DCIT, Alwar V. BRITISH HEALTH PRODUCTS (I) LTD., BHIWADI

ITA 60/JPR/2015

• Counselvise Citation: [2017] 130 COUNSELVISE.COM (IT) 5584 (ITAT-JAIPUR)
• Duration Of Justice: 2 year(s) 1 month(s) 2 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 21-02-2017
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2011-2012
• Appeal Filed On: 19-01-2015
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Keywords: Gross profit estimation; Question of law; Difference of opinion
• Section: 32; 147; 131; 68; 246; 69; 145; 27; 148; 54; 37; 6; 56; 263; 63; 132; 12; 28; 144; 10; 90; 154; 2; 11; 15; 271(1)(b); 139; 143(3); 92; 145(3)

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 HKKXPUN] YS[KK LNL; ,O JH DQY HKKJR] U;KF;D L NL; DS LE{K BEFORE: SHRI BHAGCHAND, AM & SHRI KUL BHAR AT, JM VK;DJ VIHY LA-@ ITA NO. 60/JP/2015 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2011-12 THE DCIT CIRCLE- 2, ALWAR CUKE VS. M/S. BRITISH HEALTH PRODUCTS (I) LTD. A-581 (B), INDUSTRIAL AREA, BHIWADI, ALWAR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: AAACB 7093 F VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT VK;DJ VIHY LA-@ ITA NO. 65/JP/2015 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2011-12 M/S. BRITISH HEALTH PRODUCTS (I) LTD. A-581 (B), INDUSTRIAL AREA, BHIWADI, ALWAR CUKE VS. THE JCIT RANGE-2, ALWAR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: AAACB 7093 F VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT JKTLO DH VKSJ LS@ REVENUE BY :SHRI ANIL KUMAR - DR FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY: NONE LQUOKBZ DH RKJH[K@ DATE OF HEARING : 21/02/2017 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 21/02/2017 VKNS'K@ ORDER PER BHAGCHAND, AM SINCE THERE WAS A DIFFERENCE OF OPINION BETWEEN TH E LEARNED MEMBERS, CONSTITUTING A DIVISION BENCH OF I.T.A.T., JAIPUR, THE HONBLE PRESIDENT, I.T.A.T. NOMINATED SHRI BHAVNESH SAINI, JUDICIAL MEMBER AS THIRD MEMBER. THE HONBLE THIRD MEMBER VIDE ORDER DATED 14.02.2017 ITA NO. 60/JP/2015 THE DCIT,CIRCLE- 2, ALWAR VS. M/S. BRIT ISH HEALTH PRODUCTS (I) LTD., BHIWADI, ALWAR 2 CONCURRED WITH THE FINDINGS OF THE HONBLE JUDICIAL MEMBER AND HELD AS UNDER :- 5. I HAVE CONSIDERED THE RIVAL SUBMISSIONS AND PE RUSED THE MATERIALS AVAILABLE ON RECORD. THE ASSESSEE COMPANY WAS ENGAGED IN THE MANUFACTURING OF PRODUCTS BOTH IN HEALTH FOOD, AYURVEDIC SECTOR AND HAD DERIVED INCOME FROM SUCH ACTIVITIES. THERE IS NO CHANGE IN THE BUSINESS OF THE ASSESSEE COMPANY AS COMPARED TO THA T OF EARLIER YEARS. THE ASSESSING OFFICER EXAMINED THE BOOKS OF ACCOUNT OF THE ASSESSEE AT THE ASSESSMENT PROCEEDINGS AS WELL AS AT THE REM AND PROCEEDINGS. THE ASSESSING OFFICER FOUND THAT THERE WAS LOW GP A ND NP RATIO IN THE YEAR UNDER CONSIDERATION AS COMPARED TO EARLIER YEA RS. THE ASSESSEE FILED DETAILS BEFORE THE ASSESSING OFFICER AND IT W AS EXPLAINED THAT THE DECREASE IN GP AND NP WERE DUE TO INCREASE IN THE C OST OF MATERIAL AND EXCISE DUTY. THE ASSESSEE ALSO PRODUCED BILLS FOR C ONSIDERATION OF THE ASSESSING OFFICER. IT IS NOT IN DISPUTE THAT DURING THE YEAR UNDER CONSIDERATION THE ASSESSEE HAS ALSO STARTED MANUFAC TURING OF NEW PRODUCE I.E. GLUCOSE. THE ASSESSEE HAD PREPARED A RECASTED TRADING/ MANUFACTURING ACCOUNT WHICH WAS BEFORE THE ASSESSIN G OFFICER IN THE REMAND PROCEEDINGS AND SAID DETAILS WERE FILED BEF ORE THE LD. CIT (A). THE REPLY OF THE ASSESSEE BEFORE THE LD. CIT ( A) IS FILED AT PAGE 106 OF THE PAPER BOOK IN WHICH IT WAS EXPLAINED THA T ASSESSEE PRODUCED ANNUAL STOCK REGISTER PROVIDING DETAILS OF OPENING STOCK, TOTAL ANNUAL PURCHASE ITEM WISE, CONSUMPTION AND CLOSING STOCK. ALL ORIGINAL BILLS OF PURCHASE AND LEDGER WERE PRODUCED. THE FALL IN G P WAS MAINLY FOR INCREASE IN THE COST OF RAW MATERIAL AS COMPARED TO THE EARLIER YEARS WHICH IS CLARIFIED AT PAGE 109 OF THE PAPER BOOK AN D IS ALSO REPRODUCED AT PAGE 6 OF THE ORDER OF LD. JUDICIAL MEMBER. IT W AS, THEREFORE, EXPLAINED THAT DUE TO INCREASE IN THE COST OF CONSU MPTION OF RAW MATERIAL AND PACKAGING MATERIAL THERE WAS A FALL IN GP AND NP. THESE DETAILS WERE ON CONSOLIDATED BASIS INCLUDING THE ST ART OF COMMERCIAL PRODUCTION OF GLUCOSE DURING THE YEAR UNDER CONSIDE RATION. THE GP MARGIN OF THE GLUCOSE WAS LESSER AS COMPARED TO OTH ER ITEMS. THE ASSESSING OFFICER HAS NOT ADVERSELY COMMENTED UPON THE EXPLANATION OF THE ASSESSEE IN THE REMAND R PORT. THE ASSESSING OFFICER HAS NOT POINTED OUT ANY SPECIFIC DEFECT IN MAINTENANCE OF B OOK OF ACCOUNTS WHAT-SO-SEVER IN THE REMAND REPORT ON THE EXPLANATI ON OF THE ASSESSEE. THE ASSESSEE ALSO FILED RECONCILIATION OF THE ACCOU NTS OF THREE PARTIES NAMELY M/S RIDHI SIDHI GLUCO BILOS LTD, M/S SANAT PRODUCTS LTD AND M/S ANIL LTD. THE REMAND REPORT IS FILED IN THE PA PER BOOK AT PAGE 206 OF THE PAPER BOOK AND HAS ALSO BEEN REPRODUCED IN T HE ORDER OF THE LD. JUDICIAL MEMBER IN WHICH THE ASSESSEE OFFICER ASKED FOR COMPLETE DETAILS OF ALL THE THREE PARTIES WHICH WERE SUBMITT ED BEFORE THE ASSESSING OFFICER AND ASSESSING OFFICER ACCEPTED TH E EXPLANATION OF THE ASSESSEE WITH REGARD TO THE RECONCILIATION IN T HE ACCOUNT BALANCE OF M/S RIDHI SIDHI GULOC BIOLS AND M/S SANAT PRODUCTI ON LTD. HOWEVER, ITA NO. 60/JP/2015 THE DCIT,CIRCLE- 2, ALWAR VS. M/S. BRIT ISH HEALTH PRODUCTS (I) LTD., BHIWADI, ALWAR 3 NO ADVERSE COMMENTS HAVE BEEN GIVEN AGAINST M/S. AN IL LIMITED. THE ASSESSEE FILED COMPLETE DETAILS IN RESPECT OF M/S A NIL LTD BEFORE THE LD. CIT (A) AS WELL AS BEFORE ASSESSING OFFICER IN THE REMAND PROCEEDINGS AND ALSO FURNISHED COMPLETE DETAILS INC LUDING THE CONFIRMATION OF ACCOUNT AND CURRENT ADDRESS OF M/S ANIL LTD., THEREFORE, ON THE FACE OF EVIDENCES AND MATERIAL O N RECORD IN THE LIGHT OF REMAND REPORT OF THE ASSESSING OFFICER, NO ADVIS ERS INFERENCE CAN BE DRAWN IN RESPECT OF THE ALLEGED DIFFERENCE IN THE ACCOUNTS OF THREE PARTIES. THE ASSESSING OFFICER IN THE REMAND REPORT ALSO MENTIONED THAT ASSESSEE PRODUCED PRINT OUTS OF COMPUTERIZED DAY TO DAY STOCK REGISTER OF RAW MATERIAL AND PACKED MATERIAL AND PRODUCED T HE MANUAL REGISTER OF STOCK OF FURNISHED GOODS. IT IS ALSO ADMITTED F ACT THAT THE ASSESSEE AT THE ASSESSMENT STAGE HAD FILED QUANTITATIVE DETAILS OF VALUATION OF STOCK. THE LD. JUDICIAL MEMBER IN THE LIGHT OF THE EVIDENC E AND MATERIAL AVAILABLE ON RECORD AND REMAND REPORT OF THE ASSESS ING OFFICER NOTED THAT THE ENTIRE TRANSACTION WITH M/S ANIL LIMITED WERE CONDUCTED THROUGH BANKING CHANNEL. LD. JUDICIAL MEMBER ALSO A DDRESSED THE ISSUE WHETHER THE ASSESSING OFFICER WAS JUSTIFIED IN INVO KING THE PROVISIONS OF SECTION 145 (3) OF THE I.T. ACT. THE LD. JUDICIA L MEMBER CORRECTLY NOTED THAT WHERE THE ACCOUNTS ARE CONSISTENTLY MAIN TAINED BY THE ASSESSEE AND ACCEPTED IN PAST AND THERE IS NO MATER IAL TO INDICATE HOW THE METHOD OF ACCOUNTING WAS DEFECTIVE, ASSESSING O FFICER CANNOT REJECT METHOD OF ACCOUNTING. THE LD. JUDICIAL MEMBE R RIGHT NOTED THAT MERE FALL IN GP RATE BY ITSELF IS NO GROUND OF REJE CTING THE BOOKS OF ACCOUNT OF THE ASSESSEE. IN THE PRESENT CASE, THE ASSESSING OFFICER HAS ALLEGED MAINLY TWO REASONS FOR REJECTION OF BOOKS O F ACCOUNTS. I.E. THERE WAS DECLINE IN GP/NP AND THAT ACCOUNTS OF THREE PAR TIES HAVE NOT BEEN RECONCILED. THE ASSESSEE, HOWEVER, EXPLAINED BOTH T HE ISSUED BEFORE THE ASSESSING OFFICER AT THE ASSESSMENT STAGES AS WELL AS IN THE REMAND PROCEEDINGS. THE STOCK REGISTERED ALONG WITH QUANTI TATIVE DETAILS WERE ALSO FURNISHED AND ALL THE ITEMS OF THE ASSESSEE WE RE SUBJECT TO SCRUTINY BY EXCISE DEPARTMENT HAVE NOT BEEN ADVERSELY COMMEN DED UPON BY THE LD. ASSESSING OFFICER. THE ASSESSEE, THEREFORE, SUC CESSFULLY EXPLAINED THE FALL IN GP/NP RATE WHICH HAVE BEEN RIGHTLY CONS IDERED BY THE LD. JUDICIAL MEMBER, THEREFORE, THERE IS NO MATERIAL ON RECORD TO JUSTIFY THE REJECTION OF METHODS OF ACCOUNTING OR BOOKS OF ACCO UNT IN THE MATTER OR TO APPLY HIGHER GP/NP RATE IN THE MATTER. 6. THE HONBLE RAJASTHAN HIGH COURT IN THE CASE OF MALANI JAAGANNATH VS. ACIT [( 2009) 316 ITR 120 ( RAJ.) HELD AS UNDER:- HELD THAT ACCOUNT BOOKS WERE MAINTAINED AS THEY WE RE ORDINARILY MAINTAINED YEAR AFTER YEAR WHICH WERE FO UND TO YIELD A FAIR RESULT. MERE DEVIATION IN THE GROSS PROFIT R ATE CANNOT BE A GROUND FOR REJECTING THE BOOKS OF ACCOUNT AND ENTER ING THE REALM OF ESTIMATE AND GUESS WORK. THE LOWER GROSS P ROFIT RATE SHOWN IN THE BOOKS OF ACCOUNT DURING THE CURRENT YE AR AND FALL ITA NO. 60/JP/2015 THE DCIT,CIRCLE- 2, ALWAR VS. M/S. BRIT ISH HEALTH PRODUCTS (I) LTD., BHIWADI, ALWAR 4 IN THE GROSS PROFIT RATE WAS JUSTIFIED AND ALSO ADM ITTED BY THE ASSESSING OFFICER, THE COMMISSIONER ( APPEALS) AND THE TRIBUNAL. THEREFORE, FALL IN THE GROSS PROFIT RATE LOST ITS SIGNIFICANCE. HAVING ACCEPTED THE REASONS FOR THE F ALL IN THE GROSS PROFIT RATE, NAMELY STIFF COMPETITION IN THE MARKET AND HUGE LOSS CAUSED IN A PARTICULAR TRANSACTION, NEITH ER THE REJECTION OF THE BOOKS OF ACCOUNT NOR SUBSTITUTION OF AN ESTIMATED GROSS PROFIT BY RULE OF THUMB WAS JUSTIFI ED. THE ORDER OF THE COMMISSIONER (APPEALS) WAS CORRECT. 7. THE HONBLE PUNJAB & HARYANA HIGH COURT IN THE C ASE OF CIT VS OM OVERSEAS [2009] 315 ITR 185 (P&H) HELD AS UNDER:- THE ASSESSEE-FIRM DERIVED ITS INCOME FROM MANUFACTURING AND EXPORT OF DURIES, RUGS, WOOLLEN CARPETS, MADE UPS, ETC., AND FILED A NIL RETURN OF INCOME FOR THE ASSESSMENT YEAR 2001-02. SUBSEQUENTLY IT WA S ASSESSED UNDER SECTION 143(3) OF THE INCOME-TAX ACT , 1961 AND IT DECLARED GROSS PROFIT ON THE TOTAL TURN OVER OF 25.38 PER CENT AS AGAINST 29.5 PER CENT DECLARED I N THE IMMEDIATE PROCEEDING ASSESSMENT YEAR. BEING DISSATISFIED WITH THE EXPLANATION GIVEN BY THE ASSE SSEE, THE ASSESSING OFFICER REJECTED THE BOOKS OF ACCOUNT OF THE ASSESSEE INVOKING SECTION 145(3) AND APPLIED TH E GROSS PROFIT RATE OF 27 PER CENT. WHICH RESULTED IN CERTAIN ADDITIONS. THE COMMISSIONER (APPEALS) DELET ED THE ADDITIONS MADE BY THE ASSESSING OFFICER. THE TRIBUNAL UPHELD THE ORDER OF THE COMMISSIONER (APPEALS). ON FURTHER APPEAL: HELD, DISMISSING THE APPEAL, THAT THE FACTUAL FINDING GIVEN BY THE COMMISSIONER (APPEALS) THAT TH E ADDITIONS WERE MADE BY THE ASSESSING OFFICER WITHOU T POINTING OUT ANY SPECIFIC DEFECT IN THE BOOKS OF AC COUNT WAS UPHELD BY THE TRIBUNAL. AS NO PERVERSITY OR ILLEGALITY IN THE FINDING WAS POINTED OUT BY THE DEPARTMENT, NO SUBSTANTIAL QUESTION OF LAW AROSE FO R DETERMINATION. 8. THE HONBLE DELHI HIGH COURT IN THE CASE OF CIT VS JAS JACK ELEGANCE EXPORTS [2010] 324 ITR 95 ( DELH I) HELD AS UNDER:- HELD, DISMISSING THE APPEAL, THAT IT WAS NOT THE CASE OF THE REVENUE THAT THE ASSESSEE HAD NOT FOLLO WED EITHER THE CASE OR MERCANTILE SYSTEM OF ACCOUNTING STIPULATED IS SUB-SECTION (1) OF SECTION 145 OF THE ACT. IT WAS ALSO NOT THE CASE OF THE REVENUE THAT THE CENTR AL GOVERNMENT HAD NOTIFIED ANY PARTICULAR ACCOUNTING STANDARDS TO BE FOLLOWED BY MANUFACTURERS AND ITA NO. 60/JP/2015 THE DCIT,CIRCLE- 2, ALWAR VS. M/S. BRIT ISH HEALTH PRODUCTS (I) LTD., BHIWADI, ALWAR 5 EXPORTERS OF READY MADE GARMENTS. HENCE, THE SECOND PART OF SUB-SECTION (3) OF SECTION 145 DID NOT APPL Y. AS NOTED BY THE COMMISSIONER (APPEALS) AS WELL AS BY T HE TRIBUNAL, THE ASSESSING OFFICER HAD NOT POINTED OUT ANY DEFECT IN THE ACCOUNT BOOKS MAINTAINED BY THE ASSES SEE, WHICH, ADMITTEDLY, WERE PRODUCED BEFORE THE ASSESSI NG OFFICER FOR HIS CONSIDERATION. AS REGARDS NON-PRODU CTION OF STOCK REGISTER, THE ASSESSEE HAD GIVEN AN EXPLA NATION WHICH HAD BEEN ACCEPTED NOT ONLY THE COMMISSIONER ( APPEALS) BUT ALSO BY THE TRIBUNAL AND BOTH OF THEM HAD GIVEN A CONCURRENT FINDING OF FACT THAT MAINTAINING A STOCK REGISTER WAS NOT FEASIBLE CONSIDERING THE NATURE OF THE BUSINESS BEING RUN BY THE ASSESSEE WHICH WA S ENGAGED IN THE BUSINESS OF MANUFACTURING READYMADE GARMENTS BY PURCHASING FABRIC WHICH WAS THEN SUBJECTED TO EMBROIDERY, DYEING AND FINISHING AND T HEN CONVERTED INTO READY MADE GARMENTS BY STITCHING. TH E FAILURE OF THE ASSESSEE TO PRODUCE THE PERSONS TO WHOM PAYMENTS WERE MADE BY THE ASSESSEE FOR FABRICATION, EMBROIDERY AND DYEING AND FINISHING, ETC. COULD NOT HAVE BEEN A GROUND FOR REJECTING THE ACCOUNTS UNDE R SECTION 145 (3) OF THE ACT. THE ASSESSING OFFICER, INSTEAD OF APPLYING THE GROSS PROFIT RATE DECLARED IN THE IMMEDIATE PROCEEDING YEAR, APPLIED THE GROSS PROFIT RATE DECLARED IN THE ASSESSMENT YEAR 2003-03, THEREBY FA ILING TO MAINTAIN THE ACCEPTED PRINCIPLE OF CONTINUITY A ND CONSISTENCY. THE QUESTION WHETHER FALL IN GROSS PRO FIT STOOD EXPLAINED BY THE ASSESSEE OR NOT WAS A QUESTI ON OF FACT. BOTH THE TRIBUNAL AS WELL AS THE COMMISSIONER (APPEALS) HAD ACCEPTED THE EXPLANATION GIVEN BY THE ASSESSEE. NO SUBSTANTIAL QUESTION OF LAW AROSE FOR CONSIDERATION. 9. CONSIDERING THE ABOVE DISCUSSION IN THE LIGHT OF THE MATERIAL ON RECORD, IT IS CLEAR THAT ON BOTH THE PO INTS RAISED BY THE ASSESSING OFFICER, THE ASSESSEE EXPLAINED THE ISSUE S SATISFACTORILY. THERE WAS NO REASON TO REJECT THE BOOKS OF ACCOUNT U/S 145(3) OF THE I.T. ACT. IT IS NOT ALWAYS NECESSARY THAT THE PROFI T RATE WOULD REMAIN STATIC BECAUSE IT WOULD DEPEND UPON SEVERAL OTHER F ACTORS WHICH SHOULD BE CONSIDERED FROM THE POINT OF THE VIEW OF THE BUS INESSMAN. MERE LOW PROFIT BY ITSELF IS NO GROUND FOR REJECTION OF BO OKS OF ACCOUNT OF THE ASSESSEE. THE LD. JUDICIAL MEMBER WAS THEREFORE, JU STIFIED IN ALLOWING THE APPEAL OF THE ASSESSEE AND DISMISSING THE DEPAR TMENTAL APPEAL. THE LD. ACCOUNTANT MEMBER, HOWEVER, CONFIRMED THE REJEC TION OF THE BOOKS OF ACCOUNT U/S 145(3) AND DIRECTED THAT MATTE R BE REMANDED TO THE ASSESSING OFFICER FOR TAKING A DECISION AS PER LAW. WHEN SUFFICIENT MATERIAL WAS AVAILABLE ON RECORD AND LD. CIT (A) H AS ALREADY CALLED FOR THE REMAND REPORT FROM THE ASSESSING OFFICER AT APPELLATE STAGE, ITA NO. 60/JP/2015 THE DCIT,CIRCLE- 2, ALWAR VS. M/S. BRIT ISH HEALTH PRODUCTS (I) LTD., BHIWADI, ALWAR 6 THERE WAS NO REASON TO RESTORE THE MATTER BACK TO THE ASSESSING OFFICER FOR TAKING DECISION IN THE MATTER. THE MATT ER SHOULD HAVE BEEN DECIDED BY THE TRIBUNAL ITSELF AT THE SECOND APPELL ATE STAGE IN SUCH CIRCUMSTANCES. I, THEREFORE, DO NOT AGREE WITH THE FINDINGS OF THE LD. ACCOUNTANT MEMBER. I CONCUR WITH THE VIEW OF THE LD . JUDICIAL MEMBER THAT BOOKS OF ACCOUNT SHOULD NOT BE REJECT ED AND PROFIT DECLARED BY THE ASSESSEE FOR THE YEAR UNDER CONSID ERATION SHOULD NOT BE DISTURBED. I, THEREFORE, HOLD THAT ASSESSEE HAD GIV EN REASONABLE JUSTIFICATION FOR THE DECLINE IN GP AND NP RATE AND , THEREFORE, BOOKS OF ACCOUNT SHOULD NOT BE REJECTED U/S 145(3) OF THE I. T. ACT. IN THE FACTS AND CIRCUMSTANCES OF THE CASE. I, THEREFORE, AGREE WITH THE VIEW OF THE LD. JUDICIAL MEMBER. 2. THEREFORE, IN ACCORDANCE WITH MAJORITY VIEW, THE APPEAL OF THE ASSESSEE IS ALLOWED AND THAT OF THE REVENUE IS DISM ISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 21.02.2017 . SD/- SD/- DQY HKKJR HKKXPUN (KUL BHARAT) ( BHAGCHAND) U;KF;D LNL; / JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 21/02/ 2017 *MISHRA VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- THE DCIT, CIRCLE-2,/ JCIT RANGE -2 A LWAR 2. IZR;FKHZ@ THE RESPONDENT- M/S. BRITISH HEALTH PRODUCTS (I), ALWAR 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. 60/JP/2015) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ @ ASSISTANT. REGISTRAR P