THE APPEAL AND DISM ISS THE SAME WITH COSTS. RECENTLY THE HON'BLE SUPREME COURT IN THE CASE COMM ISSIONER OF INCOME- TAX, MUMBAI VS. AMITABH BACHCHAN [2016] 69 TAXMANN.COM 170 (SC) HAS HELD AS UNDER:- 21. THERE CAN BE NO DOUBT THAT SO LONG AS THE VIEW TA KEN BY THE ASSESSING OFFICER IS A POSSIBLE VIEW THE SAME OUGHT NOT TO BE INTERFERED WITH BY THE COMMISSIONER UNDER S ECTION 263 OF THE ACT MERELY ON THE GROUND THAT THERE IS AN OTHER POSSIBLE VIEW OF THE MATTER. PERMITTING EXERCISE OF REV ISIONAL POWER IN A SITUATION WHERE TWO VIEWS ARE POSSIBLE WOULD REALLY AMOUNT TO CONFERRING SOME KIND OF AN APPELLATE POWER IN THE REVISIONAL AUTHORITY. THIS IS A COURSE OF ACTION T HAT MUST BE DESISTED FROM. HOWEVER, THE ABOVE IS NOT THE SITUATION IN THE PRESENT CASE IN VIEW OF THE REASONS STATE D BY ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 10 THE LEARNED C.I.T. ON THE BASIS OF WHICH THE SAID AUTHO RITY FELT THAT THE MATTER NEEDED FURTHER INVESTIGATION, A VIEW WITH WHICH WE WHOLLY AGREE. MAKING A CLAIM WHICH WOULD PRIM A FACIE DISCLOSE THAT THE EXPENSES IN RESPECT OF WHICH DEDUCT ION HAS BEEN CLAIMED HAS BEEN INCURRED AND THEREAFTER ABANDONING/WITHDRAWING THE SAME GIVES RISE TO THE NECESS ITY OF FURTHER ENQUIRY IN THE INTEREST OF THE REVENUE. T HE NOTICE ISSUED UNDER SECTION 69-C OF THE ACT COULD NOT HAVE BEEN SIMPLY DROPPED ON THE GROUND THAT THE CLAIM HAS BEEN WITHDRAWN. WE, THEREFORE, ARE OF THE OPINION THAT T HE LEARNED C.I.T. WAS PERFECTLY JUSTIFIED IN COMING TO HIS CONCLUSION S INSOFAR AS THE ISSUE NO.(III) IS CONCERNED AND IN PASSING THE IMPUGNED ORDER ON THAT BASIS. THE LEARNED TRIBUNAL A S WELL AS THE HIGH COURT, THEREFORE, OUGHT NOT TO HAVE INTERFE RED WITH THE SAID CONCLUSION. IN THE LIGHT OF ABOVE, THE ASSESSEES APPEAL CHALLE NGING THE ORDER U/S 263 IS DISMISSED. 7. IN THE RESULT, THE ASSESSEES APPEAL IS DISMISSE D. ORDER PRONOUNCED IN THE OPEN COURT ON 20/06/2016. SD/- SD/- HKKXPAN YFYR DQEKJ (BHAGCHAND) (LALIET KUMAR) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 20 TH JUNE, 2016 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- SHRI LAXMAN DASS BANSAL, DHOLPUR. 2. IZR;FKHZ @ THE RESPONDENT- THE CIT, ALWAR. ITA 501/JP/2011_ LAXMAN DASS BANSAL VS CIT 11 3. VK;DJ VK;QDR @ CIT 4. VK;DJ VK;QDRVIHY @ THE CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ @ DR, ITAT, JAIPUR 6. XKMZ QKBZY @ GUARD FILE (ITA NO. 501/JP/2011) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR