SMT. KAMLESH TIWARI, Jaipur V. ITO, Jaipur

ITA 587/JPR/2013

• Counselvise Citation: 58723114 RSA 2013
• Duration Of Justice: 1 year(s) 8 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-02-2015
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2008-2009
• Appeal Filed On: 30-05-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: P D VAIDYA
• Keywords: Sale consideration of property below Jantri Value; Value adopted by valuation officer; Capital asset; Principle of natural justice; Reason to believe
• Section: 50C; 147; 148

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 VKJ-IH-RKSYKUH] U;KF;D LNL; ,OA JH VH-VKJ-EHUK] YS[KK LNL; DS LE{K BEFORE: SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM VK;DJ VIHY LA- @ ITA NO. 587/JP/2013 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2008-09 SMT. KAMLESH TIWARI 1, NANDANVAN, MAHAVEER NAGAR, TONK ROAD, JAIPUR. CUKE VS. THE I.T.O. WARD 5(3), JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ L A-@ PAN/GIR NO.: AANPT 4872 G VIHYKFKHZ @ APPELLANT IZR;FKHZ @ RESPONDENT FU/KZKFJRH DH VKSJ LS @ ASSESSEE BY : SHRI R.S. SINGHVI & SHRI P.D. VAIDYA (C.A.) JKTLO DH VKSJ LS @ REVENUE BY : SHRI AJAY MALIK (ADDL.CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 04/12/2014 ?KKS'K .KK DH RKJH[ K @ DATE OF PRONOUNCEMENT : 27/02/2015 VKNS'K @ ORDER PER: T.R. MEENA, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER DATED 19/03/2013 PASSED BY THE LEARNED CIT (A)-II, JAIPUR FOR A.Y. 2008-09. THE EFFECTIVE GROUNDS OF APPEAL ARE AS UNDER:- 1) THAT THE IMPUGNED ORDER PASSED U/S 143(3)/148 OF THE INCOME-TAX ACT, 1961 BY LEARNED ITO, WARD-5(3) AND LEARNED CIT(APPEALS)-II, JAIPUR IS BAD IN LAW AS ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 2 WELL AS ON FACTS BEING AGAINST THE PRINCIPLE OF NATU RAL JUSTICE AND FOR OTHER REASONS. 2) THAT THE LEARNED ASSESSING OFFICER HAS NOT FOLLOWE D THE REQUIRED PROCEDURE IN REVENUE-OPENING OF THE ASSESSMENT U/S 148 OF THE INCOME TAX ACT. HENCE ANY PROCEEDINGS INITIATED ON WRONG PREMISES OR AGAINST THE PROVISIONS OF THE ACT IS ILLEGAL SINCE INITIATION, HENCE THE ORDER NEEDS TO BE QUASHED IN ENTIRETY. 3) THAT THE LEARNED ASSESSING OFFICER HAS GROSSLY E RRED IN CONSIDERING FULL REGISTRATION VALUE OF RS. 98,20,156/- AND LEARNED CIT(APPEALS) HAVE ALSO ERRED IN GIVING PART RELIEF AND TAKING THE SALE CONSIDERATION AT RS. 47,34,400/- AS AGAINST THE SAL E CONSIDERATION OF RS. 27,00,000/- ACTUALLY RECEIVED BY THE ASSESSEE WHILE CALCULATING THE CAPITAL GAIN. 4) THAT THE LEARNED ASSESSING OFFICER HAS GROSSLY ER RED IN NOT REFERRING THE MATTER TO THE VALUATION CELL A S REQUIRED UNDER SECTION 50C(2) OF INCOME-TAX ACT, 1961, IF THE ASSESSING OFFICER INTENDED TO ADOPT VALUATION DONE BY THE REGISTRATION AUTHORITIES, AS AGAINST THE ACTUAL SALE CONSIDERATION RECEIVED IN V IEW OF THE PROVISIONS OF LAW AND ALSO AS PRINCIPLES OF NATURAL JUSTICE. 5(I) THAT THE LEARNED ASSESSING OFFICER HAS GROSSLY ERRED IN IGNORING THE FACT THAT THE AGREEMENT ON WHICH TH E SALE IS FINALLY CONCLUDED WAS ENTERED IN 2005 AND PART CONSIDERATION WAS HANDED OVER THROUGH CHEQUE BUT DUE TO UNAVOIDABLE CIRCUMSTANCES DEVELOPMENT AGREEMENT GOT CONVERTED INTO SALE AGREEMENT BY THAT TIME THE DEVELOPER HAD PARTLY CONSTRUCTED THE BUILDING, WHICH HAS RESULTED IN DECREASE IN VALUATIO N OF LAND. II) THAT DEVELOPMENT AGREEMENT WAS OF YEAR 2005. HENCE EVEN IN THE WORST CONDITION, DLC RATE OF 2005 SHOULD HAVE BEEN CONSIDERED. OUR ABOVE SUBMISSIONS ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 3 FORTIFIED BY THE FACT THAT IN THE RECENT BUDGET, AN ACT HAS BEEN AMENDED ON THE LINES SUBMITTED IN OUR GROUNDS OF APPEAL. 6) THAT THE ASSESSEE RESERVES HIS RIGHT TO ADD, ALTE R, AMEND, DELETE ALL OR ANY GROUNDS BEFORE OR AT THE TIME OF HEARING. 2. THE SECOND GROUND OF THE APPEAL IS AGAINST CHALLE NGING THE VALIDITY OF NOTICE U/S 148 OF THE INCOME TAX ACT, 19 61 (HEREINAFTER REFERRED TO AS THE ACT). AS PER AIR INFORMATION REC EIVED FROM CIB, IT CAME TO NOTICE THAT THE SALE VALUE OF RS. 98,20,156 /- OF A PROPERTY AT KHASRA NO. 124, VILLAGE- SALADVAS THAMER, JAIPUR SOL D BY THE ASSESSEE WAS ADOPTED BY THE SUB-REGISTRAR. ON THE OTHER HAND, THE ASSESSEE HAD DECLARED THIS PROPERTY SOLD AT RS. 27 LACS ONLY AND CALCULATED CAPITAL GAIN ACCORDINGLY. THE LEARNED ASSESSING OFFICER OBSE RVED THAT AS PER SECTION 50C, THE VALUE ADOPTED BY THE SUB-REGISTRAR I.E. RS. 98,20,156/- IS TO BE TAKEN AS FULL VALUE OF CONSIDE RATION. THERE WAS DIFFERENCE OF RS. 71,20,156/- IS LIABLE TO BE TREAT ED AS INCOME FROM CAPITAL GAIN. THEREFORE, NOTICE U/S 148 OF THE ACT WA S ISSUED AFTER RECORDING REASONS THAT IN THIS CASE, THE INCOME CHA RGEABLE TO TAX HAS BEEN ESCAPED. THE ASSESSEE CHALLENGED THIS ISSUE BE FORE THE LEARNED CIT(A), WHO HAS CONFIRMED THE ISSUE BY OBSERVING TH AT THE ASSESSING OFFICER HAD REASON TO BELIEVE THAT THE INCOME HAS E SCAPED ASSESSMENT. ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 4 HE WAS RIGHT IN REOPENING THE ASSESSMENT U/S 147 REA D WITH SECTION 149 BECAUSE 4 YEARS HAS NOT BEEN ELAPSED FROM THE E ND OF THE ASSESSMENT YEAR, THEREFORE, THE ASSESSING OFFICER H AS POWER TO REOPEN THE CASE AFTER RECORDING HIS SATISFACTION U/S 147 O F THE ACT. ACCORDINGLY, HE DISMISSED THE ASSESSEES APPEAL ON THIS GROUND. 3. THE ASSESSEE CHALLENGED THE ORDER OF THE LEARNED CIT(A) ON 148 NOTICE AND ARGUED THAT THE ASSESSING OFFICER RECEIV ED THE INFORMATION FROM CIB REGARDING STAMP VALUATION OF THE LAND AND SUCH REOPENING WAS NOT JUSTIFIED FOR WHICH HE RELIED UPON THE DECISION OF HONBLE ALLAHABAD HIGH COURT IN THE CASE OF FUSION ELECTRONICS PVT. L TD. VS. CCIT 9 TAXMANN.COM 189 (2011) AND DECISION OF THE HONBLE M ADRAS HIGH COURT IN THE CASE OF CIT VS. K RAJAPANDIAN (2009) 31 1 ITR 477 (MAD) FOR REOPENING ON THE BASIS OF DVO REPORT. HE ALSO R ELIED ON THE DECISION OF THE HONBLE BOMBAY HIGH COURT IN THE CASE OF ICI CI HOME FINANCE CO. LTD. VS. ACIT 25 TAXMANN.COM 241 (2012) FOR REASO NABLE BELIEVE OF THE ASSESSING OFFICER NOT ANY OTHER AUTHORITY. THE L EARNED AR ALSO CITED VARIOUS DECISIONS ON DVOS REPORT AND REOPENING ON ACCOUNT OF THE REPORT. THEREFORE, HE PRAYED TO QUASH THE 148 NOTICE . 4. AT THE OUTSET, THE LEARNED DR SUPPORTED THE ORDE R OF BOTH THE AUTHORITIES AND ARGUED THAT THE REOPENING IS WITHIN 4 YEARS AND THE ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 5 LEARNED ASSESSING OFFICER RECORDED REASONS AND HAD REASON TO BELIEVE ON THE BASIS OF CIB INFORMATION. THE CIB INFORMATIO N DOES NOT GIVE ANY IDEA OF REASON TO BELIEVE SIMPLY AN INFORMATION PAS SED ON BY THE ONE AUTHORITY TO ANOTHER, WHICH CAN BE USED IN CASE OF A SSESSEE WHEN CONCERNED ASSESSING OFFICER SATISFIED HIMSELF THAT THERE WAS AN UNDER ASSESSMENT OF INCOME. 5. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON THE RECORD. THE LE ARNED ASSESSING OFFICER HAS VAST POWER U/S 147 WITHIN FOUR YEARS WHEN THERE WAS NO SCRUTINY ASSESSMENT IN THE CASE OF THE ASSESSEE. TH E CASE LAWS CITED BY THE LEARNED COUNSEL FOR THE ASSESSEE ARE SQUARELY N OT APPLICABLE. THE INFORMATION RECEIVED FROM CIB IS SIMPLE INFORMATION , HAS NOT CONSTRUED ANY OPINION. IT IS FOR ASSESSING OFFICER TO DECIDE WHETHER THIS INFORMATION CAN BE PART OF THE REASON TO BELIEVE OR NOT. IN THIS CASE, IT IS UNDISPUTED FACT THAT THE ASSESSEE HAS NOT TAKEN SAL E CONSIDERATION OF THE IMMOVEABLE PROPERTY AS PER SECTION 50, WHICH IS DEEMING PROVISION ON COMPUTATION OF CAPITAL GAIN. THEREFORE, WE CONFIRM THE REOPENING MADE BY THE LEARNED ASSESSING OFFICER, CONFIRMED BY THE LEARNED CIT(A). THIS GROUND OF ASSESSEES APPEAL IS DISMISSED . ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 6 6. THE GROUNDS NO. 1,3,4 AND 5 OF THE ASSESSEES APP EAL ARE AGAINST TAKING SALE VALUE CONSIDERATION ON THE BASIS OF SAL E DEED FOR STAMP VALUATION AND COMPUTING CAPITAL GAIN AT RS. 77,17,0 29/-. THE LEARNED ASSESSING OFFICER HAS CALCULATED THE CAPITAL GAIN O N THE BASIS OF SALE VALUE CONSIDERATION ADOPTED BY THE SUB-REGISTRAR AT RS. 98,20,156/- IN PLACE OF 27 LACS DECLARED BY THE ASSESSEE. THE LEARN ED AR FOR THE ASSESSEE SUBMITTED BEFORE THE ASSESSING OFFICER THA T SALE VALUE ADOPTED BY THE STAMP AUTHORITY COULD NOT BE CONSIDERED SALE VALUE OF THE PROPERTY U/S 50C OF THE ACT TO CALCULATE THE CAPITA L GAIN. HE FURTHER SUBMITTED THAT THE ASSESSEE ENTERED IN AN AGREEMENT WITH THE BUYER OF THE LAND ON 19/09/2005 TO CONSTRUCT COMMERCIAL COMP LEX ON THIS LAND. AS PER AGREEMENT, SOME CONSTRUCTION WORK WAS DONE BUT THE TRANSACTION COULD NOT BE MATERIALIZED. SINCE THE AS SESSEE WAS IN NEED OF MONEY AND SOLD THE LAND TO THE BUYER ON AGREED PRIC E OF RS. 27 LACS. LEAVING THE COST OF CONSTRUCTION, WHICH WAS INCURRED BY THE BUYER UNDER THE AGREEMENT AND THE ASSESSEE RECEIVED RS. 27 LACS FROM THE BUYER AS FULL VALUE OF CONSIDERATION BUT THE LEARNED ASSESSI NG OFFICER AFTER CONSIDERING SECTION 50C OF THE ACT HAS TAKEN THE DE EMED VALUE OF SALE CONSIDERATION AT RS. 98,20,156/-. ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 7 7. BEING AGGRIEVED BY THE ORDER OF THE ASSESSING OF FICER, THE ASSESSEE CARRIED THE MATTER BEFORE THE LEARNED CIT( A), WHO HAD ALLOWED THE APPEAL PARTLY BY OBSERVING THAT THE STAMP VALUA TION AUTHORITY HAD TAKEN SALE CONSIDERATION VALUE OF LAND AT RS. 47,34 ,400/-. THE ASSESSEE HAS SOLD ONLY LAND NOT CONSTRUCTION, THEREFORE, VAL UATION ADOPTED BY THE STAMP AUTHORITY FOR STAMP PURPOSES AT RS. 50,85,756 /- CANNOT BE CONSIDERED AS PART OF SALE CONSIDERATION FOR THE PU RPOSE OF COMPUTING CAPITAL GAIN. ACCORDINGLY SHE DIRECTED TO THE ASSES SING OFFICER TO RECOMPUTE THE CAPITAL GAIN ON SALE OF LAND BY CONSI DERING THE STAMP VALUE FOR RS. 47,34,400/-. 8. NOW THE ASSESSEE IN THE APPEAL BEFORE US. LEARNED A.R. FOR THE ASSESSEE SUBMITTED THAT THE ALE CONSIDERATION ON TH E BASIS OF STAMP VALUE ADOPTED BY THE LEARNED ASSESSING OFFICER AT R S. 98,20,156/- IS NOT CORRECT AND TENABLE. THIS STAMP VALUATION MADE BY TH E STAMP AUTHORITY CONSTITUTE TO VALUATION I.E. (I) LAND VALUATION AT RS. 47,34,400/- AND (II) CONSTRUCTION VALUATION AT RS. 50,85,756/-. IT IS FU RTHER ARGUED THAT CONSTRUCTION EXPENSES WERE BORNE BY THE BUYER, WHICH HAS NOT BEEN INCLUDED IN THE SALE CONSIDERATION. HOWEVER, THE ACT UAL SALE CONSIDERATION OF THE LAND WAS AT RS. 27 LACS. THE LEA RNED ASSESSING OFFICER DID NOT REFER THIS PROPERTY TO THE VALUATIO N OFFICER TO FIND OUT THE ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 8 ESTIMATED VALUE OF THE LAND. HE SIMPLY ADOPTED THE STAMP AUTHORITYS FIGURE AS SALE CONSIDERATION. THUS, HE PRAYED TO DEL ETE THE ADDITION. FURTHER HE ARGUED ON VARIOUS ASPECTS OF THE CAPITAL ASSETS U/S 45-1 REFERRED PARAS OF SALE DEED AND MARKET PRICE ETC.. THE APPELLANT WAS IN NEED OF MONEY AND THERE WAS DELAY IN COMPLETION OF P ROJECT, THE APPELLANT DECIDED TO SALE THE LAND TO THE DEVELOPER , WHO ALREADY STARTED THE CONSTRUCTION ON THE LAND. THEREFORE, THERE WAS N O ALTERNATE AVAILABLE WITH THE ASSESSEE OTHER THAN TO SALE THE L AND TO THE DEVELOPER. THE SALE CONSIDERATION DECIDED MUTUALLY AND AGREED B Y BOTH THE PARTIES WAS RS. 27 LACS. IT IS FURTHER ARGUED THAT AS PER SU B-SECTION (2) OF SECTION 50C OF THE ACT, THE LEARNED ASSESSING OFFIC ER WAS INCUMBENT UPON TO REFER THE MATTER TO THE VALUATION OFFICER. HE FURTHER ARGUED THAT IF THE ASSESSING OFFICER IS NOT SATISFIED WITH THE S ALE CONSIDERATION OFFERED BY THE ASSESSEE THEN HE MUST REFER THE VALU ATION MATTER TO THE VALUATION OFFICER, FOR WHICH HE RELIED UPON THE FOLL OWING CASE LAWS:- (I) MEGHRAJ BAID VS. ITO (2008) 23 SOT 25 (JODH). (II) ITO VS. SMT. MANJU RANI JAIN (2008) 24 SOT 24 ( DELHI). (III) AJMAL FRAGRANCES & FASHIONS (P) LTD. VS. ACI T CIRCLE 13(1) (2009) 34 SOT 57 (MUM). ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 9 THEREFORE, HE PRAYED TO DELETE THE ADDITION MADE UND ER THE HEAD CAPITAL GAIN. 8.1 LEARNED A.R. FURTHER RELIED UPON THE DECISION O F THE HONBLE PUNJAB & HARYANA HIGH COURT IN THE CASE OF CIT VS. C HANDNI BHUCHAR (2010) 323 ITR 510 AND THE DECISION OF THE HONBLE CALCUTTA HIGH COURT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT, SILIGURI GA NO. 3686 OF 2013 ITAT NO. 221 OF 2013 ORDER DATED 13 TH MARCH, 2014 AND PRAYED TO SET ASIDE THE ORDER TO THE ASSESSING OFFICER AND DI RECTED TO REFER THIS CASE TO THE DVO FOR VALUATION OF LAND ON DATE OF SA LE. 9. AT THE OUTSET, THE LEARNED DR VEHEMENTLY SUPPOR TED THE ORDER OF THE LEARNED CIT(A) AND ARGUED THAT THE AR OF THE A SSESSEE COULD NOT RAISE ANY OBJECTION AGAINST SALE CONSIDERATION EXCE PT EXPLAIN THE RECEIPT OF SALE CONSIDERATION AND HAD NOT REQUESTED BEFORE THE ASSESSING OFFICER TO REFER THIS MATTER TO THE DVO FOR VALUATI ON OF LAND. 10. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON THE RECORD. IT IS UNDISPUTED FACT THAT THE ASSESSEE SIMPLY CHALLENGED THE SALE CONSIDERATI ON ON THE BASIS OF STAMP VALUATION AUTHORITY BUT HAD NOT REQUESTED TO REFER THIS ISSUE TO THE DVO BUT THE HONBLE CALCUTTA HIGH COURT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT, SILIGURI (SUPRA) HAS HELD AS UNDER:- ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 10 FOR THE AFORESAID REASONS, WE ARE OF THE OPINION TH AT THE VALUATION BY THE DEPARTMENTAL VALUATION OFFICER, CO NTEMPLATED UNDER SECTION 50C, IS REQUIRED TO AVOID MISCARRIAGE OF JUSTICE. THE LEGISLATURE DID NOT INTEND THAT THE CAPITAL GAIN SHOULD BE FIXED MERELY ON THE BASIS OF THE VALUATION TO BE MA DE BY THE DISTRICT SUB-REGISTRAR FOR THE PURPOSE OF STAMP DUT Y. THE LEGISLATURE HAS TAKEN CARE TO PROVIDE ADEQUATE MACH INERY TO GIVE A FAIR TREATMENT TO THE CITIZEN/TAX PAYER. THER E IS NO REASON WHY THE MACHINERY PROVIDED BY THE LEGISLATURE SHOULD NOT BE USED AND THE BENEFIT THEREOF SHOULD BE REFUS ED. EVEN IN A CASE WHERE NO SUCH PRAYER IS MADE BY THE LEARNE D ADVOCATE REPRESENTING THE ASSESSEE, WHO MAY NOT HAVE BEEN PROPERLY INSTRUCTED IN LAW, THE ASSESSING OFFICER, D ISCHARGING A QUASI JUDICIAL FUNCTION, HAS THE BOUNDEN DUTY TO ACT FAIRLY AND TO GIVE A FAIR TREATMENT BY GIVING HIM AN OPTIO N TO FOLLOWING THE COURSE PROVIDED BY LAW. FOR THE AFORESAID REASONS, THE ORDER UNDER CHALLENG E IS SET ASIDE. THE IMPUGNED ORDER INCLUDING ORDERS PASSED BY THE CI T(A) AND THE ASSESSING OFFICER ARE ALL SET ASIDE. THE MAT TER IS REMANDED TO THE ASSESSING OFFICER. HE SHALL REFER T HE MATTER TO THE DEPARTMENTAL VALUATION OFFICER IN ACCORDANCE WITH LAW. AFTER SUCH VALUATION IS MADE, THE ASSESSMENT SHALL BE MADE DO NOVO IN ACCORDANCE WITH LAW. THE FACTS OF THE CASE ARE IDENTICAL TO CASE REFERRED BY THE HONBLE CALCUTTA HIGH COURT, THEREFORE, WE ARE OF THE CONSID ERED VIEW THAT THE ITA 587/JP/2013_ SMT. KAMLESH TIWARI VS. ITO 11 MATTER IS REQUIRED TO BE SET ASIDE TO THE ASSESSING OFFICER. THE ASSESSING OFFICER IS DIRECTED TO REFER THE VALUATIO N OF LAND TO THE DVO FOR THE PURPOSE OF VALUATION OF THE LAND ON THE DAT E OF SALE. ACCORDINGLY, THE MATTER IS SET ASIDE TO THE ASSESSING OFFICER. 11. IN THE RESULT, THE ASSESSEES APPEAL IS ALLOWED FOR STATISTICAL PURPOSES ONLY. ORDER PRONOUNCED IN THE OPEN COURT ON 27/02/2015. SD/- SD/- VKJ-IH-RKSYKUH VH-VKJ-EHUK (R.P.TOLANI) (T.R. MEENA) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ @ JAIPUR FNUKAD @ DATED:- 27 TH FEBRUARY, 2015 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- SMT. KAMLESH TIWARI, JAIPUR. 2. IZR;FKHZ @ THE RESPONDENT- THE ITO, WARD 5(3), JAIPUR. 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. 587/JP/2013) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR