SMT. LEELA DEVI BUMB, BIJAINAGAR V. INCOME TAX OFFICER, WARD-1, BEAWAR

ITA 573/JPR/2019

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 8451 (ITAT-JAIPUR)
• Duration Of Justice: 8 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 15-01-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2012-2013
• Appeal Filed On: 22-04-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: K C GUPTA
• Keywords: Principle of natural justice; Initiation of penalty proceedings; Speculation loss
• Section: 271(1)(c); 143(3); 131

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S,A JAIPUR JH FOT; IKY 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. 573/JP/2019 FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2012-13 SMT. LEELA DEVI BUMB 117, SHITAL MATA MARKET, KUMHAR MOHALLA, BIJAINAGAR. CUKE VS. THE ITO, WARD-1, BEAWAR. TOLFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AIJPB 0894 L VIHYKFKHZ@ APPELLA NT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : NONE JKTLO DH VKSJ LS @ REVENUE BY : SHRI K.C. GUPTA (JCIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 01/01/2020 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 15/01/2020 VKNS'K@ ORDER PER: VIKRAM SINGH YADAV, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST TH E ORDER OF LD. CIT(A), AJMER DATED 27.02.2019 FOR THE ASSESSMENT Y EAR 2012-13 WHEREIN THE ASSESSEE HAS CHALLENGED THE SUSTENANCE OF LEVY OF PENALTY U/S 271(1)(C) OF THE IT ACT. 2. NONE HAS APPEARED ON BEHALF OF THE ASSESSEE NOR ANY ADJOURNMENT APPLICATION HAS BEEN FILED. FURTHER, I T HAS BEEN NOTED THAT THE MATTER HAS BEEN FIXED FOR HEARING ON COUPLE OF OCCASIONS EARLIER AS ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 2 WELL. IT WAS THEREFORE DECIDED TO HEAR THE MATTER EX-PARTE QUA THE ASSESSEE BASED ON MATERIAL AVAILABLE ON RECORD. 3. BRIEFLY THE FACTS OF THE CASE ARE THAT ASSESSMEN T IN THIS CASE WAS COMPLETED U/S 143(3) ON 13.03.2018 WHEREIN THE ADDI TION OF RS. 56,30,000/- WAS MADE U/S 69 OF THE ACT AS THE S AID AMOUNT WAS FOUND DEPOSITED IN THE ASSESSEES BANK AND NO SATIS FACTORY EXPLANATION WAS FURNISHED BY THE ASSESSEE. ON APPEAL, THE ADDIT ION HAS SINCE BEEN CONFIRMED BY THE COORDINATE BENCH (VIDE ITS ORDER DATED 08.12.2017 IN ITA NO. 909/JP/2019) AND THE RELEVANT FINDING READS AS UNDER:- 4. IN VIEW OF THESE FACTUAL ASPECT AND ABSENCE OF ANY DOCUMENT IN SUPPORT OF CLAIMED OF ASSESSEE THAT SHE WAS A SU B-BROKER AND CASH DEPOSITED IN BANK BELONG TO THE CLIENTS, WE FI ND NO FAULT IN THE ORDER OF LD. CIT(A). IN OUR CONSIDERED VIEW, TH E ASSESSEE HAS NOT ABLE TO FILE ANY DOCUMENTARY EVIDENCE WITH REGA RD TO THE NATURE AND SOURCE OF THE CASH DEPOSITS IN HER BANK ACCOUNT OF RS. 56,30,000/-. THEREFORE, THE CIT(A) HAS RIGHTLY SUST AINED THE ADDITIONS. AS FAR AS ALTERNATIVE PLEA OF THE ASSESS EE WITH REGARD TO THE SET OFF OF THE LOSS TO BE ALLOWED AGAINST THE I NCOME OF RS. 56,30,000/- TAXED U/S 69 IS ALSO AGAINST THE LEGAL PROVISION OF THE ACT. THIS LOSS WAS A SPECULATION LOSS AND IT COUL D BE SET OFF ONLY AGAINST SPECULATION INCOME. THEREFORE, THE CIT(A) HAS RIGHTLY DENIED THE BENEFIT OF SET OFF TO THE ASSESSEE THE F INAL PLEA OF THE LD. A/R THAT THE MATTER MAY BE RESTORED TO THE FILE OF THE AO ALSO CANNOT BE ACCEPTED FOR THE REASONS THAT THE ASSESSE E HAS BEEN PROVIDED SUFFICIENT OPPORTUNITY BEFORE THE AUTHORIT IES BELOW TO PRODUCE NECESSARY DOCUMENTS IN SUPPORT OF HER CLAIM . ANY ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 3 REMAND OF THE ISSUE TO THE FILE OF THE AO AS THIS S TAGE SHALL BE AGAINST THE BASIC TENANTS OF LAW. 4. SEPARATELY, THE ASSESSING OFFICER INITIATED PENA LTY PROCEEDINGS U/S 271(1)(C) OF THE ACT AND SATISFACTION HAS BEEN RECORDED BY THE ASSESSING OFFICER STATING THAT THE ASSESSEE HAS CON CEALED AND ALSO FURNISHED INACCURATE PARTICULARS OF INCOME. DURING THE COURSE OF PENALTY PROCEEDINGS, A FRESH SHOW CAUSE NOTICE WAS ISSUED T O THE ASSESSEE DATED 18.01.2018 AND IN RESPONSE, THE ASSESSEE SUBM ITTED AS UNDER:- IN THE ABOVE CONTEXT THE ASSESSEE VIDE HER LETTER 31.01.2018 HAS SUBMITTED THAT DUE TO HEAVY LOSSES SUSTAINED BY ALL /MAXIMUM PARTIES, DETAILS AS PER CHART; THE BUSINESS WAS LAT ER CLOSED. THUS THE ASSESSEE WAS ONLY DOING THE TRADE AS 'SUB BRO KEERS' AND THE OPERATIONS/TRANSACTIONS AS MADE WITH M/S SI SODIYA FUTURE, AJMER WAS MAINLY OF CLIENTS/PERSONS. A SWOR N AFFIDAVIT OF ASSESSEE DATED 20.01.2005 WAS ALSO SUB MITTED TO A.O. STATING THE AFORESAID FACTS. THE LADY WAS ALSO INTERROGATED PERSONALLY U/S 131 & SHE NARRATED THE SAME TO A.O. AS CONFIRMED BY A.O. IN HIS ORDER. ALL THE SAI D PERSONS WERE ALSO SUMMONED BY A.O. U/S 131 OF INCOME-TAX AC T, 1961 & ALL APPEARED BEFORE A.O. & ACCEPTED THE FACT S THAT TRANSACTIONS OF SALE/PURCHASE AT MCX/NCDEX WERE THR OUGH M/S PANKAJ TRADERS PROPRIETOR SMT. LEELA BUMB & STA TED THE QUANTUM OF LOSSES SUFFERED BY THEM. THEY ALL ADMITT ED & ACCEPTED THAT SMT. LEELA DEVI WAS ONLY PROVIDING TH E FACILITY OF NCDEX/MCX BOLT ON COMMISSION BASIS. ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 4 THUS NEITHER THERE IS ANY CONCEALMENT NOR ANY INACC URATE PARTICULARS BECAUSE NOTHING SPECIFIC DEFECT OR CONC EALMENT PROVED OR DEDUCTED. 5. THE SUBMISSIONS OF THE ASSESSEE WERE NOT FOUND A CCEPTABLE TO THE ASSESSING OFFICER AND IT WAS HELD THAT SINCE TH E MATTER HAS BEEN DECIDED BY THE LD CIT(A) AND TRIBUNAL AGAINST THE A SSESSEE IN THE QUANTUM PROCEEDINGS, THE ASSESSEE HAS CONCEALED AND ALSO FURNISHED INACCURATE PARTICULARS OF HER INCOME AND THE RELEVA NT FINDINGS OF THE AO READS AS UNDER:- I HAVE CAREFULLY GONE THROUGH THE ABOVE DECISIONS CITED BY LEARNED A/R OF THE ASSESSEE BUT THESE ARE NO HELP T O THE ASSESSEE. SINCE THE LD CIT (A) AJMER AND THE HON'BL E ITAT, JAIPUR HAS ALREADY CONSIDERED THE SUBMISSION OF THE ASSESSEE AND THE APPEAL OF THE ASSESSEE HAS BEEN DISMISSED B Y BOTH THE APPELLATE AUTHORITIES. IN VIEW OF DETAILED FACTS DISCUSSED ABOVE, I FIND T HAT THE ASSESSEE HAS CONCEALED AND ALSO FURNISHED INACCURAT E PARTICULARS OF HER INCOME, THEREFORE, PENALTY PROCE EDINGS U/S 271(1)(C) OF THE I.T. ACT, 1961 HAVE BEEN INITIATED SEPARATELY. AS PER THE PROVISION OF SECTION 271(1)(C) R.W.S. 27 4 OF THE IT ACT 1961 ' IF THE ASSESSING OFFICER OR THE COMMISSIONER (APPEALS) [OR THE [PRINCIPAL COMMISSIO NER OR] COMMISSIONER] IN THE COURSE OF ANY PROCEEDING UNDER THIS ACT, IS SATISFIED THAT ANY PERSON- HAS CONCEALED TH E ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 5 PARTICULARS OF HIS INCOME OR FURNISHED INACCURATE P ARTICULARS OF [OF SUCH INCOME, OR].' AS PER THE PROVISION OF SECTION 271(1)(C) OF THE IT ACT 1961, THE PENALTY U/S 271(1)(C)OF THE 1.T. ACT, 196 1 'IN THE CASES REFERRED TO IN CLAUSE (C)[IN ADDITION TO TAX, IF ANY, PAYABLE] BY HIM, A SUM WHICH SHALL NOT BE LESS THAN , BUT WHICH SHALL NOT EXCEED [THREE TIMES], THE AMOUNT OF TAX SOUGHT TO BE EVADED BY REASON OF THE CONCEALMENT OF PARTICULARS OF HIS INCOME [OR FRINGE BENEFITS] OR T HE FURNISHING OF INACCURATE PARTICULARS OF SUCH INCOME [OR FRINGE BENEFITS].' (I) THE INCOME ASSESSED AFTER EFFECT OF HONBLE ITAT ORDER. RS. 58,12,390/- (II) TAX & CESS DETERMINED ON ABOVE INCOME. RS. 16 ,42,560/- (III) TAX ON RETURN INCOME. RS. NIL (IV) TAX & CESS ON CONCEALED INCOME. RS. 16,42,5 60/- (V) MINIMUM PENALTY IMPOSABLE @ 100% OF TAX SOUGHT TO BE EVADED. RS. 16,42,560/- (VI) MINIMUM PENALTY IMPOSABLE @ 300% OF TAX SOUGHT TO BE EVADED. RS. 49,27,680/- (VII) PENALTY LEVIED 100% OF TAX SOUGHT TO BE EVADED. RS. 16,42,560/- I HEREBY IMPOSE A PENALTY U/S 271(1) OF THE ACT FO R THE A.Y. 2012-13, OF RS. 16,42,560/- WHICH IS 100% OF T HE TAX SOUGHT TO EVADED. 6. WE, THEREFORE, FIND THAT RIGHT FROM THE ASSESSME NT PROCEEDINGS TILL COMPLETION OF THE PENALTY PROCEEDI NGS, THE AO STATED THAT THE ASSESSEE HAS CONCEALED HER PARTICUL ARS OF INCOME ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 6 AS WELL AS FURNISHED INACCURATE PARTICULARS OF INCO ME. THEREFORE, BOTH THE CHARGES FOR LEVY OF PENALTY HAS BEEN PUT O N THE ASSESSEE HOWEVER, THERE DOESNT SEEM TO BE ANY CLEAR FINDING IN THE PENALTY ORDER AS TO WHY THE CASE OF THE ASSESSEE FALLS UNDE R BOTH CONCEALMENT OF PARTICULARS OF INCOME AS WELL AS FUR NISHING INACCURATE PARTICULARS OF INCOME OF HER INCOME. NO DOUBT, THE FINDINGS IN THE QUANTUM PROCEEDINGS ARE RELEVANT, H OWEVER, THE SAME CANNOT IPSO FACTO LEAD TO LEVY OF PENALTY AS A SSESSMENT AND PENALTY PROCEEDINGS ARE INDEPENDENT PROCEEDINGS. T HE AO HAS TO RECORD A SPECIFIC FINDING IN THE PENALTY ORDER AS T O HOW THE CASE OF THE ASSESSEE FALLS UNDER CONCEALMENT AND/OR FURNISH ING INACCURATE PARTICULARS OF INCOME. FURTHER, EVEN WHERE CHARGE I S UNCERTAIN AT THE TIME OF INITIATION OF PENALTY PROCEEDINGS, IT M UST NECESSARILY BE SUBSTITUTED WITH A CONCLUSIVE DEFAULT AT THE TIME O F PASSING THE PENALTY ORDER. IN THIS REGARD, WE REFER TO THE DEC ISION OF HONBLE RAJASTHAN HIGH COURT IN CASE OF SHEVETA CONSTRUCTIO N CO. PVT. LTD. VS. ITO (IN DB NO. 534/2008 VIDE ORDER DATED 06.12.2016) WHEREIN IT WAS HELD AS UNDER:- 4. FROM THE ORDER OF ASSESSMENT, THE ASSESSING OF FICER HAS USED THE LANGUAGE AS UNDER:- PENALTY PROCEEDINGS UNDER SECTION 271(1)(C) FOR CONCEALMENT OF INCOME/FURNISHING OF INACCURATE PART ICULARS OF INCOME HAVE BEEN INITIATED SEPARATELY. 5. COUNSEL FOR THE APPELLANT RELIED UPON THE DECISI ON OF ANDHRA PRADESH HIGH COURT IN CASE OF CHENNAKESAVA PHARMACEUTICALS VS. COMMISSIONER OF INCOME TAX REPO RTED IN (2012) 349 ITR 196, WHEREIN IT HAS BEEN HELD AS UND ER:- ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 7 'IN RELIANCE PETRO PRODUCTS PVT.LTD'S CASE (1 SUPRA ), THE SUPREME COURT ALSO HELD THAT IMPOSITION OF PENALTY IS UNWARRANTED WHEN THERE IS NO FINDING IN THE ASSESSM ENT ORDER THAT DETAILS SUPPLIED BY THE ASSESSEE WERE FO UND TO BE FALSE. THIS INDICATES THAT THE VIEW TAKEN BY THE DELHI HIGH COURT IN RAM COMMERCIAL ENTERPRISES LTD. 'S CASE (6 SUPRA ) WHICH HAS BEEN APPROVED IN DILIP N. SHROFF'S CASE (10 SUPRA) CONTINUES TO BE VALID AND THIS PART OF THE JUDGMENT IN DIIIP N. SHROFF'S CASE (10 SUPRA) HAS NOT BEEN OVER RULED AND CONTINUES TO BE GOOD LA W. MOREOVER THE DECISION OF THE DELHI HIGH COURT IN RA M COMMERCIAL ENTERPRISES (6 SUPRA)WAS ALSO FOLLOWED B Y THE SAME HIGH COURT IN COMMISSIONER OF INCOME TAX V . M.K.SHARMA(9 SUPRA) AND SLP(C) NO.17591 OF 2008 FIL ED AGAINST THE SAID DECISION WAS DISMISSED BY THE SUPR EME COURT ON 18.7.2008. APPLYING THE ABOVE PRINCIPLE THAT THE ASSESSING OFF ICER SHOULD RECORD IN THE ASSESSMENT ORDER HIS SATISFACT ION THAT THE ASSESSEE HAD EITHER CONCEALED THE INCOME O R FURNISHED INACCURATE PARTICULARS OF INCOME IN HIS R ETURN BEFORE IMPOSING PENALTY, WE NOTICED THAT IN THE ASSESSMENT ORDERS PASSED BY THE ASSESSING OFFICER F OR THE ASSESSMENT ORDERS PASSED BY THE ASSESSING OFFIC ER FOR THE ASSESSMENT YEAR 198283 (WHICH IS THE SUBJEC T MATTER OF I.T.T.A NO. 29 OF 2000) AND FOR THE ASSESSMENT YEAR 198384 (WHICH IS SUBJECT MATTER OF ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 8 I.T.T.A. NO. 33 OF 2000), NO SUCH SATISFACTION IS RECORDED. 6. ANOTHER DECISION OF SUPREME COURT IN CASE OF DIL IP N. SHOOFF VS. JOINT COMMISSIONER OF INCOME TAX & ANR. (2007) 291 ITR 519 (SC) IT HAS BEEN HELD AS UNDER:- IT IS OF SOME SIGNIFICANCE THAT IN THE STANDARD PR OFORMA USED BY THE ASSESSING OFFICER IN ISSUING A NOTICE D ESPITE THE FACT THAT THE SAME POSTULATES THAT INAPPROPRIAT E WORDS AND PARAGRAPHS WERE TO BE DELETED, BUT THE SA ME HAD NOT BEEN DONE. THUS, THE ASSESSING OFFICER HIMS ELF WAS NOT SURE AS TO WHETHER HE HAD PROCEEDED ON THIS BASIS THAT THE ASSESSEE HAD CONCEALED HIS INCOME OR HE HAD FURNISHED INACCURATE PARTICULARS. EVEN BEFORE U S, THE LEARNED ADDITIONAL SOLICITOR GENERAL WHILE PLACING THE ORDER OF ASSESSMENT LAID EMPHASIS THAT HE HAD DEALT WITH BOTH THE SITUATIONS. THE IMPUGNED ORDER, THEREFORE, SUFFERS FROM NON- APPLICATION OF MIND. IT WAS ALSO BOUND TO COMPLY WI TH THE PRINCIPLES OF NATURAL JUSTICE. THE INCOME TAX OFFICER HAD MERELY HELD THAT THE ASSESSEE IS GUILTY OF FURNISHING OF INACCURATE PART ICULARS AND NOT OF CONCEALMENT OF INCOME; WHICH FINDING WAS ARRIVED AT ALSO BY THE COMMISSIONER OF INCOME TAX A ND THE INCOME TAX APPELLATE TRIBUNAL. IN THE FACTS AND CIRCUMSTANCES OF THE CASE, THERE ARE ENOUGH MATERIA L TO ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 9 SHOW THAT THE ACTION ON THE PART OF THE APPELLANT M AY NOT BE SAID TO BE SUCH WHICH WOULD ATTRACT THE PENA L PROVISION UNDER S. 271(1)(C). FOR THE REASONS AFOREMENTIONED, THE IMPUGNED JUDGMENT CANNOT BE SUSTAINED. 7. HE CONTENDED THAT WHILE CONCLUDING THE ASSESSMEN T ORDER THE OFFICER MUST BE CLEAR WHETHER IT IS THE C ONCEALMENT OF INCOME OR FURNISHING OF INACCURATE DETAIL. HE CA NNOT HAVE BOTH THE THINGS. 7.1 HOWEVER, MR. SINGHI APPEARING FOR THE DEPARTMEN T SUBMITS THAT A PERUSAL OF THE ORDER OF PENALTY MAKE S IT AMPLY CLEAR THAT BOTH THE THINGS ARE FULFILLED. IN THAT V IEW OF THE MATTER THE VIEW TAKEN BY THE TRIBUNAL IS REQUIRED T O BE ACCEPTED. 8. WE HAVE HEARD MR. PRAKUL KHURANA AND MR. ANUROO P SINGHI. 9. TAKING INTO CONSIDERATION THE DECISION OF THE AN DHRA PRADESH HIGH COURT WHICH VIRTUALLY CONSIDERED THE S UBSEQUENT LAW AND THE LAW WHICH WAS PREVAILING ON THE DATE THE DE CISION WAS RENDERED ON 27.08.2012. IN VIEW OF THE OBSERVATIONS MADE IN THE SAID JUDGMENT, WE ARE OF THE OPINION THAT THE CONTE NTION RAISED BY THE APPELLANT IS REQUIRED TO BE ACCEPTED AND IN THE FINDING OF ASSESSING OFFICER IN THE ASSESSMENT ORDER IT IS HEL D THAT THE AO HAS TO GIVE A NOTICE AS TO WHETHER HE PROPOSES TO L EVY PENALTY FOR CONCEALMENT OF INCOME OR FURNISHING INACCURATE PART ICULARS. HE ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 10 CANNOT HAVE BOTH THE CONDITIONS AND IF IT IS SO HE HAS TO SAY SO IN THE NOTICE AND RECORD A FINDING IN THE PENALTY ORDE R. 10. IN THAT VIEW OF THE MATTER, THE ISSUE IS ANSWER ED IN FAVOUR OF THE ASSESSEE AND AGAINST THE DEPARTMENT. THE APPEAL IS ACCORDINGLY ALLOWED. WE THEREFORE FIND THAT THE LD CIT(A) HAS NOT CONSID ERED THE ABOVE ASPECT OF THE MATTER AND MERELY FOR THE REASON THAT ASSESSMENT ORDER HAS BEEN CONFIRMED IN QUANTUM PROCEEDINGS BY THE TRIBUNAL, HE HAS CONFIRMED THE LEVY OF PENALTY EX-PARTE QUA THE ASSESSEE. GIVEN THE PECULIAR FACTS AND CIRCUMSTANCES OF THE P RESENT CASE, WE BELIEVE THAT THE ASSESSEE DESERVE ONE MORE OPPORTUN ITY AND WE ACCORDINGLY DEEM IT APPROPRIATE TO SET-ASIDE THE MA TTER TO THE FILE OF THE LD CIT(A) TO DECIDE THE SAME AFRESH TAKING I NTO CONSIDERATION AFORESAID DISCUSSION AFTER PROVIDING REASONABLE OPPORTUNITY TO THE ASSESSEE. NEEDLESS TO SAY, THE ASSESSEE SHOULD ATTEND TO THE APPELLATE PROCEEDINGS BEFORE THE LD C IT(A) AND COOPERATE IN TIMELY COMPLETION OF THE APPELLATE PRO CEEDINGS. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOW ED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 15/01/2020. SD/- SD/- FOT; IKY 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:- 15/01/2020. ITA NO. 573/JP/2019 SMT. LEELA DEVI BUMB VS. ITO 11 *SANTOSH VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SMT. LEELA DEVI BUMB, BIJAINAGAR. 2. IZR;FKHZ@ THE RESPONDENT- ITO, WARD-1, BEAWAR. 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. 573/JP/2019} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR