Shri Amit Kumar Kaushik C/o- Ashish G Gupta & Associates, 760, L.B.S. Colony, Station Road, Near C.H.C., Bassi Jaipur, Jaipur V. ITO Ward-7(4), Jaipur, Ward-7(4), Jaipur

ITA 705/JPR/2019

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 8484 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 1 month(s) 25 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 10-07-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2014-2015
• Appeal Filed On: 15-05-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: ASHISH GUPTA
• Keywords: Principle of natural justice; Period of limitation; Set aside
• Section: 143(3); 153A; 22

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. 705/JP/2019 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2014-15 SHRI AMIT KUMAR KAUSHIK C/O M/S KAUSHIK PHARMA & DISTRIBUTORS, BEHIND CHC STATION ROAD, BASSI, JAIPUR. CUK E VS. THE ITO, WARD-7(4), JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AYZPK8860F VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI ASHISH GUPTA (C.A.) JKTLO DH VKSJ LS @ REVENUE BY : MISS CHANCHAL MEENA (ADDL.CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 09/07/2020 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT: 10/07/2020 VKNS'K@ ORDER PER: VIJAY PAL RAO, J.M. THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST TH E ORDER DATED 12.03.2019 OF LD. CIT(A), JAIPUR FOR THE ASSESSMENT ORDER 2014-15. DUE TO PREVAILING COVID-19 PANDEMIC CONDITION THE HEARI NG OF THE APPEAL IS CONCLUDED THROUGH VIDEO CONFERENCE. THE ASSESSEE HA S RAISED FOLLOWING GROUNDS:- ITA NO. 705/JP/2019 SHRI AMIT KUMAR KAUSHIK VS. ITO 2 1. UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE T HE LEARNED CIT(A) HAS ERRED IN PASSING THE EX-PARTE ORDER WITH OUT GIVING OPPORTUNITY TO THE ASSESSEE OF BEING HEARD WHICH IS VOID AB-INITIO DESERVES TO BE QUASHED. 2. UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE TH E LEARNED CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS. 5,16,100/- U/S 68 OF THE INCOME TAX ACT, 1961 MADE BY THE LEARNED AO. 2. GROUND NO. 1 IS REGARDING DISMISSAL OF THE APPEA L OF THE LD. CIT(A) BY PASSING EX-PARTE IMPUGNED ORDER WITHOUT G IVING OPPORTUNITY TO THE ASSESSEE. 3. WE HAVE HEARD THE LD. AR AS WELL AS LD. DR AND C ONSIDERED THE RELEVANT MATERIAL AVAILABLE ON RECORD. AT THE OUTSE T, WE NOTE THAT THE LD. CIT(A) HAS DISMISSED THE APPEAL OF THE ASSESSEE SUM MARILY FOR WANT OF APPEARANCE AS WELL AS ON THE GROUND THAT THE ASSESS EE HAS NOT FILED E- APPEAL AS REQUIRED UNDER RULE 45(1) OF THE INCOME T AX RULES, 1963 AS AMENDED W.E.F. 01.03.2016. THEREFORE, THE LD. CIT(A ) HAS TREATED THE APPEAL AS NOT MAINTAINABLE AND NONEST FOR WANT OF E -FILING. IT IS PERTINENT TO NOTE THAT NON FILING OF APPEAL ELECTRO NICALLY JUST AFTER AMENDMENT OF RULE 45(1) OF THE IT RULES IS ONLY A D EFECT IN THE FILING WHEN THE ASSESSEE HAS ALREADY FILED A PHYSICAL APPE AL WELL WITHIN THE PERIOD OF LIMITATION. THEREFORE, INSTEAD OF TREATIN G THE APPEAL AS NOT ITA NO. 705/JP/2019 SHRI AMIT KUMAR KAUSHIK VS. ITO 3 MAINTAINABLE AND NONEST A DEFECT NOTICE OUGHT TO HA VE BEEN ISSUED TO THE ASSESSEE. WE FURTHER NOTE THAT THIS TRIBUNAL HA S TAKEN UP CONSISTENT VIEW ON THIS ISSUE THE DEFECT IN FILING OF THE APPE AL CAN BE REMOVED AND CANNOT BE A GROUND TO DISMISS THE APPEAL WITHOUT GI VING AN OPPORTUNITY TO THE ASSESSEE TO REMOVE THE DEFECT. IN CASE OF BI KANER DISTRIBUTORS PVT. LTD. VS. DCIT IN ITA NO. 1174 TO 1180/JP2018 T HIS TRIBUNAL VIDE ORDER DATED 24.01.2019 HAS CONSIDERED THIS ISSUED I N PARA 5 AS UNDER:- 5. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WEL L AS THE RELEVANT MATERIAL ON RECORD. AT THE OUTSET, WE NOT E THAT THE LD. CIT (A) HAS RECORDED THE FACTS REGARDING FILING OF THE APPEALS THAT THE ASSESSEE FILED THE SEVEN APPEALS ARISING FROM T HE ASSESSMENT ORDERS PASSED UNDER SECTION 143(3) READ WITH SECTIO N 153A OF THE IT ACT DATED 22 ND MARCH, 2016. ALL THESE SEVEN APPEALS WERE FILED WITHIN THE PERIOD OF LIMITATION ON 21 ST APRIL, 2016. THE APPEALS WERE TAKEN UP FOR HEARING ON 21 ST JUNE, 2018. HOWEVER, THERE WAS NO NOTICE OR SHOW CAUSE NOTICE GIVEN TO T HE ASSESSEE BY THE LD. CIT (A) BEFORE DISMISSING THE APPEALS BY TREATING THE SAME AS NOT MAINTAINABLE FOR WANT OF E-FILING. THE REFORE, WE FIND THAT DISMISSAL OF THE APPEALS WITHOUT GIVING AN OPP ORTUNITY TO THE ASSESSEE TO REMOVE THE DEFECT AND TO FILE THE APPEA LS ELECTRONICALLY AMOUNTS TO VIOLATION OF PRINCIPLES O F NATURAL JUSTICE. FURTHER, ONCE THE APPEALS FILED MANUALLY WERE TAKEN UP FOR HEARING, THEN EVEN IF THERE WAS A DEFECT ON ACCOUNT OF NON-FILING OF THE APPEALS ELECTRONICALLY, THE ASSESSEE OUGHT T O HAVE BEEN GRANTED AN OPPORTUNITY TO REMOVE THE DEFECT. THOUG H THERE MAY BE A QUESTION OF DELAY DUE TO LATE FILING OF THE AP PEALS ELECTRONICALLY, HOWEVER, ONCE THE APPEALS WERE FILE D MANUALLY WITHIN THE PERIOD OF LIMITATION, THEN THE SUBSEQUEN T FILING OF THE APPEALS ELECTRONICALLY CAN BE TAKEN UP BY CONSIDERI NG THE FACT THAT IT WAS NOT A DELAY FOR TAKING THE STEPS BUT IT WAS ONLY A ITA NO. 705/JP/2019 SHRI AMIT KUMAR KAUSHIK VS. ITO 4 DEFECT IN FILING THE APPEALS. IT IS ALSO RELEVANT TO NOTE THAT THE AMENDMENT IN RULE 45 OF THE IT RULES WAS BROUGHT IN TO STATUTE WITH EFFECT FROM 01.03.2016 AND, THEREFORE, THIS IS THE FIRST YEAR OF THE AMENDMENT REQUIRING E-FILING OF THE APPEAL A ND HENCE THE NON-FILING OF THE APPEAL ELECTRONICALLY CANNOT BE C ONSIDERED AS A DEFECT SO FATAL TO STRAIGHT-AWAY DISMISS THE APPEAL WITHOUT GIVING AN OPPORTUNITY TO REMOVE THE SAID DEFECT. THIS BEN CH HAS CONSIDERED AN IDENTICAL ISSUE IN CASE OF KAILASH CH AND JAT VS. ACIT (SUPRA) IN PARA 4 AS UNDER :- 4. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WE LL AS RELEVANT MATERIAL ON RECORD. AT THE OUTSET WE NOTE THAT THE APPEAL FILED BY THE ASSESSEE (MANUALLY) WAS DULY TAKEN UP FOR HEARING BY THE LD. CIT(A) AND AFTER HEARING THE REPRESENTATIVE OF THE ASSESSEE SHRI K.L. CHOUDHARY, C.A. THE LD. CIT(A) H AS FINALLY DISMISSED THE APPEAL ON THE GROUND OF NON MAINTAINA BILITY IN PARAS 3.1.1, 3.1.2 & 4 AS UNDER:- 3.1.1 I HAVE CONSIDERED THE ASSESSMENT ORDER, SUBM ISSION MADE BY THE APPELLANT AS WELL AS THE PAPER APPEAL. ON PE RUSAL OF THE DETAILS, IT IS OBSERVED THAT THIS APPEAL WAS FILED MANUALLY IN THIS OFFICE ON 23.1.2017. AS PER THE PROVISIONS OF RULE 45 OF THE IT RULES, 1961, IT HAS BEEN MADE COMPULSORY/MANDATORY TO E-FILE THE APPEAL BEFORE THE CIT(A) W.E.F. 01.03.2016 IN R ESPECT OF PERSONS WHO ARE REQUIRED TO FURNISH RETURN OF INCOM E ELECTRONICALLY. SUBSEQUENTLY, THIS TIME LIMIT WAS E XTENDED TO 15.06.2016, VIDE CIRCULAR NO. 20/2016 (F. NO. 279/M ISC/M- 54/2016/ITJ DATED 26.05.2016). DURING THE APPELLATE PROCEEDINGS, THE ITBA SYSTEM WAS CHECKED TO VERIFY WHETHER THE APPELLANT HAS FILED THE APPEAL ELECTRONICALLY AS MA NDATED UNDER RULE 45 OF IT RULES. THE ITBA VERIFICATION SHOWED T HAT THE APPEAL HAS NOT BEEN FILED ELECTRONICALLY. 3.1.2 IN VIEW OF THE ABOVE FACTS, IT IS EVIDENCE TH AT THE CASE OF THE APPELLANT IS COVERED BY THE PROVISION OF SECTIO N 249 R.W. RULE ITA NO. 705/JP/2019 SHRI AMIT KUMAR KAUSHIK VS. ITO 5 45 OF IT RULES WHICH LAYS DOWN THAT EVERY APPEAL SH ALL BE FILED IN THE PRESCRIBED FORM AND SHALL BE VERIFIED IN THE PR ESCRIBED MANNER. IN THIS CASE THE APPELLANT HAD FILED THE AP PEAL MANUALLY AND WAS REQUIRED TO E-FILE IN ACCORDANCE WITH RULE 45 OF IT RULES FOR THE EXTENDED PERIOD I.E. 15.06.2016. SINCE, THI S APPEAL HAS BEEN FILED MANUALLY, IT IS DEFECTIVE APPEAL WHICH I S NON- MAINTAINABLE AND IS BEING FILED. THE E-APPEAL MAY B E TAKEN UP SEPARATELY FOR ADJUDICATION WHENEVER IT IS FILED AS PER LAW AND EXISTING INSTRUCTION IN FORCE. 4. THUS, THIS APPEAL IS DEFECTIVE AND NON-MAINTAIN ABLE AND IS BEING FILED/DISMISSED. THUS, NO ADJUDICATION ON MER IT IS CONSIDERED NECESSARY. IN THE RESULT, THE APPEAL IS DISMISSED ON TECHNICAL GROUNDS BEING MANUALLY FILED AND HENCE IN ADMISSIBLE AB-INITIO. THUS, IT IS CLEAR THAT THE LD. CIT(A) TOOK COGNIZAN CE OF THE APPEAL FILED MANUALLY THOUGH IT WAS DEFECTIVE. ONCE THE AP PEAL FILED BY THE ASSESSEE FOUND TO BE DEFECTIVE BECAUSE NON COMP LIANCE OF RULE 45 OF THE IT RULES, THE PROPER COURSE OF ACTIO N WAS TO ALLOW THE ASSESSEE TO FILE THE APPEAL THROUGH E-FILING AN D THEN, THE APPEAL SO FILED BY THE ASSESSEE OUGHT TO HAVE BEEN DECIDED ON MERITS. THUS, THE APPEAL OF THE ASSESSEE WAS DISMIS SED BEING NOT MAINTAINABLE WITHOUT EVEN ISSUING ANY NOTICE OR RAI SING SUCH A QUESTION OF MAINTAINABILITY OF THE APPEAL TO THE AS SESSEE. HENCE, THE ORDER PASSED BY THE LD. CIT(A) IS IN VIOLATION OF PRINCIPLES OF NATURAL JUSTICE AND CONSEQUENTLY NOT SUSTAINABLE IN LAW. THE MUMBAI BENCHES OF THE TRIBUNAL IN CASE OF M/S ALL I NDIA FEDERATION OF TAX PRACTITIONERS VS. ITO (SUPRA) WHI LE CONSIDERING THE REQUIREMENT OF E-FILING HAS HELD IN PARA 6 AS U NDER:- 6. WE HAVE HEARD THE COUNSELS FOR BOTH THE PARTIES AND WE HAVE ALSO PERUSED THE MATERIAL PLACED ON RECORD AS WELL AS ORDERS PASSED BY THE REVENUE AUTHORITIES. FROM THE RECORDS WE NOTICED THAT ELECTRONICALLY FILING OF THE APPEALS WAS INTRO DUCED FOR THE FIRST ITA NO. 705/JP/2019 SHRI AMIT KUMAR KAUSHIK VS. ITO 6 TIME VIDE RULE 45 OF I.T. RULES 1962, MANDATING COM PULSORY E- FILING OF APPEALS BEFORE APPELLATE COMMISSIONER WIT H EFFECT FROM 1 ST MARCH 2016. WE NOTICED THAT IN THIS RESPECT, THERE IS NO CORRESPONDING AMENDMENT IN ANY OF THE PROVISIONS OF THE SUBSTANTIVE LAW I.E I.T. ACT, 1961. AS PER THE FACTS OF THE PRESENT CASE, THE ASSESSMEN T IN THE ABOVE CASE WAS COMPLETED U/S 143(3) OF THE I.T. ACT 1961. HOWEVER THE ASSESSEE HAS FILED APPEAL BEFORE LD. CIT(A) IN PAPE R FORM AS PRESCRIBED UNDER THE PROVISIONS OF I.T. ACT 1961 WI THIN THE PRESCRIBED PERIOD OF LIMITATION. BUT THE SAME WAS D ISMISSED BY LD. CIT(A) BY HOLDING THAT ASSESSEE HAD NOT FILED A PPEAL THROUGH ELECTRONIC FORM, WHICH IS MANDATORY AS PER I.T. RUL ES 1962. AFTER HAVING CONSIDERED THE ENTIRE FACTUAL POSITION , WE FIND THAT HONBLE SUPREME COURT IN THE CASE OF STATE OF PUNJ AB VS.SHYAMALALMURARI AND OTHERS REPORTED IN AIR 1976 (SC) 1177 HAS CATEGORICALLY HELD THAT COURTS SHOULD NOT GO ST RICTLY BY THE RULEBOOK TO DENY JUSTICE TO THE DESERVING LITIGANT AS IT WOULD LEAD TO MISCARRIAGE OF JUSTICE. IT HAS BEEN REITERATED B Y THE HONBLE SUPREME COURT THAT ALL THE RULES OF PROCEDURE ARE H ANDMAID OF JUSTICE. THE LANGUAGE EMPLOYED BY THE DRAFTSMAN OF PROCEDURAL LAW MAY BE LIBERAL OR STRINGENT, BUT THE FACT REMAI NS THAT THE OBJECT OF PRESCRIBING PROCEDURE IS TO ADVANCE THE C AUSE OF JUSTICE. THE HONBLE APEX COURT HAS SAID IN AN ADVERSARIAL SYSTEM, NO PARTY SHOULD ORDINARILY BE DENIED THE OPPORTUNITY O F PARTICIPATING IN THE PROCESS OF JUSTICE DISPENSATION. THE HONBLE SUPREME COURT IN ITS JUDGEMENT REPORTED AS AIR 2005 (SC) 3304 IN THE CASE OF RANIKUSUMVRS. KANCHA N DEVI, REITERATED THAT, A PROCEDURAL LAW SHOULD NOT ORDINA RILY BE CONSTRUED AS MANDATORY, AS IT IS ALWAYS SUBSERVIENT TO AND IS IN AID OF JUSTICE. ANY INTERPRETATION, WHICH ELUDES OR FRUSTRATES THE RECIPIENT OF JUSTICE, IS NOT TO BE FOLLOWED. ITA NO. 705/JP/2019 SHRI AMIT KUMAR KAUSHIK VS. ITO 7 FROM THE FACTS OF THE PRESENT CASE, WE GATHERED THA T THE ASSESSEE HAD ALREADY FILED THE APPEAL IN PAPER FORM , HOWEVER ONLY THE E-FILING OF APPEAL HAS NOT BEEN DONE BY TH E ASSESSEE AND ACCORDING TO US, THE SAME IS ONLY A TECHNICAL CONSI DERATION. IN THIS RESPECT, WE RELY UPON THE JUDGEMENT OF HONBLE SUPR EME COURT, WHEREIN THE HONBLE SUPREME COURT HAS REITERATED TH AT IF IN A GIVEN CIRCUMSTANCES, THE TECHNICAL CONSIDERATION AN D SUBSTANTIAL JUSTICE ARE PITTED AGAINST EACH OTHER, THEN IN THAT EVENTUALITY THE CAUSE OF SUBSTANTIAL JUSTICE DESERVES TO BE PREFERR ED AND CANNOT BE OVERSHADOWED OR NEGATIVED BY SUCH TECHNICAL CONS IDERATIONS. APART FROM ABOVE WE HAVE ALSO NOTICED THAT THE COOR DINATE BENCH OF HONBLE ITAT DELHI BENCH IN APPEAL ITA NO. 6595/ DEL/16 IN CASE TITLED GURINDER SINGH DHILLON VRS. ITO HAD RES TORED THE MATTER TO THE FILE OF LD. CIT(A) UNDER IDENTICAL CI RCUMSTANCES WITH A DIRECTION DO DECIDE APPEAL AFRESH ON MERIT, AFTER CONDONING THE DELAY, IF ANY. SINCE IN THE PRESENT CASE, WE FIND THAT APPEAL IN T HE PAPER FORM WAS ALREADY WITH LD. CIT(A), THEREFORE IN THAT EVEN TUALITY THE LD. CIT(A) OUGHT NOT TO HAVE DISMISSED THE APPEAL SOLEL Y ON THE GROUND THAT THE ASSESSEE HAS NOT FILED THE APPEAL E LECTRONICALLY BEFORE THE APPELLATE COMMISSIONER. KEEPING IN VIEW THE FACTS AND CIRCUMSTANCES AS WELL AS THE CASE LAWS DISCUSSED AND RELIED UPON ABOVE, WE ARE OF THE CONSIDERED VIEW THAT THE CAUSE OF JUSTICE WOULD BE SERVED IN C ASE, WE SET ASIDE THE ORDERS OF LD. CIT(A) & ALLOW THE PRESENT APPEAL. WHILE SEEKING THE COMPLIANCE, WE DIRECT THE ASSESSEE TO F ILE THE APPEAL ELECTRONICALLY WITHIN 10 DAYS FROM THE DATE OF RECE IPT OF THIS ORDER. IN CASE, THE DIRECTIONS ARE FOLLOWED THEN IN THAT EVENTUALITY, THE DELAY IN E-FILING THE APPEAL SHALL STAND CONDONED. LD. CIT(A) IS FURTHER DIRECTED TO CONSIDER THE APPE AL FILED BY THE ASSESSEE ON MERITS BY PASSING A SPEAKING ORDER. RES ULTANTLY, WE ALLOW THE APPEAL FILED BY THE ASSESSEE. ITA NO. 705/JP/2019 SHRI AMIT KUMAR KAUSHIK VS. ITO 8 IN VIEW OF THE ABOVE FACTS AND CIRCUMSTANCES OF THE CASE, WE SET ASIDE THE IMPUGNED ORDER OF THE LD. CIT(A) AND REM AND THE MATTER TO THE RECORD OF THE LD. CIT(A) WITH DIRECTI ON TO THE ASSESSEE TO E-FILE THE APPEAL. THE LD. CIT(A) SHALL DECIDE THE APPEAL OF THE ASSESSEE ON MERITS. NEEDLESS TO SAY T HE ASSESSEE BE GIVEN AN APPROPRIATE OPPORTUNITY BEFORE PASSING A FRESH ORDER. ACCORDINGLY, IN VIEW OF THE FACTS AND CIRCUMSTANCES OF THE CASE WHEN THE LD. CIT (A) HAS DISMISSED THE APPEAL WITHO UT EVEN GIVING AN OPPORTUNITY OF HEARING TO THE ASSESSEE TO REMOVE THE DEFECT, THE IMPUGNED ORDER PASSED BY THE LD. CIT (A ) IS NOT SUSTAINABLE AND THE SAME IS SET ASIDE. THE MATTERS ARE REMANDED TO THE RECORD OF CIT (A). THE ASSESSEE IS DIRECTED TO FILE THE APPEALS ELECTRONICALLY WITHIN A PERIOD OF 30 DAYS F ROM THE DATE OF THIS ORDER AND THE LD. CIT (A) THEN DECIDE THE APPE ALS OF THE ASSESSEE ON MERITS. ACCORDINGLY, THE MATTER IS REMANDED TO THE RECORD O F THE LD. CIT(A) FOR GRANTING ONE MORE OPPORTUNITY TO THE ASSESSEE TO RE CTIFY THE DEFECT BY FILING THE APPEAL ELECTRONICALLY WITHIN A PERIOD OF 30 DAYS FROM THE DATE OF THIS ORDER AND THE LD. CIT(A) THEN DECIDE THE AP PEAL OF THE ASSESSEE ON MERITS AFTER GIVING AN OPPORTUNITY OF HEARING TO THE ASSESSEE. OTHER GROUND RAISED BY THE ASSESSEE STAND DISPOSED OFF AS SET ASIDE TO THE RECORD OF THE LD. CIT(A). ITA NO. 705/JP/2019 SHRI AMIT KUMAR KAUSHIK VS. ITO 9 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOW ED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 10/07/2020. SD/- SD/- FOE FLAG ;KNO FOT; IKY JKO (VIKRAM SINGH YADAV) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 10/07/2020. * SANTOSH. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SHRI AMIT KUMAR KAUSHIK, JAIPUR. 2. IZR;FKHZ@ THE RESPONDENT- ITO, WARD-7(4), JAIPUR. 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. 705/JP/2019} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR