SMT. PINKI DEVI AGARWAL, JAIPUR V. INCOME TAX OFFICER, WARD-4(3), JAIPUR

ITA 515/JPR/2018

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 7513 (ITAT-JAIPUR)
• Duration Of Justice: 9 month(s) 5 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-01-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2011-2012
• Appeal Filed On: 10-04-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: J C KULHARI JCIT DHK
• Assessee Lawyers: S L PODDAR
• Keywords: Rejection of books of accounts; Unexplained expenditure; Gift; Corroborative evidences
• Section: 68

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 JKWO] U;KF;D LNL; ,OA JH FOE FLAG ;K NO ] YS[KK LNL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM AND SHRI VIKRAM SING H YADAV, AM VK;DJ VIHY LA-@ ITA NO. 515/JP/2018 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2011-12. SMT. PINKI DEVI AGARWAL PLOT NO. B-1, JAMNAPURI, NEAR MURLIPURA SCHEME, SIKAR ROAD, JAIPUR. CUKE VS. THE INCOME TAX OFFICER, WARD 4(3), JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. AEJPA 5730 N VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI S.L. PODDAR (ADVOCATE) JKTLO DH VKSJ LS@ REVENUE BY : SHRI J.C. KULHARI (JCIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 16.01.2019. ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 16/01/2019. VKNS'K@ ORDER PER VIJAY PAL RAO, JM : THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER DATED 15 TH MARCH, 2018 OF LD. CIT (A)-2, JAIPUR FOR THE ASSESSMENT YEAR 2011-12. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS :- 1. UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE THE LEARNED CIT (A) HAS ERRED IN CONFIRMING THE ADDITION OF RS. 13, 82,626/- ON ACCOUNT OF CASH DEPOSITED IN BANK. 2. UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE TH E LEARNED CIT (A) HAS ERRED IN CONFIRMING THE ADDITION OF RS. 2,1 4,050/- ON ACCOUNT OF DISALLOWANCE OF PLOT REGISTRATION EXPENS ES INCURRED OUT OF OPENING CASH BALANCE. 3. THE ASSESSEE CRAVES YOUR INDULGENCE TO ADD AMEND OR ALTER ALL OR ANY GROUNDS OF APPEAL BEFORE OR AT THE TIME OF H EARING. 2 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR. GROUND NO. 1 IS REGARDING ADDITION MADE ON ACCOUNT OF CASH DEPOSITED IN THE BANK ACCOUNT. 2. THE ASSESSEE IS AN INDIVIDUAL AND EARNING INCOME FROM BUSINESS AND OTHER SOURCES. THE ASSESSEE FILED HER RETURN OF INCOME O N 12 TH JANUARY, 2012 DECLARING TOTAL INCOME OF RS. 2,54,887/-. IN THE SCRUTINY AS SESSMENT, THE AO NOTED THAT THERE IS A CASH DEPOSIT OF RS. 16,81,000/- IN THE TWO BAN K ACCOUNTS OF THE ASSESSEE, THE DETAILS OF WHICH ARE AS UNDER :- 1. AXIS BANK ACCOUNT NO. 910010013887284. DATE AMOUNT OF CASH DEPOSIT 23.04.2010 6000/ - 30.04.2010 3,97,000/ - 11.05.2010 2,000/ - 21.07.2010 5,00,000/ - 21.07.2010 1,000/ - 4.09.2010 1,80,000/ - 13.09.2010 15,000/ - 09.11.2010 50,000/ - TOTAL 11,51,000/ - 2. HDFC BANK ACCOUNT NO. 03482000005378. DATE AMOUNT OF CASH DEPOSIT 06.04.2010 95,000/ - 12.04.2010 60,000/ - 03.05.2010 2,00,000/ - 10.05.2010 1,00,000/ - 11.05.2010 75,000/ - TOTAL 5,30,000/ - THE AO ASKED THE ASSESSEE TO EXPLAIN THE SOURCE OF CASH DEPOSIT IN THE BANK ACCOUNTS. IN RESPONSE, THE ASSESSEE PRODUCED THE C ASH BOOK SHOWING OPENING CASH BALANCE OF RS. 11,32,626/- AND GIFTS RECEIVED DURIN G THE YEAR OF RS. 2,50,000/-. THE 3 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR. AO DID NOT ACCEPT THE EXPLANATION OF THE ASSESSEE A ND AFTER ALLOWING THE BENEFIT OF CASH WITHDRAWAL FROM THE BANK ACCOUNT OF RS. 1,50,0 00/-, THE AO MADE THE ADDITION OF RS. 13,82,626/- TO THE TOTAL INCOME OF THE ASSES SEE AS UNEXPLAINED CASH DEPOSIT IN THE BANK ACCOUNTS OF THE ASSESSEE. THE ASSESSEE CH ALLENGED THE ACTION OF THE AO BEFORE THE LD. CIT (A) AND CONTENDED THAT WHEN THE ASSESSEE HAS SHOWN THE SOURCE OF THE CASH DEPOSIT IN THE BANK ACCOUNT AS OPENING BALANCE AS WELL AS GIFTS RECEIVED FROM THE FAMILY MEMBERS, THEN THE ADDITION MADE BY THE AO IS NOT JUSTIFIED. THE ASSESSEE HAS EXPLAINED THAT THE ASSESSEE DEPOSITED THE CASH IN BANK ACCOUNT FOR THE PURPOSE OF PURCHASING A HOUSE PROPERTY WHICH WAS PU RCHASED BY UTILIZING THE SAID AMOUNT FROM THE BANK ACCOUNT. THE LD. CIT (A) WAS N OT IMPRESSED WITH THE EXPLANATION OF THE ASSESSEE AND CONFIRMED THE DISAL LOWANCE/ADDITION MADE BY THE AO ON THIS ACCOUNT. 3. BEFORE US, THE LD. A/R OF THE ASSESSEE HAS SUBMI TTED THAT ONCE THE ASSESSEE IS REGULARLY ASSESSED TO TAX AND FILING THE RETURN OF INCOME AND OPENING CASH BALANCE IS DULY REFLECTED IN THE BOOKS OF ACCOUNT AS ON 01.04. 2010, THEN THE SOURCE OF CASH DEPOSIT IN THE BANK ACCOUNT CANNOT BE REJECTED BY T HE AO WITHOUT REJECTING THE BOOKS OF ACCOUNTS OF THE ASSESSEE. THE LD. A/R HAS FURTHER CONTENDED THAT ONCE THE BOOKS OF ACCOUNT OF THE ASSESSEE ARE NOT REJECTED B Y THE AO, THEN THE CASH WHICH IS SHOWN IN THE BOOKS OF ACCOUNTS IS AN EXPLAINED SOUR CE FOR DEPOSIT MADE IN THE BANK ACCOUNT. HE HAS REFERRED TO THE RETURN OF INCOME F ILED FOR THE ASSESSMENT YEARS 2009-10 AND 10-11 ALONG WITH THE COMPUTATION OF INC OME, BALANCE SHEET AND SUBMITTED THAT AS PER THE BALANCE SHEETS OF ASSESSM ENT YEARS 2009-10 AND 10-11, THE ASSESSEE WAS HAVING THE CASH BALANCE AS ON 31 ST MARCH, 2010 OF RS. 11,32,626/- 4 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR. WHICH WAS SHOWN AS OPENING BALANCE AS ON 01.04.2010 . THEREFORE, THE SAID AMOUNT OF CASH WHICH IS PART OF THE BOOKS OF ACCOUNT CANNO T BE REJECTED. AS REGARDS THE GIFT OF RS. 2,50,000/-, THE LD. A/R HAS SUBMITTED THAT T HE SAID AMOUNT WAS RECEIVED BY THE ASSESSEE AS GIFTS FROM HER MOTHER SMT. SANTOSH DEVI AGARWAL (RS. 1,50,000/-) AND FATHER SHRI MALI RAM AGARWAL (RS. 1,00,000/-) V IDE GIFT DEEDS DATED 10.05.2010 AND 12.08.2010 RESPECTIVELY. THE LD. A/R HAS ALSO R EFERRED TO THE GIFT DEED DATED 10.05.2010 AND SUBMITTED THAT THE MOTHER HAS ALSO M ENTIONED THE PAN AS WELL AS SHE WAS ALSO ASSESSED TO INCOME TAX. THEREFORE, WHE N THE MOTHER OF THE ASSESSEE IS DONOR OF RS. 1,50,000/- AND REGULARLY ASSESSED TO T AX, THEN THE AMOUNT OF RS. 1,50,000/- GIVEN AS GIFT TO THE ASSESSEE CANNOT BE DENIED. THE LD. A/R HAS ALSO REFERRED TO THE GIFT DEED DATED 12.08.2010 WHEREBY THE FATHER OF THE ASSESSEE SHRI MALI RAM AGARWAL ALSO STATED TO HAVE GIFTED RS. 1,0 0,000/- TO THE ASSESSEE. HENCE, THE LD. A/R HAS SUBMITTED THAT THE ASSESSEE HAD DUL Y EXPLAINED THE SOURCE OF DEPOSIT MADE IN THE BANK ACCOUNT OF THE ASSESSEE BEING OPEN ING CASH BALANCE OF RS. 11,32,626/- AS ON 01.04.2010 AND GIFT OF RS. 2,50,0 00/- OUT OF WHICH RS. 1,50,000/- FROM MOTHER AND RS. 1,00,000/- FROM FATHER OF THE A SSESSEE. ALL THESE DOCUMENTS WERE FILED BEFORE THE AO, HOWEVER, THE LD. CIT (A) HAS MISUNDERSTOOD THE FACT AND REFERRED THAT THE GIFT DEEDS WERE NOT FILED BEFORE THE AO WHILE REJECTING THE CLAIM OF THE ASSESSEE. HE HAS ALSO REFERRED TO THE REPLY FI LED BY THE ASSESSEE BEFORE THE AO AS WELL AS LD. CIT (A) AND SUBMITTED THAT THE ASSES SEE HAS DISCHARGED HER ONUS BY PRODUCING THE SUPPORTING EVIDENCE OF SOURCE OF THE CASH DEPOSIT IN THE BANK ACCOUNT. SINCE THE ASSESSEE HAD TO PURCHASE THE HO USE PROPERTY, THEREFORE, THE ASSESSEE HAS DEPOSITED THIS AMOUNT IN THE BANK ACCO UNT DURING THE YEAR UNDER 5 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR. CONSIDERATION. IN SUPPORT OF HIS CONTENTION, HE HA S RELIED UPON THE DECISION OF COORDINATE BENCH OF THIS TRIBUNAL IN THE CASE OF SM T. MANJU DEVI NAWAL VS. ACIT, 34 TAX WORLD 253 (JP) AS WELL AS THE DECISION OF JODHP UR BENCH OF THE TRIBUNAL IN THE CASE OF ITO VS. SMT. VIMLA DEVI, 34 TAX WORLD 151 ( JD). THUS THE LD. A/R HAS SUBMITTED THAT WITHOUT POINTING OUT ANY DEFECT OR M ISTAKE IN THE BOOKS OF ACCOUNTS AS WELL AS THE EVIDENCE FILED BY THE ASSESSEE, THE ADDITION MADE BY THE AO IS NOT SUSTAINABLE AND THE SAME MAY BE DELETED. 4. ON THE OTHER HAND, THE LD. D/R HAS SUBMITTED THA T THE AO AS WELL AS THE LD. CIT (A) HAS ANALYZED ALL THE FACTS AS WELL AS THE E VIDENCE PRODUCED BY THE ASSESSEE AND FOUND THAT ALL THESE EVIDENCES PRODUCED BY THE ASSESSEE CANNOT BE VERIFIED FROM THE INDEPENDENT SOURCE AND THESE ARE SELF-SERVING D OCUMENTS. ALL THE SOURCES OF DEPOSITS HAVE BEEN SHOWN IN CASH. EVEN THE GIFTS A RE ALSO CLAIMED TO HAVE BEEN RECEIVED IN CASH. HENCE NONE OF THE TRANSACTIONS OF SOURCE OF CASH DEPOSIT MADE IN THE BANK ACCOUNTS IS THROUGH BANKING CHANNEL BUT AL L ARE CLAIMED TO HAVE BEEN IN CASH. HE HAS RELIED UPON THE ORDERS OF THE AUTHORI TIES BELOW. 5. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WELL AS THE RELEVANT MATERIAL ON RECORD. FOR EXPLAINING THE CASH DEPOSIT IN THE BAN K ACCOUNT OF RS. 13,82,626/-, THE ASSESSEE HAS FILED THE CASH BOOK SHOWING THE OPENIN G CASH BALANCE OF RS. 11,32,626/- AND GIFT OF RS. 2,50,000/- RECEIVED DUR ING THE YEAR, OUT OF WHICH RS. 1,50,000/- RECEIVED FROM MOTHER SMT. SANTOSH DEVI A GARWAL AND RS. 1,00,000/- FROM FATHER SHRI MALI RAM AGARWAL. THE ASSESSEE P RODUCED THE GIFT DEEDS WHEREBY THE MOTHER AND FATHER OF THE ASSESSEE HAVE CONFIRME D THE GIFTS GIVEN OF RS. 1,50,000/- AND RS. 1,00,000/- RESPECTIVELY TO THE A SSESSEE. IT IS PERTINENT TO NOTE 6 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR. THAT THE ASSESSEE HAS BEEN FILING HER RETURN OF INC OME REGULARLY AND ALSO PRODUCED THE RETURN OF INCOME AS WELL AS BALANCE SHEETS FOR THE ASSESSMENT YEARS 2009-10 AND 2010-11, AND THESE FACTS AND RECORDS ARE NOT IN DISPUTE. SINCE NONE OF THE RETURNS OF INCOME IN THE PRECEDING YEAR WERE SUBJEC TED TO SCRUTINY ASSESSMENT, THEREFORE, THE AVAILABILITY OF CASH WITH THE ASSESS EE WOULD NOT BE PROVED BY MERE FILING OF RETURN OF INCOME. HOWEVER, THE ASSESSEE HAS SHOWN THE AVAILABILITY OF CASH OF RS. 11,32,626/- IN THE BOOKS OF ACCOUNT BEING OP ENING CASH BALANCE AS ON 01.04.2010. THE SAID CASH WAS ALSO CLOSING CASH BA LANCE AS ON 31 ST MARCH, 2010 IN THE BALANCE SHEET AS ON 31 ST MARCH, 2010. THE RETURNS OF INCOME THOUGH WERE NO T SUBJECTED TO SCRUTINY, HOWEVER, ONCE THE CASH WAS R EFLECTED IN THE BOOKS OF ACCOUNT AND PART OF THE BALANCE SHEET OF THE ASSESSEE, THEN IN THE ABSENCE OF SAID CASH INTRODUCED IN THE BOOKS OF ACCOUNT BY THE ASSESSEE DURING THE YEAR UNDER CONSIDERATION, THE ISSUE OF MAKING ADDITION BY DISA LLOWING THE AVAILABILITY OF CASH IN THE HANDS OF THE ASSESSEE CAN BE CONSIDERED ONLY IN THE PRECEDING YEAR IN WHICH THE CASH WAS INTRODUCED BY THE ASSESSEE IN THE BOOKS OF ACCOUNT. THE AO DURING THE ASSESSMENT PROCEEDINGS WAS VERY WELL AWARE OF THE F ACT THAT RS. 11,32,626/- WAS STATED TO HAVE BEEN INTRODUCED IN THE BOOKS DURING THE EARLIER ASSESSMENT YEAR AND, THEREFORE, IF THE SAID CLAIM OF THE ASSESSEE WAS NO T ACCEPTABLE THEN THE PROPER COURSE OF ACTION WAS TO MAKE THE ADDITION OF THIS C ASH INTRODUCED IN THE BOOKS OF ACCOUNT UNDER SECTION 68 IN THE RELEVANT ASSESSMENT YEAR IN WHICH THE SAID CASH WAS INTRODUCED IN THE BOOKS AND NOT IN THE YEAR UNDER C ONSIDERATION WHEN IT IS SHOWN AS OPENING CASH BALANCE. THE AO INSTEAD OF TAKING UP THE ASSESSMENT OF THE PRECEDING YEAR HAS MADE THE ADDITION OF THE SAID AMOUNT BY RE JECTING THE SOURCE OF THE 7 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR. AMOUNT AS SHOWN AS OPENING CASH BALANCE. FURTHER, THE AO HAS NOT REJECTED THE BOOKS OF ACCOUNTS OF THE ASSESSEE AND, THEREFORE, O NCE THE ASSESSEE HAS ESTABLISHED THE AVAILABILITY OF THE CASH IN THE BOOKS OF ACCOUN T, THEN THE PROPER COURSE OF ACTION FOR REJECTING THE SAID CLAIM AND MAKING THE ADDITIO N IS TO REOPEN THE ASSESSMENT OF THE EARLIER YEAR. HENCE, TO THE EXTENT OF AVAILABIL ITY OF CASH OF RS. 11,32,626/- BEING OPENING CASH BALANCE WHICH WAS DULY REFLECTED IN TH E BOOKS OF ACCOUNT OF THE ASSESSEE FOR THE YEAR UNDER CONSIDERATION AS WELL A S IN THE EARLIER YEAR, THE SAME CANNOT BE REJECTED AND THE CONSEQUENTIAL ADDITION I S NOT SUSTAINABLE. 5.1. AS REGARDS THE GIFT OF RS. 2,50,000/-, THOUGH THE ASSESSEE HAS ALSO SHOWN THE GIFTS FROM HER MOTHER AND FATHER IN THE EARLIER YEA RS, HOWEVER, THAT IS NOT AN ISSUE BEFORE US AS THE SOURCE OF CASH FOR THE YEAR UNDER CONSIDERATION IS ONLY TO THE EXTENT OF THE GIFT RECEIVED DURING THE YEAR UNDER CONSIDER ATION. THE AO HAS REJECTED THE CLAIM OF GIFTS RECEIVED FROM THE MOTHER AND FATHER OF RS. 1,50,000/- AND RS. 1,00,000/- RESPECTIVELY ON THE GROUND THAT THE ASSE SSEE HAS FAILED TO PRODUCE HER MOTHER AND FATHER FOR EXAMINATION. THE LD. CIT (A) HAS CONFIRMED THE SAID REJECTION OF THE CLAIM OF GIFTS WITH THE OBSERVATION THAT GIF T DEEDS WERE NOT FILED BEFORE THE AO. HOWEVER, WE FIND THAT THE AO HAS DULY ACKNOWLE DGED THE FILING OF THE GIFT DEEDS IN PARA 3 OF THE ASSESSMENT ORDER WHEREIN THE DOCUMENTS FILED BY THE ASSESSEE COMPRISING OF THE GIFT DEEDS OF SMT. SANTO SH DEVI AGARWAL AND SHRI MALI RAM AGARWAL. HENCE THE OBSERVATION OF THE LD. CIT (A) IS CONTRARY TO THE FACTS WHEN THESE DOCUMENTS WERE DULY FILED BEFORE THE AO. HOW EVER, THE MOTHER AS WELL AS THE FATHER OF THE ASSESSEE ARE REGULARLY ASSESSED TO IN COME TAX AND FILING THEIR INCOME- TAX RETURNS. THEREFORE, SUCH A MEAGER AMOUNT OF RS. 1,50,000/- AND RS. 1,00,000/- 8 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR. WHICH IS WITHIN THE RANGE OF THEIR INCOME DECLARED DURING THE YEAR UNDER CONSIDERATION CANNOT BE DENIED. ONCE THE ASSESSEE HAS PRODUCED THE GIFT DEEDS AND THE DONORS ARE REGULARLY ASSESSED TO TAX, THEN THE IDENTITY AND CREDITWORTHINESS OF THE DONORS CANNOT BE DOUBTED WITHOUT PROPER VERIFIC ATION OF ALL SOURCES OF THEIR INCOME. THE INCOME DECLARED DURING THE YEAR UNDER CONSIDERATION BY THE MOTHER AND FATHER OF THE ASSESSEE ARE RS. 1,77,250/- AND R S. 1,50,460/- RESPECTIVELY. HENCE IN THE FACTS AND CIRCUMSTANCES WHEN BOTH THE DONORS ARE ASSESSED TO TAX AND FILING THEIR RETURNS OF INCOME, THEN THE ASSESSEE HAS DISC HARGED HER ONUS OF PROVING THE IDENTITY, CREDITWORTHINESS AND GENUINENESS OF THE T RANSACTION. IN CASE THE AO WAS NOT SATISFIED WITH THE EVIDENCE PRODUCED BY THE ASS ESSEE, THE AO WAS VERY WELL EMPOWERED TO SUMMON THE DONORS FOR THEIR EXAMINATIO N. THOUGH THERE MAY BE AN ISSUE OF CREDITWORTHINESS OF THE DONORS FOR GIVING THE GIFTS FOR THE EARLIER YEAR AS WELL AS FOR THE YEAR UNDER CONSIDERATION, HOWEVER, THE I SSUE OF GIFTS GIVEN IN THE EARLIER YEAR CANNOT BE EXAMINED FOR THE YEAR UNDER CONSIDER ATION AS IT WAS PART OF THE CASH INTRODUCED BY THE ASSESSEE IN THE EARLIER YEAR. FU RTHER, THERE IS NO DISPUTE THAT THE REASON AND OCCASION OF THE DEPOSIT MADE IN THE BANK ACCOUNT IS TO PURCHASE A HOUSE WHICH WAS PURCHASED BY THE ASSESSEE. THEREFORE, IN THE FACTS AND CIRCUMSTANCES OF THE CASE, THE ADDITION MADE BY THE AO OF RS. 13,82, 626/- IS DELETED. GROUND NO. 2 IS REGARDING AN ADDITION OF RS. 2,14,0 50/- ON ACCOUNT OF UNEXPLAINED EXPENDITURE FOR REGISTRATION OF PLOT OF LAND. 6. THIS ISSUE IS CONSEQUENTIAL AS THE ASSESSEE HAS EXPLAINED THE SOURCE OF THIS EXPENDITURE BY OPENING CASH BALANCE AS WELL AS THE GIFT OF RS. 2,50,000/-. SINCE WE 9 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR. HAVE DECIDED THE ISSUE OF AVAILABILITY OF OPENING C ASH BALANCE AS WELL AS GENUINENESS OF THE GIFT IN FAVOUR OF THE ASSESSEE, THE SAID ADD ITION MADE BY THE AO IS LIABLE TO BE DELETED. 7. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWED . ORDER IS PRONOUNCED IN THE OPEN COURT ON 16/01/2 019. SD/- SD/- ( FOE FLAG ;KNO ) ( FOT; IKY JKWO (VIKRAM SINGH YADAV ) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER JAIPUR DATED:- 16/01/2019. DAS/ VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. THE APPELLANT- SMT. PINKI DEVI AGARWAL, 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. 515/JP/2018) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR 10 ITA NO. 515/JP/2018 SMT. PINKI DEVI AGARWAL, JAIPUR.