ACIT, Jaipur V. ADITYA POROPCON PVT. LTD, Jaipur

ITA 727/JPR/2016

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 4816 (ITAT-JAIPUR)
• Duration Of Justice: 4 month(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 19-12-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2008-2009
• Appeal Filed On: 29-07-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: AJAY MALIK CIT DHK
• Keywords: Capital asset; Additional evidence

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S, JAIPUR JH DQY HKKJR] U;KF;D LNL; ,OA JH FOE FLAG ;KNO] YS [KK LNL; DS LE{K BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YAD AV, AM VK;DJ VIHY LA-@ ITA NO.727/JP/16 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2008-09 THE ACIT, CIRCLE-6, JAIPUR CUKE VS. M/S ADITYA PROPCON PVT. LTD., A -2, PUSHP ENCLAVE, PRATAP NAGAR, SECTOR-5, JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. AAACD 6226 A VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT VK;DJ VIHY LA-@ ITA NO.728/JP/16 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2010-11 THE ACIT, CIRCLE-6, JAIPUR CUKE VS. M/S ADITYA PROPCON PVT. LTD., A -2, PUSHP ENCLAVE, PRATAP NAGAR, SECTOR-5, JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. AAACD 6226 A VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI SANDEEP JHANWAR (CA) JKTLO DH VKSJ LS@ REVENUE BY : SHRI AJAY MALIK (ADDL. CIT ) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 15.12.2016 ?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 19/12/2016. VKNS'K@ ORDER PER SHRI VIKRAM SINGH YADAV, A.M. THESE ARE TWO APPEALS FILED BY THE REVENUE ARISING OUT OF THE ORDER OF THE LD CIT(A) -5, JAIPUR DATED 11.5.2016 FOR AY 200 8-09 AND ORDER DATED 13.5.2016 FOR AY 2010-11 RESPECTIVELY. GIVEN THE I DENTICAL FACT PATTERN, THE SAME WERE HEARD TOGETHER AND ARE BEING DISPOSED OFF BY THIS CONSOLIDATED ORDER. ITA NOS. 727 & 728/JP/16 THE ACIT, CIRCLE-6, JAIPUR VS. M/S ADITYA PROPCORN (P) LTD. JAIPUR 2 IN ITA NO. 727/JP/16, THE REVENUE HAS TAKEN FOLLOWI NG GROUND OF APPEAL: WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE AND IN LAW, THE LD. CIT(A) HAS ERRED IN DELETING THE ADDITION OF RS. 2, 32,13,786/- MADE BY THE AO ON ACCOUNT OF INCLUSION OF INTEREST COST INCURRED FOR PROJECT-2 IN THE VALUE OF INVENTORY OF PROJECT -2. IN ITA NO. 728/JP/16, THE REVENUE HAS TAKEN FOLLOWI NG GROUNDS OF APPEAL: (I) WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW, THE CIT(A) HAS ERRED IN DELETING THE ADDITION OF RS. 2, 22,974/-MADE BY AO ON ACCOUNT OF EXCESS STOCK CLAIMED IN RESPECT OF SALE S DURING THE YEAR. (II) WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW, THE CIT(A) HAS ERRED IN DELETING THE ADDITION OF RS. 8, 37,979/- MADE BY AO ON ACCOUNT OF REDUCING THE COST OF GOODS SOLD IN RESPE CT OF PROPORTIONATE COST TO BE INCURRED IN FUTURE. (III) WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW, THE CIT(A) HAS ERRED IN DELETING THE ADDITION OF RS.3,4 1,99,625/- MADE BY AO ON ACCOUNT OF INCLUSION OF INTEREST COST INCURRED F OR PROJECT-2 IN THE VALUE OF INVENTORY OF PROJECT-2. 2. IN RESPECT OF REVENUES APPEAL NO. 727/JP/16 WHE RE AN ADDITION OF RS. 2,32,13,786/- WAS MADE BY THE AO ON ACCOUNT OF INCL USION OF INTEREST COST INCURRED FOR PROJECT 2 IN THE VALUE OF THE INVENTOR Y AND IN RESPECT OF GROUND NO. 3 OF REVENUES APPEAL NO. 762/JP/16 WHERE AN ADDITI ON OF RS. 3,41,99,625 ON ACCOUNT OF INCLUSION OF INTEREST COST OF PROJECT 2 IN THE VALUE OF INVENTORY OF PROJECT 2 WAS MADE BY THE AO, THE LD. AR SUBMITTED THAT THE TRIBUNAL IN ASSESSEES OWN CASE FOR A.Y. 2009-10 IN ITA NO. 762 /JP/2012 VIDE ITS ORDER DATED 30.01.2014, UNDER THE SAME FACTS AND CIRCUMST ANCES OF THE CASE HAS HELD THAT INTEREST ON FUND BORROWED TO PURCHASE LAN D WHICH IS PART OF INVENTORY OF THE ASSESSEE COMPANY IS AN ALLOWABLE D EDUCTION U/S 36(1)((III) AND ITA NOS. 727 & 728/JP/16 THE ACIT, CIRCLE-6, JAIPUR VS. M/S ADITYA PROPCORN (P) LTD. JAIPUR 3 HENCE DISMISSED THE APPEAL OF THE REVENUE. THE PRES ENT CASE IS SQUARED COVERED BY THE PRINCIPLES LAID DOWN IN THE ABOVE JU DGEMENT. 2.1 THE RELEVANT FINDINGS OF THE COORDINATE BENCH I N ITA NO. 762/JP/12 DATED 30.01.2014 IS REPRODUCED AS UNDER: (18.) WE HAVE HEARD THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON RECORD AND ALSO THE ORDERS OF THE AUTHORITIES BELOW. WE FI ND THAT THE BOOKS OF ACCOUNTS OF THE ASSESSEE ARE AUDITED AND THE LD. AU DITOR HAS NOT GIVEN ANY ADVERSE COMMENT FOR NOT FOLLOWING THE ACCOUNTIN G STANDARDS WHICH ARE MANDATORY FOR A COMPANY U/S 211 OF THE COMPANIE S ACT, 1956. WE ALSO FIND THAT THERE IS NO DISPUTE THAT THE SAID LA ND IS PART OF INVENTORY FOR THE ASSESSEE AND IS NOT A CAPITAL ASSET. THE ASSES SEE HAS PRODUCED EVIDENCES OF NO INCREASE IN THE LAND PRICE AND AO H AS NOT BROUGHT ANYTHING ON RECORD TO SUPPORT THAT THE ASSESSEE WOU LD BE ABLE TO REALISE THE INTEREST COST INCURRED OVER AND ABOVE THE COST OF PURCHASE OF LAND. IN SUCH CIRCUMSTANCES, AS PER BASIC ACCOUNTING PRINCIP LES OF VALUATION OF INVENTORY THAT THE INVENTORY IS TO BE VALUED AT COS T OR NET REALISABLE VALUE WHICH-EVER IS LOWER. THE UNCONTROVERTED EVIDENCES SHOW THAT THERE IS NO BUYER OF THE SIMILAR LAND IN SAME VICINITY AT THE P RICE WHICH IS LESSER THAN THE PRICE PAID BY THE ASSESSEE AND THEREFORE, WE AR E CONVINCED WITH THE CIT(A) AND THE A/R OF THE ASSESSEE THAT THE INVENTO RY OF LAND CANNOT BE VALUED AT A PRICE HIGHER THAN IT IS BOUGHT. LD. A/ R HAS STATED THAT THE ASSESSEE HAS NOT TAKEN UP THE PROJECT ACTIVITY EVEN TILL 31.3.2013. THE DELAY IN PROJECT IS FOR ECONOMIC REASONS. IN SUCH C IRCUMSTANCES, THE AS-16 DOES NOT ALLOW CAPITALISATION OF INTEREST COST ALON GWITH THE COST OF LAND. IT ALLOWS CAPITALISATION OF INTEREST COST ONLY DURI NG NORMAL PERIOD OF CONSTRUCTION AND NOT FOR INORDINATE DELAY IN THE CO NSTRUCTION ACTIVITY DUE TO ADVERSE MARKET FORCES. THERE IS SPECIFIC REQUIR EMENT OF AS-16, NOT TO CAPITALISE THE INTEREST COST ALONG WITH THE COST OF LAND IF IT IS HELD WITHOUT ANY ASSOCIATED DEVELOPMENT ACTIVITY. ACCORDINGLY, THE ACCOUNTING TREATMENT OF THE INTEREST COST IS PERFECTLY IN LINE WITH THE ACCOUNTING STANDARDS. WE FURTHER FIND THAT DESPITE ANY ACCOUN TING TREATMENT, THE INTEREST ON CAPITAL BORROWED FOR THE PURPOSE OF BUS INESS IS ALLOWABLE U/S 36(1)(III). A PROVISO HAS BEEN INSERTED W.E.F 1.4. 2004 WHICH READS AS UNDER :- ITA NOS. 727 & 728/JP/16 THE ACIT, CIRCLE-6, JAIPUR VS. M/S ADITYA PROPCORN (P) LTD. JAIPUR 4 PROVIDED THAT ANY AMOUNT OF THE INTEREST PAID, IN RESPECT OF CAPITAL BORROWED FOR ACQUISITION OF AN ASSET FOR EXTENSION OF EXISTING BUSINESS OR PROFESSION (WHETHER CAPITALISED IN THE BOOKS OF ACC OUNT OR NOT); FOR ANY PERIOD BEGINNING FROM THE DATE ON WHICH THE CAPITAL WAS BORROWED FOR ACQUISITION OF THE ASSET TILL THE DATE ON WHICH SUC H ASSET WAS FIRST PUT TO USE, SHALL NOT BE ALLOWED AS DEDUCTION. THE PROVISO SPECIFICALLY REFERRED TO THE INTEREST P AID IN RESPECT OF CAPITAL BORROWED FOR ACQUISITION OF ANY ASSET FOR EXTENSION OF EXISTING BUSINESS. THE PRESENT CASE IS OF ACQUISITION OF LAND FOR ITS DEVELOPMENT IN COURSE OF REAL ESTATE ACTIVITY OF THE ASSESSEE. ASSESSEE IS A BOUT TO COMPLETE ONE PROJECT AND TO CONTINUE THE ACTIVITIES HAS PURCHASE D ANOTHER LAND TO DEVELOP ANOTHER PROJECT. THE ARGUMENT OF THE LD. D R THAT THE PROVISO WOULD APPLY TO THE ASSESSEES CASE CANNOT BE ACCEPT ED. WE ARE OF THE CONSIDERED OPINION THAT THE PURCHASE OF INVENTORY I S CONTINUATION OF THE SAME BUSINESS ACTIVITY IN ROUTINE COURSE AND CANNOT BE TERMED AS EXTENSION OF THE BUSINESS ACTIVITY. THE PROVISO HA S BEEN INSERTED TO DISENTITLE CLAIM OF INTEREST ON FUNDS BORROWED FOR ACQUISITION OF CAPITAL ASSETS FOR THE PERIOD UPTO THE ASSET IS PUT TO USE. THE TERM PUT TO USE HERE APPLIES TO CAPITAL ASSET ONLY BECAUSE A CAPITA L ASSETS IS HELD TO FACILITATE THE BUSINESS ACTIVITY AND SOMETIMES IT N EEDS TO BE PREPARED AFTER ITS ACQUISITION FOR BEING USED TO FACILITATE THE BUSINESS ACTIVITY. AS AGAINST THIS, PURCHASE AND HOLDING OF INVENTORY ITE M ITSELF IS A BUSINESS ACTIVITY. IN ABSENCE OF THIS PROVISO, SECTION 36(1 )(III) EARLIER ENTITLED ASSESSEES TO CLAIM INTEREST IN RESPECT OF CAPITAL A SSETS, EVEN FOR THE PERIOD DURING WHICH THEY WERE UNDER CONSTRUCTION AS HELD IN VARIOUS JUDGEMENTS POINTED OUT BY THE LD. AR OF THE ASSESSE E. THE INTEREST WAS FOUND ALLOWABLE DESPITE ITS CAPITALISATION IN THE B OOKS OF ACCOUNTS IN THE JUDGEMENTS. WE ARE THEREFORE, OF THE OPINION THAT THE INTEREST ON FUNDS BORROWED TO PURCHASE LAND WHICH IS PART OF INVENTOR Y OF THE ASSESSEE COMPANY IS AN ALLOWABLE DEDUCTION U/S 36(1)(III). W E ACCORDINGLY REJECT THIS GROUND OF THE DEPARTMENTAL APPEAL ALSO. 3. IN RESPECT OF GROUND NO. 1 OF APPEAL NO. 762/JP/ 16 WHERE AN ADDITION OF RS. 2,22,974 WAS MADE BY THE AO IN RESPECT OF EXCES S COST CLAIMED IN RESPECT OF SALES, THE LD. AR SUBMITTED THAT THE TRIBUNAL I N ASSESSEES OWN CASE FOR A.Y. 2009-10 IN ITA NO. 762/JP/2012 VIDE ITS ORDER DATED 30.01.2014, UNDER THE SAME FACTS AND CIRCUMSTANCES OF THE CASE HAS ACCEPT ED THE ASSESSEES ITA NOS. 727 & 728/JP/16 THE ACIT, CIRCLE-6, JAIPUR VS. M/S ADITYA PROPCORN (P) LTD. JAIPUR 5 CALCULATION AND REJECTED THE ONE DONE BY THE AO. TH E PRESENT CASE IS SQUARED COVERED BY THE PRINCIPLES LAID DOWN IN THE ABOVE JU DGEMENT. 3.1 THE RELEVANT FINDINGS OF THE COORDINATE BENCH I N ITA NO. 762/JP/12 DATED 30.01.2014 IS REPRODUCED AS UNDER: (7) WE HAVE HEARD THE RIVAL PARTIES. ON PERUSAL O F MATERIAL ON RECORD AND ORDERS OF THE AUTHORITIES BELOW, WE FIND THAT THE A SSESSEE HAS ALLOCATED THE ENTIRE COST ON EACH AND EVERY UNIT. THE COST O F CONSTRUCTION IS PRO- RATA IN THE RATIO OF AREA OF EACH UNIT BUT THE COST OF LAND IS ALLOCATED ON WEIGHTED AVERAGE SELLING RATE OF EACH UNIT AS THERE ARE LARGE VARIATIONS IN THE SELLING RATES OF THE UNITS DEPENDING ON THEIR R ESPECTIVE LOCATION. MAJOR DIFFERENCE IS BECAUSE OF THE FLOOR. GOVERNME NT ALSO RECOGNISES IT FOR THE PURPOSE OF STAMP DUTY VALUATION AND TAKE DI FFERENT VALUE OF LAND FOR REGISTRATION OF PROPERTY AT DIFFERENT FLOORS. T HE MANNER IN WHICH AO HAS ALLOCATED THE COST IS GIVING DISTORTED RESULT O F PROFIT/LOSS ON EACH UNIT AS AGAINST WHICH THE FORMULA DRAWN BY THE ASSESSEE BALANCES THE SAME. THERE IS NO DISPUTE AS TO THE FACT THAT THE SAME BA SIS IS ADOPTED FOR ALL THE UNITS AND IN ALL THE YEARS WHENEVER SALE OF THE UNIT IS RECOGNIZED IN THE BOOKS OF ACCOUNTS. IN OUR CONSIDERED OPINION T HE METHOD ADOPTED BY THE ASSESSEE IS MORE LOGICAL AND DOES NOT LEAVE ANY POSSIBILITY OF LEAKAGES IN REVENUE ALSO. IN THESE FACTS AND CIRCUM STANCES WE FIND NO MERIT IN THE FIRST GROUND OF DEPARTMENTAL APPEAL. REGARDING THE SECOND GROUND, WE FIND THAT THE WORKING SHOWN BY THE ASSES SEE WAS THE BASIS OF FINANCIAL STATEMENTS AND PREPARATION OF BOOKS OF AC COUNTS. THERE IS NO FINDING OF THE ASSESSING OFFICER THAT ANY OF THE IN FORMATION REGARDING FINANCIAL STATEMENT OR BOOKS OF ACCOUNT WAS NO PROV IDED BY THE ASSESSEE. IN SUCH CIRCUMSTANCES, IT IS WRONG TO CONSIDER THE CALCULATION AS ADDITIONAL EVIDENCES. THE LD. CIT(A) HAS, TO HIS S ATISFACTION, VERIFIED THE CALCULATIONS WHICH HE FOUND HAS CORRECT. WE FIND NO MERIT IN THE ARGUMENTS OF LD. DR THAT VERIFICATION OF COMPUTATIO N OF ALLOCATION OF COST, WHICH HAS NOT BEEN DONE BY THE AO IS NOT WITHIN THE JURISDICTION OF THE LD. CIT(A). WE ACCORDINGLY DISMISS GROUND NO. 2 OF THE DEPARTMENTAL APPEAL ALSO. 4. IN RESPECT OF GROUND NO. 2 OF APPEAL NO. 762/JP/16 WHERE AN ADDITION OF RS. 8,37,979 WAS MADE BY THE AO BY REDUCING THE COS T OF GOODS SOLD IN RESPECT OF PROPORTIONATE COSTS, THE LD. AR SUBMITTED THAT THE TRIBUNAL IN ASSESSEES ITA NOS. 727 & 728/JP/16 THE ACIT, CIRCLE-6, JAIPUR VS. M/S ADITYA PROPCORN (P) LTD. JAIPUR 6 OWN CASE FOR A.Y. 2009-10 IN ITA NO. 762/JP/2012 VI DE ITS ORDER DATED 30.01.2014, UNDER THE SAME FACTS AND CIRCUMSTANCES OF THE CASE HAS HELD THAT THE ASSESSEE HAS MADE A SYSTEMATIC ESTIMATION OF CO ST TO BE INCURRED AND THE SAME IS VERY NEAR TO THE EXPENDITURE ACTUALLY INCUR RED AT THE LATER STAGES. THE PRESENT CASE IS SQUARED COVERED BY THE PRINCIPLES L AID DOWN IN THE ABOVE JUDGEMENT. 4.1 THE RELEVANT FINDINGS OF THE COORDINATE BENCH I N ITA NO. 762/JP/12 DATED 30.01.2014 IS REPRODUCED AS UNDER: (12) WE HAVE HEARD THE RIVAL PARTIES AND PERUSED T HE ORDERS OF AUTHORITIES BELOW AND ALSO THE MATERIAL ON RECORD. WE FIND THAT ASSESSEE STARTED BOOKING SALE OF CERTAIN UNITS OF WHICH POSSESSIONS HAVE BEEN HANDED OVER TO CUSTOMERS. HOWEVER, CERTAIN WORK IN THE BUILDIN G WAS STILL TO BE COMPLETED AND THE COST OF THE SAME SHALL OBVIOUSLY ALLOCATED TO ALL THE UNITS INCLUDING THOSE FOR WHICH SALE HAS ALREADY BE EN BOOKED AS ALL THE UNITS ARE PART OF THE COMMON STRUCTURE. ACCORDINGLY THE ASSESSEE MADE A SYSTEMATIC ESTIMATION OF COST STILL TO BE INCURRED WHICH IS VERY NEAR TO THE EXPENDITURE ACTUALLY INCURRED AT THE LATER STAGE. WE ACCORDINGLY AGREE WITH THE LD. AR OF THE ASSESSEE THAT AMOUNT OF COST STILL TO BE INCURRED FOR THE UNITS OF WHICH SALE HAS BEEN BOOKED SHOULD BE R EDUCED IN COMPUTING THE PROFIT REALIZABLE FROM SALE OF THOSE UNITS. THE ASSESSEE HAS MADE A REASONABLE ESTIMATE OF ENTIRE COST AND ITS PROPORTI ON TO THE UNITS ALREADY SOLD. THE EXPENDITURE FINALLY INCURRED IS HIGHER T HAN THE ESTIMATE MADE BY THE ASSESSEE. THERE CANNOT BE ANY BETTER APPROA CH FOR SUCH ESTIMATION. WE ACCORDINGLY FIND NO INFIRMITY IN TH E ORDER PASSED BY THE CIT(A) ON THIS ISSUE AND THEREFORE REJECT THIS GROU ND OF THE DEPARTMENTAL APPEAL. 5. THE LD DR IS HEARD WHO HAS FAIRLY ACCEPTED THE P OSITION THAT ALL THESE ISSUES UNDER CONSIDERATION ARE COVERED BY THE EARLIER DECI SION OF THE COORDINATE BENCH. 6. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. UNDISPUTEDLY, THERE ARE NO CHANGES IN THE FACTS AND CIRCUMSTANCES OF ITA NOS. 727 & 728/JP/16 THE ACIT, CIRCLE-6, JAIPUR VS. M/S ADITYA PROPCORN (P) LTD. JAIPUR 7 THE CASE. THE AO HAS TAKEN NOTE OF THE DECISION OF THE COORDINATE BENCH (SUPRA), HOWEVER, HAS DECIDED NOT TO FOLLOW THE SAM E FOR THE REASONS THAT THE DEPARTMENT IS IN APPEAL BEFORE THE HONBLE HIGH COU RT. THE LD CIT(A) HAS HOWEVER, FOLLOWED THE DECISION OF THE COORDINATE BE NCH (SUPRA). NO CONTRARY AUTHORITY HAS BEEN BROUGHT TO OUR NOTICE SUBSEQUENT TO ABOVE DECISIONS OF THE COORDINATE BENCH OR THE FACT THAT SAID DECISION OF THE COORDINATE BENCH HAS BEEN STAYED BY THE HONBLE HIGH COURT. IN VIEW OF THE SIMILAR FACTS AND CIRCUMSTANCES OF THE CASE AND RESPECTFULLY FOLLOWIN G THE DECISION OF COORDINATE BENCH IN ASSESSEES OWN CASE (SUPRA), THE GROUNDS O F APPEAL TAKEN BY THE REVENUE ARE DISMISSED. IN THE RESULT BOTH THE APPEALS FILED BY THE REVENUE ARE DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 19/12 /2016. SD/- SD/- (KUL BHARAT ) (VIKRAM SINGH YADAV) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER JAIPUR DATED:- 19/12/2016 PILLAI VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- THE ACIT, CIRCLE-6, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- M/S ADITYA PROPCORN (P) LTD. JAIPUR 3. VK;DJ VK;QDR@ CIT II, JAIPUR 4. VK;DJ VK;QDRVIHY@ THE CIT(A)-5, JAIPUR 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO.727 &728/JP/2016) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR.S ITA NOS. 727 & 728/JP/16 THE ACIT, CIRCLE-6, JAIPUR VS. M/S ADITYA PROPCORN (P) LTD. JAIPUR 8