SMT. ERAVATI DEVI, HINDAUN CITY V. INCOME TAX OFFICER, SAWAI MADHOPUR

ITA 546/JPR/2017

• Counselvise Citation: [2019] 116 COUNSELVISE.COM (IT) 5582 (ITAT-JAIPUR)
• Duration Of Justice: 2 year(s) 1 month(s) 2 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-07-2019
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: SMC
• Assessment Year: 2011-2012
• Appeal Filed On: 23-06-2017
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: KAILASH MANGAL DHK
• Keywords: Reopening of assessment; Unexplained investment; Sale consideration of property below Jantri Value; Capital asset; Income from undisclosed sources; Cost of acquisition; Tangible material; Reason to believe
• Section: 50C; 147; 148; 139

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCH B, JAIPUR JH JESK LH-'KEKZ] YS[KK LNL; ,OA JH FOT; IKY JKO] U;KF;D LNL; DS LE{K BEFORE : SHRI RAMESH C.SHARMA, AM & SHRI VIJAY PAL RAO, JM VK;DJ VIHY LA-@ ITA NO. 546/JP/2017 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2011-12 SMT. ERAWATI DEVI W/O LATE SHRI BRIJ LAL E-44, MOHAN NAGAR, HINDAUN CITY CUKE VS. THE ITO (3) KARAULI, HQ SAWAI MADHOPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS @ ASSESSEE BY : NONE (NOTICE RETURNED UNSERVED) WRITTEN SUBMISION JKTLO DH VKSJ LS@ REVENUE BY: SHRI KAILASH MANGAL, ADDL. CIT-DR LQUOKBZ DH RKJH[K@ DATE OF HEARING : 23/07/2019 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 25/07/2019 VKNS'K@ ORDER PER VIJAY PAL RAO, JM THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER DATED 13-01-2017 OF LD. CIT(A), KOTA FOR THE ASSESSMENT YEAR 2011-12. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS:- 1. THAT THE LD. CIT(A) WAS NOT JUSTIFIED IN CONFI RMING THE ACTION OF THE AO FOR INITIATING PROCEEDINGS U/S 147 AND CONSEQUENCE 2 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR ISSUE OF NOTICE U/S 148 IN AN ARBITRARY MANNER WITH OUT RECORDING ANY FINDINGS UPON DETAILED SUBMISSIONS OF THE APPELLANT . THEREFORE, HE WAS NOT JUSTIFIED IN CONFIRMING THIS ACTION OF THE AO. THEREFORE, THE INITIATION OF PROCEEDINGS U/S 147 AND CONSEQUENCE N OTICE U/S 148 & ULTIMATE ASSESSMENT ORDER MAY KINDLY BE QUASHED. 2. THAT WHILE ADJUDICATING UPON GROUND NO. 2 TAKEN IN APPEAL BEFORE THE LD. CIT(A) AGAINST ASSESSING THE TOTAL INCOME OF THE APPELLANT, QUITE ARBITRARILY AND ILLEGALLY, BEING I MPRESSED ONLY FOR THE DEFAULTS OF THE APPELLANT CONFIRMING THE ASSESSMENT OF THE TOTAL INCOME OF APPELLANT WHICH IS UNJUSTIFIED FOR THE FOLLOWING REASONS. (I) FIRSTLY, THE TOTAL INCOME OF THE ASSESSEE WAS ASSESSED BY THE AO AS INCOME FROM UNDISCLOSED SOURC ES WHICH WAS THE SALE CONSIDERATION OF AN IMMOVABLE PROPERTY , ADMITTEDLY BY THE AO ALSO BUT THIS OBJECTION WAS NO T ACCEPTED BY THE LD. CIT(A) AS NOT MAINTAINABLE. (II) SECONDLY, THE LD. CIT(A) NOT ALLOWING THIS GROUND WHOLLY RELYING UPON AN ENQUIRY REPORT OBTAIN ED U/S 250(4) OF THE AO FOR WHICH NO OPPORTUNITY WAS GIVEN TO THE APPELLANT BY THE AO AS WELL AS LD. CIT(A). 3. THAT WITHOUT PREJUDICE TO THE ABOVE, IN ANY CASE , EVEN ON THE FACTS CONSIDERED BY THE LD. CIT(A) IN THE AP PELLATE ORDER ITSELF, ,THIS WAS ONLY A CASE OF SHORT TERM CAPITAL GAIN, I F ANY NOT TO THE EXTENT OF RS. 10,97,000/- AS ASSESSED AND CONFIRMED AS INC OME FROM UNDISCLOSED SOURCES AND AS SUCH THERE IS NO JUSTIFI CATION OF ASSESSING THE TOTAL INCOME OF THE APPELLANT AS CONFIRMED. 2.1 NONE APPEARED ON BEHALF OF THE ASSESSEE WHEN TH IS APPEAL WAS CALLED FOR HEARING. IT TRANSPIRED FROM THE RECORD T HAT THE ASSESSEE HAS BEEN SEEKING ADJOURNMENTS SINCE BEGINNING AND THE APPEAL OF THE ASSESSEE WAS EARLIER DISMISSED VIDE TRIBUNAL ORDER DATED 14-08-2 017 DUE TO NON- APPEARANCE AS WELL AS DEFECTS IN THE APPEAL WERE NO T REMOVED BY THE ASSESSEE. SUBSEQUENTLY, THE SAID ORDER WAS RECALLED BY THE TRIBUNAL VIDE 3 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR ITS ORDER DATED 4-4-2018 IN M.A. NO.19/JP/2011 FILE D BY THE ASSESSEE. ALTHOUGH THE CASE OF THE ASSESSEE WAS RECALLED FOR DECIDING AFRESH AFTER HEARING YET THE ASSESSEE DID NOT COME FORWARD TO AP PEAR AND ARGUE HER CASE BEFORE THE TRIBUNAL. ON THE EARLIER OCCASION O N 15-05-2019, THE LD.AR OF THE ASSESSEE HAS WITHDRAWN HIS POWER. THER EFORE, FRESH NOTICE WAS ISSUED TO THE ASSESSEE THROUGH RPAD. THE SAID N OTICE WAS ALSO RETURNED UNSERVED WITH THE POSTAL REMARKS THAT NO S UCH PERSON IS AVAILABLE AT THE ADDRESS. IN THESE CIRCUMSTANCES, WE PROPOSE TO HEAR AND DISPOSE OF THE APPEAL OF THE ASSESSEE EX-PARTE AFTER CONSIDERI NG THE WRITTEN SUBMISSION FILED BY THE ASSESSEE. 3.1 THE GROUND NO. 1 OF THE ASSESSEE IS REGARDING V ALIDITY OF REOPENING OF ASSESSMENT. 3.2 IN THE WRITTEN SUBMISSION, THE ASSESSEE HAS CON TENDED THAT THE AO HAS REOPENED THE ASSESSMENT WITHOUT APPLICATION OF MIND AND WITHOUT ARRIVING TO THE CONCLUSION WHETHER ANY INCOME ASSES SABLE TO TAX HAS ESCAPED ASSESSMENT. FURTHER THE AO HAS CONSIDERED E NTIRE SALE CONSIDERATION OF THE IMMOVABLE PROPERTY SOLD BY THE ASSESSEE AS INCOME HAS ESCAPED ASSESSMENT. THUS THE ASSESSEE HAS CONTE NDED THAT WHEN THERE WAS NO INCOME CHARGEABLE TO TAX THEN THERE WAS NO NEED OF FILING OF 4 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR RETURN OF INCOME BY THE ASSESSEE. THE ONLY BASIS FO R FORMING THE BELIEF IS SALE DEED EXECUTED BY THE ASSESSEE AND THE AO HAS NOT UNDERTAKEN ANY STEP TO FIND OUT WHETHER ANY INCOME CHARGEABLE TO T AX HAS ESCAPED ASSESSMENT. THUS IT IS PLEADED THAT FORMATION OF B ELIEF FOR ESCAPEMENT IS BASED ON IRRELEVANT AND WRONG ASSUMPTION OF FACTS E SPECIALLY AVAILABLE ON RECORD AND THEREFORE, THE PROCEEDINGS INITIATED FOR REASSESSMENT ARE ILLEGAL, WITHOUT JURISDICTION AND VOID AB INITIO. 3.3 ON THE OTHER HAND, THE LD. DR HAS SUBMITTED THA T THE AO HAS RECORDED THE REASONS FOR REOPENING OF ASSESSMENT BY GIVING THE DETAILS OF TRANSACTION OF SALE OF IMMOVABLE PROPERTY BY THE AS SESSEE VIDE SALE DEED DATED 4-01-2011. SINCE THE ASSESSEE HAS NOT FILED A NY RETURN OF INCOME, THEREFORE, THE SAID INFORMATION AND TRANSACTION OF SALE OF IMMOVABLE PROPERTY CONSTITUTES A TANGIBLE MATERIAL TO FORM T HE BELIEF THAT INCOME ASSESSABLE TO TAX HAS ESCAPED ASSESSMENT. HE HAS RE FERRED TO THE ORDER OF THE LD. CIT(A) AND SUBMITTED THAT THE LD. CIT(A) HA S DULY CONSIDERED THE OBJECTIONS RAISED BY THE ASSESSEE AND IT WAS HELD THAT THE INFORMATION IN THE POSSESSION OF THE AO CONSTITUTE A TANGIBLE MATE RIAL TO FORM THE BELIEF THAT INCOME ASSESSABLE TO TAX HAS ESCAPED ASSESSMEN T AND THEREFORE, THE REOPENING OF THE ASSESSMENT IS HELD AS VALID. 5 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR 3.4 WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WEL L AS THE RELEVANT MATERIAL AVAILABLE ON RECORD. THERE IS NO DISPUTE T HAT THE ASSESSEE HAS NOT FILED ANY RETURN OF INCOME U/S 139 OF THE ACT. IT I S ALSO NOT IN DISPUTE THAT DURING THE YEAR UNDER CONSIDERATION THE ASSESSEE HA S SOLD THE PLOT OF LAND VIDE SALE DEED DATED 4-01-2011 AND THE SAID INFORM ATION WAS RECEIVED BY THE AO. SINCE THE ASSESSEE HAS NOT FILED ANY RETURN OF INCOME AND STAMP DUTY VALUATION OF PLOT OF LAND WAS FOUND MORE THAN THE SALE CONSIDERATION SHOWN IN THE SALE DEED, THE AO INITIATED THE PROCEE DINGS U/S 147/148 OF THE ACT BY RECORDING THE REASONS AS UNDER:- THE ASSESSEE HAS NOT FILED RETURN OF INCOME FOR T HE ASSESSMENT YEAR 2011-12. FROM THE INFORMATION RECEI VED FROM THE SUB-REGISTRAR, HINDAUN CITY, IT IS GATHERED THAT TH E ASSESSEE HAS SOLD AN IMMOVABLE PROPERTY ON 04-01-2011 FOR A TOTAL CONSID ERATION OF RS. 1021000/- WHICH WAS ASSESSED AT RS. 1097000/- BY TH E SUB-REGISTRAR FOR STAMP DUTY PURPOSES. SINCE THE ASSESSEE HAS NOT FIL ED RETURN OF INCOME AS WELL AS DETAILS ABOUT COST OF ACQUISITION, HENCE SALE CONSIDERATION U/S 50C AT RS. 1097000/- HAS ESCAPED ASSESSMENT WITHIN THE MEANING OF SECTION 147 OF THE ACT AS THE ASSESSEE HAS NOT DISC LOSED ANY TYPE OF CAPITAL GAIN INCOME. IT IS CLEAR THAT EVEN IF THE VALUATION ADOPTED BY T HE STAMP VALUATION AUTHORITY IS IGNORED, THE SALE CONSIDERATION SHOWN IN THE SALE DEED ITSELF CONSTITUTE A TANGIBLE MATERIAL TO FORM THE BELIEF T HAT INCOME IN THE SHAPE OF CAPITAL GAIN IS ASSESSABLE TAX HAS ESCAPED AS SESSMENT SPECIFICALLY 6 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR WHEN THE ASSESSEE HAS NOT FILED ANY RETURN OF INCOM E. HENCE, THE AO AT THE TIME OF RECORDING THE REASONS AND ISSUING NOTIC E U/S 148 OF THE ACT WAS HAVING MATERIAL WITH HIM IN THE SHAPE OF TRANS ACTION OF IMMOVABLE PROPERTY VIDE SALE DEED DATED 14-01-2011 AND NO C ONTRARY MATERIAL WAS AVAILABLE WITH THE AO TO BE CONSIDERED FOR FORMING THE BELIEF THAT INCOME ASSESSABLE TO TAX HAS ESCAPED ASSESSMENT. THE QUANT UM OF INCOME FINALLY LIABLE TO BE ASSESSED TO TAX MAY VARY AFTER CONSIDE RING THE COST OF ACQUISITION AND OTHER ALLOWABLE DEDUCTIONS IF ANY. BUT AT THE TIME OF RECORDING THE REASONS WHEN THOSE INFORMATIONS WERE NOT AVAILABLE WITH THE AO DUE TO THE REASON OF NON-FILING OF RETURN OF INCOME THEN THE MATERIAL AVAILABLE WITH THE AO WAS REQUIRED TO BE C ONSIDERED TO FORM THE BELIEF AND HENCE IN OUR VIEW THE AO WAS JUSTIFIED I N FORMING THE BELIEF THAT INCOME ASSESSABLE TO TAX HAS ESCAPED ASSESSMEN T. ACCORDINGLY, WE DO FIND ANY ERROR OR ILLEGALITY IN THE IMPUGNED ORDER OF THE LD. CIT(A) UPHOLDING THE VALIDITY OF REOPENING OF ASSESSMENT. THUS GROUND NO. 1 OF THE ASSESSEE IS DISMISSED. 4.1 THE GROUND NO. 2 AND 3 OF THE ASSESSEE ARE REGA RDING ADDITION MADE BY THE AO ON ACCOUNT OF SALE OF PLOT OF LAND. 7 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR 4.2 IN THE WRITTEN SUBMISSION, THE ASSESSEE HAS CON TENDED THAT THE AO AS WELL AS LD. CIT(A) COMMITTED AN ERROR WHILE TREA TING THE SALE CONSIDERATION AS INCOME FROM UNDISCLOSED SOURCES WH EREAS THE INCOME IS FROM SALE OF IMMOVABLE PROPERTY AND THEREFORE, IT OUGHT TO HAVE BEEN ASSESSED AS CAPITAL GAIN AFTER ALLOWING COST OF ACQ UISITION AS DEDUCTION. THUS ENTIRE CONTENTION OF THE ASSESSEE RAISED IN TH E WRITTEN SUBMISSION IS REGARDING NOT ALLOWING THE COST OF ACQUISITION AS D EDUCTION FROM SALE CONSIDERATION WHILE ASSESSING THE SALE CONSIDERATIO N AS INCOME FROM UNDISCLOSED SOURCES. 4.3 ON THE OTHER HAND, THE LD. DR HAS SUBMITTED THA T LD. CIT(A) SOUGHT REPORT FROM THE AO AND AFTER CONSIDERING THE OUTCOM E OF THE ENQUIRY CONDUCTED BY JCIT, RANGE-2, KOTA, IT WAS FOUND THAT THE ASSESSEE PURCHASED THE SAID PLOT OF LAND DURING THE YEAR UND ER CONSIDERATION ON 02-08-2010 FOR A CONSIDERATION OF RS. 8.21 LACS. TH E SAID CONSIDERATION WAS SHOWN AS PAID BY THE ASSESSEE IN CASH AND THER EFORE, IN THE ABSENCE OF SOURCE OF SAID PAYMENT IN CASH THE ENTIRE AMOUNT HAS BEEN TREATED AS INCOME FROM UNDISCLOSED SOURCES. HE RELIED ON THE ORDERS OF THE AUTHORITIES BELOW. 8 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR 4.4 WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WEL L AS RELEVANT MATERIAL ON RECORD. THE LD. CIT(A) HAS DECIDED THIS ISSUE AS UNDER:- IN VIEW OF THE GROUND NO. 2 RAISED BY THE APPELLA NT OBJECTING TO THE ASSESSING OF SALE CONSIDERATION RECEIVED ON SALE OF PROPERTY AS INCOME FROM UNDISCLOSED SOURCES, DETAILS REGARDING THE PRO PERTY WAS SOUGHT FROM THE AO U/S 250(4) WHEREBY THE CHAIN OF PROPERT Y OWNERSHIP AND THE BASIS FOR HOLDING THE RECEIPT FROM SALE OF PROP ERTY AS UNDISCLOSED WAS SOUGHT TO BE EXPLAINED AND JUSTIFIED. FROM A PERUSAL OF THE REPORT OBTAINED FROM THE AO D ATED 10-01-2017, DULY FORWARDED BY JCIT, RANGE-2, KOTA, IT IS CLEAR THAT THE ASSESSEE PURCHASED THE PROPERTY IN CASH ON 02-08-2010 FOR RS . 8,21,000/- FROM ONE SHRI RADHEY SHAYAM JANGID WHO WAS THE OWNER OF SAID PROPERTY FROM1976 AS PER THE DOCUMENT. SUBSEQUENTLY, AFTER A GAP 3 MONTHS, THE ASSESSEE SOLD THE PROPERTY FOR RS. 10,21,000/- (VA LUED BY SUB-REGISTRAR OR STAMP DUTY PURPOSES AT RS.10,97,000/-).HENCE, TH E PROPERTY WAS NEVER A CAPITAL ASSET FOR THE PURPOSE OF LONG TERM CAPITAL GAINS. AT BEST, IF THE SOURCE OF ACQUISITION OF THE PROPERTY COULD BE ASCERTAINED, THE AMOUNT OF DIFFERENCE WOULD TAXABLE AS SHORT TERM CA PITAL GAIN. HOWEVER, NEITHER DURING THE COURSE OF ASSESSMENT PR OCEEDING, NOR DURING THE COURSE OF APPELLATE PROCEEDINGS, THE A/R OF THE ASSESSEE COULD EXPLAIN THE SOURCE OF THE MONEY INVESTED IN T HE INITIAL PURCHASE & LATER SALE OF THE MONEY INVESTED IN THE INITIAL PURCHASE & LATER SALE OF SAID PROPERTY. NO RETURN WAS FILED TO CLAIM ANY SORT OF EXEMPTION FROM TAXABLE GAINS OR OTHERWISE. UNDER THE CIRCUMST ANCES, I DO NOT FIND FAULT WITH THE AOS ACTION TO TAX THE RECEIPT AS UN DISCLOSED. AS REGARDS THE OBJECTION OF THE A/R REGARDING CHANG ING OF HEAD OF INCOME WHILE ASSESSING THE SAME IS NOT CONSIDERED V ALID SINCE THE INITIAL ACTION BEING TAKEN ON A REASON TO BELIEVE OF CERTAIN INCOME ESCAPING ASSESSMENT, THE FINAL ENQUIRY REVEALED THA T THERE WAS NO DISCLOSED SOURCE OF THE SAID INVESTMENT & SUBSEQUEN T RECEIPT FROM SALE. HENCE, THE OBJECTION IS CONSIDERED AS NOT MAINTAINA BLE & DISMISSED. THE CASE LAWS ENCLOSED ARE NOT FOUND SIMILAR ON THE FACTS INVOLVED IN THE INSTANT APPEAL AND THE DECISION IS BASED ON THE FINDINGS BROUGHT OUT IN THE ASSESSMENT ORDER ITSELF. THE ADDITION OF RS. 10,97,000- IS ACCORDINGLY CONFI RMED. 9 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR THERE IS NO DISPUTE THAT THE ASSESSEE PURCHASED THE PLOT OF LAND IN QUESTION DURING THE YEAR ITSELF ON 2-08-2010 AND CL AIMED THE PURCHASE CONSIDERATION OF RS. 8.21 LACS WHICH WAS PAID IN CA SH. THE ASSESSEE HAS NOT EXPLAINED THE SOURCE OF THE SAID PAYMENT OF RS. 8.21 LACS. HOWEVER, SUBSEQUENTLY, THE SAID PLOT WAS SOLD BY THE ASSESSE E VIDE SALE DEED DATED 4-01-2011 FOR A CONSIDERATION OF RS. 10.21 LACS. TH E AO HAS TAKEN THE STAMP DUTY VALUATION AT RS. 10.97 LACS AND ADDED TH E SAME AS INCOME FROM UNDISCLOSED SOURCES. IT IS PERTINENT TO NOTE T HAT ONCE THE STAMP DUTY VALUATION IS CONSIDERED AS FULL VALUE CONSIDERATION THEN IT CAN BE TREATED ONLY FOR THE PURPOSE OF CAPITAL GAIN. THEREFORE, TH E ADDITION MADE BY THE AO BY CONSIDERING THE STAMP DUTY VALUATION OF SALE TRANSACTION AS INCOME FROM UNDISCLOSED SOURCES IS NOT PROPER AND JUSTIFIE D WHEN THE SAID SALE CONSIDERATION IS DULY SUPPORTED BY SALE DEED. HOWEV ER, THE PURCHASE CONSIDERATION OF RS. 8.21 LACS PAID BY THE ASSESSEE IN CASH IS CERTAINLY REMAINED UNEXPLAINED AND THEREFORE, TO THE EXTENT O F SAID AMOUNT OF RS. 8.21 LACS IT IS AN UNEXPLAINED INVESTMENT. ACCO RDINGLY, APART FROM ADDITION OF RS. 8.21 LACS ON ACCOUNT OF UNEXPLAINED INVESTMENT, THE SHORT TERM CAPITAL GAIN ON SALE OF THE SAID LAND IS LIABL E TO BE ASSESSED TO TAX. HENCE, IN THE FACTS AND CIRCUMSTANCES OF THE CASE, WE RESTRICT THE ADDITION 10 ITA NO. 546/JP/2017 ERAWATI DEVI VS ITO- 3, KARAULI, HQ SAWAI MADHOPUR TO THE EXTENT OF RS. 8.21 LACS AS UNEXPLAINED INVES TMENT AND SHORT TERM CAPITAL GAIN BY CONSIDERING THE FULL VALUE OF CONSI DERATION U/S 50C OF THE ACT AND AFTER ALLOWING COST OF ACQUISITION OF RS. 8 .21 LACS. THUS GROUND NO. 2 AND 3 OF THE ASSESSEE ARE PARTLY ALLOWED. 5.0 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PA RTLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 25/ 07/201 9. SD/- SD/- JESK LH 'KEKZ FOT; IKY JKO (RAMESH C. SHARMA) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 25/07/ 2019 *MISHRA VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SMT. ERAWATI DEVI, HINDAUN CITY 2. IZR;FKHZ@ THE RESPONDENT-THE ITO -3 KARAULI, HQ SAWAI MADHO PUR 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.546/JP/2017) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR