RAMA STEEL ROLLING MILLS & GENERAL ENGG. WARKS, Jaipur V. ITO, Jaipur

ITA 695/JPR/2014

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 99598 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 2 month(s) 6 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-12-2015
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: 2007-2008
• Appeal Filed On: 10-10-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: O P BHATEJA CIT DHK
• Keywords: Bad and doubtful debts; Onus to prove

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 VH-VKJ-EHUK] YS[KK LNL; ,OA JH YFYR DQEKJ] U;KF; D LNL; DS LE{K BEFORE: SHRI T.R.MEENA, AM & SHRI LALIET KUMAR, JM VK;DJ VIHY LA -@ ITA NO. 695/JP/2014 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2007-08 M/S RAMA STEEL ROLLING MILLS & GENERAL ENGG. WORKS, 129, INDUSTRIAL AREA, JHOTWARA, JAIPUR. CUKE VS. I.T.O. WARD 3(1), JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO. AABFR 5933 L VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI P.C. PARWAL (CA) JKTLO DH VKSJ LS@ REVENUE BY : SHRI O.P. BHATEJA (ADDL.CIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 24/11/2015. MN?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 16/12/2015. VKNS'K@ ORDER PER T.R. MEENA, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER DATED 16/09/2014 OF THE LEARNED CIT(A)-I, JAIPUR FOR A.Y. 2007-08. THE EFFECTIVE GROUNDS OF APPEAL ARE AS UNDER:- 1. THE LD CIT(A) HAS ERRED ON FACTS AND IN LAW IN CON FIRMING THE ADDITION OF RS. 34,91,181/- U/S 41(1) BY HOLDIN G THAT THE ASSESSEE HAS FAILED TO PRODUCE SH. PARAS JAIN I N SPITE OF THE CLEAR DIRECTION OF THE HONBLE ITAT BY IGNOR ING THAT HONBLE ITAT IN THE ALTERNATIVE HAS ALSO STATED THAT THE 2 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO A.O. WILL BE FREE TO ADD BACK THE SAME AS PER LAW IF THE ASSESSEE IS UNABLE TO GIVE THE EXACT ADDRESS OF THE CREDITOR AND SINCE THE EXACT ADDRESS OF THE CREDITOR IS FURN ISHED, THE ADDITION CONFIRMED BY THE CIT(A) IS UNJUSTIFIED AND ALSO NOT AS PER LAW. 2. THE LD CIT(A) HAS ERRED ON FACTS AND IN LAW IN CONF IRMING THE ABOVE ADDITION EVEN WHEN THE ACCOUNT OF THE CRED ITOR HAS BEEN SETTLED IN F.Y. 201-11 AGAINST THE SALE OF GOODS WORTH RS. 30,70,467/- AND THE BALANCE OF RS. 4,20,41 7/- WRITTEN BACK AND OFFERED TO TAX. 2. THE ASSESSEE IS RUNNING A ROLLING MILL. IN THIS C ASE, THE HONBLE ITAT VIDE ORDER DATED 20/05/2011 HAD SET ASIDE THE ISSUE BY OBSERVING AS UNDER:- (I) WE THEREFORE FEEL THAT MATTER IS TO BE RESTORED BACK ON THE FILE OF THE A.O. TO ASCERTAIN AS TO WHETHER THE LIABILIT Y HAS CEASED OR NOT. THE A.O. MAY VERIFY THE DISCHARGING OF LIABI LITY TILL THE DATE OF FRESH ASSESSMENT AND IF THE LIABILITY HAS B EEN DISCHARGED TILL DATE THEN THERE WILL BE REMISSION OR CESSATION OF LIABILITY AS PER THE CREDITOR AND IF THE ASSESSEE F AILS TO PRODUCE THE CREDITOR OR UNABLE TO GIVE THE EXACT ADDRESS TH EN SUCH LIABILITY WILL STAND CEASED DURING THE YEAR AND A.O. WILL BE FREE TO ADD BACK THE SAME AS PER LAW. THE MATTER IS RESTORED BACK ON THE FILE OF THE A.O . TO BE DECIDED AFRESH AS PER THE FINDINGS GIVEN ABOVE. 3 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO THEREAFTER THE ASSESSING OFFICER GAVE REASONABLE OPP ORTUNITY OF BEING HEARD. THE FACT IS THAT THE LD ASSESSING OFFICER MAD E ADDITION U/S 41(1) OF THE INCOME TAX ACT, 1961 (IN SHORT THE ACT) AT RS. 3 4,91,181/- WHICH WAS DELETED BY THE LD CIT(A) BUT THE HONBLE ITAT HAD SE T ASIDE THE ISSUE TO THE ASSESSING OFFICER BY HOLDING THAT THE ASSESSING OFF ICER SHOULD VERIFY THE DISCHARGING OF LIABILITY TILL THE DATE OF FRESH ASS ESSMENT AND IF THE LIABILITY HAS BEEN DISCHARGED TILL DATE THEN THERE WILL BE REM ISSION OR CESSATION OF LIABILITY AS PER THE CREDITOR AND IF THE ASSESSEE F AILS TO PRODUCE THE CREDITOR OR UNABLE TO GIVE THE EXACT ADDRESS THEN SUCH LIABI LITY WILL STAND CEASED DURING THE YEAR. THE LD ASSESSING OFFICER IN COMPLIA NCE OF THIS DIRECTION HAD ISSUED NOTICE TO THE ASSESSEE AND ASKED TO FURNISH FRESH EVIDENCE REGARDING DISCHARGING OF LIABILITY IN RESPECT OF TIRUPATI STEE L. THE ASSESSEE FILED WRITTEN REPLY ON 23/2/203, WHICH HAS BEEN REPRODUCED BY THE ASSESSING OFFICER ON PAGE 6 OF THE ASSESSMENT ORDER. AFTER CONSIDERING T HE ASSESSEES REPLY, THE LD ASSESSING OFFICER HELD THAT THE ASSESSEE WAS ASKE D TO PRODUCE SHRI PARAS JAIN, PROPRIETOR OF M/S TIRUPATI STEELS FOR EXAMINAT ION. HOWEVER, THE ASSESSEE DID NOT PRODUCE SHRI PARAS JAIN, PROPRIETO R OF M/S TIRUPATI STEELS STATING THAT SHRI PARAS JAIN IS OUT OF STATION AND HE IS EXPECTED TO COME BACK AFTER MONTHS TIME AND REQUESTED TO GIVE APPROX IMATELY ONE MONTH TIME TO PRODUCE HIM, WHICH WAS NOT FOUND CONVINCING T O THE ASSESSING 4 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO OFFICER AND IN ABSENCE OF VERIFICATION OF THE CREDI TOR, THE FACTS CLAIMED BY THE AR OF THE ASSESSEE IN HIS SUBMISSIONS, REMAINED UNVERIFIABLE. THE ASSESSEE DID NOT PRODUCE SHRI PARAS JAIN FOR EXAMIN ATION ONLY IS SOLE MOTIVE TO AVOID THE TRUTH OF THE FACTS AND SHRI PAR AS JAIN WAS NOT IN AN EXISTENCE OTHERWISE HE WOULD HAVE PRODUCED HIM FOR EX AMINATION. THUS, THE ASSESSEE MADE A STORY TO SETTLE THE LIABILITY A S MENTIONED ABOVE AS SHRI PARAS JAIN WAS OUT OF STATION. HE COULD HAVE FURNISH ED INCOME TAX RETURN ALONGWITH COMPUTATION OF INCOME, P&L ACCOUNT OF SHRI PARAS JAIN FOR THE A.Y. 2011-12 BUT NOT MADE SO IN SUPPORT OF HIS CONT ENTION. IN ABSENCE OF IT PARTICULARS OF SHRI PARAS JAIN, THE CROSS EXAMINA TION OF THE TRANSACTIONS AS CLAIMED BY THE ASSESSEE COULD NOT BE VERIFIED A S SHRI PARAS JAIN, PROPRIETOR OF M/S TIRUPATI STEELS WOULD BE CLAIMED AT RS. 4,20,714/- AS BAD DEBTS IN HIS P&L ACCOUNT. IT IS IMPORTANT TO MENTIO N HERE THAT THE CASE IS GOING TO BE BARRED BY LIMITATION ON 31/3/2013 THE A SSESSING OFFICER WAS NOT IN POSITION TO GIVE FURTHER TIME TO PRODUCE SHRI PA RAS JAIN, PROPRIETOR OF M/S TIRUPATI STEELS AT THIS JUNCTURE AS THE SUFFICIENT T IME HAS ALREADY BEEN PROVIDED DURING THE ORIGINAL AS WELL AS SET ASIDE AS SESSMENT PROCEEDINGS. THEREFORE, HE GAIN MADE ADDITION U/S 41(1) OF THE AC T AT RS. 34,91,181/-. 5 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO 3. BEING AGGRIEVED BY THE ORDER OF THE LD ASSESSING OFFICER, THE ASSESSEE CARRIED THE MATTER BEFORE THE LD CIT(A), WH O HAD DISMISSED THE ASSESSEES APPEAL BY OBSERVING AS UNDER:- 4. I HAVE CONSIDERED FACTS OF THE CASE. IT IS NOTE D THAT IN THIS CASE THE ADDITION OF RS. 34,91,181/- ON ACCOUNT OF DEEME D INCOME U/S 41(1) WAS MADE BY THE A.O. WHICH WAS DELETED BY T HE FIRST APPELLATE AUTHORITY. ON SECOND APPEAL, THE HONBLE ITAT RESTORED THE MATTER TO THE FILE OF A.O. WITH THE DI RECTION THAT THE A.O. SHOULD ASCERTAIN AS TO WHETHER THE LIABILIT Y HAD CEASED OR NOT. THE HONBLE TRIBUNAL HAD ALSO OBSERVED THAT THE A.O. MAY VERIFY THE DISCHARGING OF LIABILITY AND IF THE APPELLANT FAILED TO PRODUCE THE CREDITOR OR WAS UNABLE TO GIVE THE EX ACT ADDRESS THEN SUCH LIABILITY WILL STAND CEASED DURING THE YEAR AND A.O. WILL BE FREE TO AD BACK THE SAME AS PER LAW. 5. IT WAS NOTED BY THE A.O. THAT DURING THE YEAR UND ER CONSIDERATION, THE APPELLANT HAD SHOWN SUNDRY CREDI TORS FOR GOODS SUPPLIED WORTH RS. 41,01,012/- WHICH INCLUDED T HE AMOUNT OF RS. 34,91,181/- IN THE NAME OF M/S TIRUPAT I STEELS. THE APPELLANT, HOWEVER, FAILED TO FURNISH ANY CONFIRM ATION OF ACCOUNT FROM THE SAID CREDITOR. THE AO, THEREAFTER C ALLED FOR INFORMATION U/S 133(6). FOR THIS PURPOSE THE INSPEC TOR WAS DEPUTED TO COLLECT INFORMATION FROM M/S TIRUPATI STE ELS. THE INSPECTOR REPORTED THAT NO SUCH ENTITY EXISTED AT T HE GIVEN ADDRESS, F450, ROAD NO. 12, VKI AREA, JAIPUR. THIS A DDRESS 6 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO WAS OCCUPIED BY M/S ABHISHEK POLYMERS, AS INTIMATED BY THE GUARD, SH. RICHHPAL PAREEK. 5.1 IN THE COURSE OF ASSESSMENT PROCEEDINGS U/S 143 (3)/250, THE AO AGAIN ASKED THE APPELLANT TO PRODUCE SHRI PARAS JAIN, PROPRIETOR OF M/S TIRUPATI STEELS FOR EXAMINATION AN D VERIFICATION OF THE ENTRY STANDING IN HIS NAME. THE APPELLANT, HOWEVER, FAILED TO PRODUCE SH. JAIN ON THE GROUND TH AT HE WAS OUT OF STATION. THE A.O. ALSO OBSERVED THAT IN THE A BSENCE OF IT PARTICULARS OF SH. PARAS JAIN AND HIS CROSS EXAMINA TION, THE TRANSACTIONS CLAIMED BY THE APPELLANT COULD NOT BE VERIFIED. THUS, IT IS NOTICED THAT EVEN IN THE COURSE OF SET A SIDE PROCEEDINGS, THE APPELLANT HAS FAILED TO PRODUCE SH . PARAS JAIN, IN SPITE OF CLEAR DIRECTIONS OF THE HONBLE I TAT, WHICH ARE, IF THE ASSESSEE FAILED TO PRODUCE THE CREDITOR OR UNABLE TO GIVE THE EXACT ADDRESS THEN SUCH LIABILITY WILL STAND CEA SED DURING THE YEAR AND A.O. WILL BE FREE TO AD BACK THE SAME A S PER LAW. PRODUCTION OF ANY OTHER DOCUMENT BY THE APPELLANT C ANNOT SUBSTITUTE THE REQUIREMENT OF PRODUCTION OF SH. JA IN FOR EXAMINATION, AS DIRECTED BY THE A.O. AND FURTHER AF FIRMED BY THE HONBLE TRIBUNAL IN VIEW OF THE PECULIAR FACTS WHI CH HAD EMERGED ON FIELD ENQUIRY CONDUCTED BY THE A.O. AS H ELD BY THE APEX COURT IN THE CASE OF SUMATI DAYAL (214 ITR 801) , THE MATTER IN THE INCOME TAX PROCEEDINGS HAS TO BE DECI DED IN THE LIGHT OF HUMAN PROBABILITIES. IN THE PECULIAR FACTS OF THIS CASE, WHEN THE FIELD ENQUIRIES HAD REVEALED THAT THE CREDI TORS 7 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO ADDRESS WAS INCORRECT, THE NON PRODUCTION OF SRI JAI N FOR EXAMINATION GOES AGAINST THE APPELLANT. IN VIEW OF THE ABOVE DISCUSSION, IT IS CLEAR THAT T HE APPELLANT HAS FAILED TO ESTABLISH THE EXISTENCE OF THE LIABIL ITY CLAIMED BY IT. HENCE, I DO NOT FIND ANY REASON TO INTERFERE WIT H THE ORDER OF THE A.O. ON THIS ISSUE. 4. NOW THE ASSESSEE IS IN APPEAL BEFORE US. THE LD AR OF THE ASSESSEE HAS SUBMITTED THAT THE ASSESSEE FIRM IS ENGAGED IN THE BUSINESS OF MS BARS AND ROUNDS ETC. IN THE ORIGINAL ASSESSMENT, THE A.O . MADE ADDITION OF RS. 34,91,181/- U/S 41(1) OF THE ACT. THE LD CIT(A) VIDE ORDER DATED 08/06/2010 HAD DELETED THE ADDITION WHEREIN HE HAS HELD THAT THERE IS NO REMAND OR CESSATION OF LIABILITY BY THE ASSESSEE OR CREDITOR. TO ESTABLISH THE IDENTITY OF THE CREDITOR, HIS PAN AND VOTER ID WAS G IVEN ALONGWITH COPY OF RENT AGREEMENT FOR THE DECLARED OFFICE PREMISES. SI MPLY FOR WANT OF CONFIRMATION, ADDITION MADE BY THE A.O. CANNOT BE J USTIFIED. THE ASSESSEE HAD PURCHASED GOODS FROM M/S TIRUPATI STEELS DURING FINANCIAL YEAR 2001- 02 AND 2002-03. DUE TO DISPUTE ON ACCOUNT OF SHORT SUPPLY AND POOR QUALITY THE ASSESSEE DID NOT MAKE PAYMENT TO THE PA RTY. THE SAID CREDITOR WAS REPEATEDLY ASKED TO SETTLE THE DISPUTE BUT NO SE TTLEMENT WAS MADE AND THEREFORE PAYMENT IS OUTSTANDING. FINALLY THE MATTE R WAS RESOLVED IN THE FINANCIAL YEAR 2010-11 IN WHICH ASSESSEE HAS SOLD GO ODS WORTH RS. 8 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO 30,70,467/- AND DEDUCTED A SUM OF RS. 4,20,714/- WHI CH WAS WRITTEN BACK AND OFFERED AS INCOME OF F.Y. 2010-11. IN SUPPORT O F THE SAME ASSESSEE HAS FILED THE COPY OF LEDGER ACCOUNT AND COPY OF RE TURN FOR F.Y. 2010-11. THE ASSESSEE HAS ALSO DECLARED THIS SALE BEFORE THE SALES TAX DEPARTMENT. IN ADDITION TO THIS ASSESSEE HAS ALSO FILED THE FOL LOWING EVIDENCES BEFORE THE ASSESSING OFFICER TO PROVE THE EXISTENCE OF PAR AS JAIN PROPRIETOR OF TIRUPATI STEELS. (I) PRESENT ADDRESS ALONGWITH COPY OF ACCOUNT IN AS SESSEES BOOKS FOR F.Y. 2010-11. (II) SALES TAX REGISTRATION DOCUMENT OF TIRUPATI ST EELS. (III) RENT AGREEMENT OF TIRUPATI STEELS. (IV) IDENTITY CARD OF PARAS JAIN, PROPRIETOR OF TIR UPATI STEELS. (V) PAN OF PARAS JAIN. THE ASSESSING OFFICER HAS NOT POINTED OUT ANY DEFECT ON THE SAME. HENCE THE ASSESSEE HAS DISCHARGED HIS BURDEN OF PROOF. HE FURTHER SUBMITTED THAT SO FAR AS NON-PRODUCTION OF THE CREDITOR AND NON FI LING OF HIS IT RETURN, BALANCE SHEET, AND P&L ACCOUNT IS CONCERNED, WE MAY POINT OUT THAT ASSESSEE HAS A DISPUTE WITH THIS PARTY SINCE LAST MO RE THAN 10 YEARS AND ASSESSEE HAS ALSO DEDUCTED HIS PART PAYMENT. THEREFO RE, HE WAS NOT CO- OPERATING THE ASSESSEE AND IT IS BEYOND CONTROL OF THE ASSESSEE TO PRODUCE HIM. OTHERWISE ALSO AS EXPLAINED IN PARA 1 SUPRA ASS ESSEE HAS FILED VARIOUS 9 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO OTHER EVIDENCES WHICH PROVES THAT ASSESSEE HAS SETT LED THE LIABILITIES IN THE SUBSEQUENT YEARS. HE RELIED ON THE FOLLOWING CASE LA WS:- (I) CIT VS. HARDIK FABRICS (2013) 86 CCH 195 (GUJ). (II) CIT VS HOTLINE ELECTRONICS LTD. (2012) 80 CCH 156 (D EL) (III) CIT VS. SMT. SITA DEVI JUNEJA (2010) 33 DTR (P&H) 20 1. (IV) CIT VS G.K. PATEL & CO. (2012) 83 CCH 210 (GUJ). IN THESE FACTS AND IN VIEW OF THE SPECIFIC DIRECTION OF ITAT, THE ADDITION MADE BY THE A.O. IS UNCALLED FOR AND MAY BE DELETED . 5. AT THE OUTSET, THE LD DR HAS VEHEMENTLY SUPPORTE D THE ORDER OF THE LD CIT(A). 6. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON THE RECORD. THE ASSESSEE DURING THE COURSE OF RE- ASSESSMENT PROCEEDINGS AS WELL AS ORIGINAL ASSESSMEN T PROCEEDINGS HAD FURNISHED COPY OF PAN, VOTER ID AND COPY OF RENT AG REEMENT TO ESTABLISH THE IDENTITY, WHICH IS EVIDENT FROM THE FIRST APPEAL ORDER OF THE LD CIT(A). EVEN DURING THE RE-ASSESSMENT PROCEEDINGS, THE LD A R SUBMITTED THE REQUIRED DETAILS VIDE LETTER DATED 23/2/2013 AND AL SO INFORMED THE PRESENT ADDRESS OF SHRI PARAS JAIN, S/O- MAHAVIR PD. GADIA, 2/87, VIDYADHAR NAGAR, JAIPUR 302013. THE ASSESSEE HAD SOLD THE GOODS TO M/ S TIRUPATI STEEL FOR RS. 30,70,467/- IN F.Y. 2010-11 AND REMAINING AMOUN T OF RS. 4,20,714/- HAD BEEN WRITTEN BACK AND OFFERED AS INCOME IN F.Y. 2010-11 RELEVANT TO 10 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO ASSESSMENT YEAR 2011-12, WHICH IS VERIFIABLE FROM P AGE 43 OF THE PAPER BOOK. THIS PAGE SHOWS THAT IN TRADING ACCOUNT AND P&L ACCOUNT, THE ASSESSEE HAS CREDITED RS. 4,21,590/- AS INCOME. THE ASSESSEE ALSO PAID VAT ON THIS SALE WHICH IS EVIDENT FROM PAGE NO. 29 OF THE PAPER BOOK. AT PAGE 33, THERE IS COPY OF BANK CHALLAN, VAT PAID BY THE ASSESSEE AND AT PAGE 34 TO 38 OF THE PAPER BOOK ARE THE COPY OF QU ARTERLY RETURN OF VAT OF THE ASSESSEE WHEREIN GROSS SALE HAS BEEN SHOWN AT R S. 39,60,970/-. THEREFORE, THE ASSESSEE HAS DISCHARGED HIS ONUS BEFO RE THE ASSESSING OFFICER AS WELL AS THE CIT(A). THE ASSESSEE HAS PROV ED THAT HE HAD MADE PAYMENT IN THE SUBSEQUENT YEAR IN FORM OF GOODS SOL D AND PARTLY HE HAS WRITTEN BACK THE AMOUNT IN THE INCOME. ACCORDINGLY, WE HOLD THAT THE LD CIT(A) WAS NOT JUSTIFIED IN CONFIRMING THE ADDITION. THEREFORE, WE DELETE THE ADDITION CONFIRMED BY THE LD CIT(A). 7. IN THE RESULT, THE ASSESSEES APPEAL IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 16/12/2015. SD/- SD/- YFYR DQEKJ VH-VKJ-EHUK (LALIET KUMAR) (T.R. MEENA) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 16 TH DECEMBER, 2015 RANJAN* 11 ITA NO. 695/JP/2014 M/S RAMA STEEL ROLLING MILLS VS ITO VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- M/S RAMA STEEL ROLLING MILLS & GENERA L ENGG. WORKS, JHOTWARA, JAIPUR. 2. IZR;FKHZ @ THE RESPONDENT- THE ITO, WARD 3(1), 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. 695/JP/2014) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR