SHRI JAIDEEP DHADDA, Jaipur V. INCOME TAX OFFICER, WARD-1-1, Jaipur

ITA 733/JPR/2017

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 6904 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 3 month(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 07-01-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2008-2009
• Appeal Filed On: 29-09-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: P P MEENA JCIT DHK
• Assessee Lawyers: RAJIV SOGANI
• Keywords: Bogus purchase; Rejection of books of accounts; Rule of consistency
• Section: 271(1)(c); 143(3); 6

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. 733/JP/2017 FU/KZKJ.K O'KZ@ ASSESSMENT YEAR : 2008-09 JAIDEEP DHADDA, 3934, DHADDA MARKET, JOHARI BAZAAR, JAIPUR. CUKE VS. I.T.O., WARD 1(1), JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: ABXPD 5619 E VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI ROHAN SOGANI & SHRI RAJIV SOGANI (CA) JKTLO DH VKSJ LS@ REVENUE BY : SHRI P.P. MEENA (JCIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 02/01/2019 MN?KKS'K.KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 07/01/2019 VKNS'K@ ORDER PER: VIJAY PAL RAO, J.M. THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER DATED 21/07/2017 OF LD. CIT(A)-I, JAIPUR ARISING FROM THE PENALTY ORDER PASSED U/S 271(1)(C) OF THE INCOME TAX ACT, 1961 (IN SHORT THE ACT) FOR THE A.Y. 2008-09. THE ASSESSEE HAS RAISED FOLLOWING GROUNDS O F APPEAL: 1(A) IN THE FACTS AND CIRCUMSTANCES OF THE CASE AN D IN LAW, THE LD. CIT(A) HAS ERRED IN CONFIRMING THE ACTION OF THE LD. A.O. IN IMPOSING THE PENALTY OF RS. 43,122/- U/S 271(1)(C) OF THE INCOME TAX ACT, 1961. THE ACTION OF THE LD. CIT(A) IS ILLEGAL, UNJUSTIFIE D, ARBITRARY AND AGAINST THE FACTS OF THE CASE. RELIEF MAY PLEASE BE GRANTED BY QUASHING THE SAID PENALTY OF RS. 43,122/- IMPOSED UNDER SECTION 271(1)(C). ITA 733/JP/2017_ JAIDEEP DHADDA VS ITO 2 (B) IN THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. A.O. HAS ERRED IN IMPOSING PENALTY U/S 271(1)(C) WITHOUT SPE CIFICALLY POINTING OUT WHETHER THE PENALTY WAS PROPOSED ON CONCEALMENT OF PARTICULARS OF INCOME OR FOR FURNISHING INACCURATE PARTICULARS OF INCOME. THE ACTION OF THE LD. A.O. IS ILLEGAL, UNJUSTIFIED ARBI TRARY AND AGAINST THE FACTS OF THE CASE. RELIEF MAY PLEASE BE GRANTED BY QUASHING THE PENALTY IMPOSED U/S 271(1)(C). 2. GROUND NO. 1(A) OF THE APPEAL IS REGARDING CONFI RMING OF PENALTY OF RS. 43,122/-. THE ASSESSMENT IN THE CASE OF ASSESSE E WAS COMPLETED U/S 143(3) OF THE ACT ON 14/12/2010. WHILE COMPLETING T HE SCRUTINY ASSESSMENT, THE ASSESSING OFFICER REJECTED THE BOOK S OF ACCOUNT OF THE ASSESSEE U/S 145(3) OF THE ACT AND MADE THE ADDITIO N ON ACCOUNT OF UNVERIFIABLE PURCHASES @ 25% OF SUCH PURCHASES. HENC E, THE ASSESSING OFFICER MADE THE ADDITION OF RS. 4,95,423/- BEING 2 5% OF BOGUS/UNVERIFIABLE PURCHASES OF RS. 19,81,691/-. 3. THE SAID ADDITION WAS CHALLENGED BY THE ASSESSEE BEFORE THE LD. CIT(A) IN THE QUANTUM PROCEEDINGS AND IT WAS RESTRICT ED TO 7% OF SUCH PURCHASES AS AGAINST 25% MADE BY THE ASSESSING OFFI CER. THUS, THE LD. CIT(A) HAS RESTRICTED THE ADDITION TO RS. 1,39,555/- . THE ASSESSING OFFICER WHILE PASSING THE ORDER U/S 271(1)(C) OF THE ACT ON 25/3/2015 LEVIED THE PENALTY OF RS. 43,122/- BEING 100% OF TAX SOUGHT TO BE EVADED BY THE ASSESSEE. 4. THE ASSESSEE CHALLENGED THE LEVY OF PENALTY U/S 2 71(1)(C) OF THE ACT BEFORE THE LD. CIT(A) BUT COULD NOT SUCCEED. ITA 733/JP/2017_ JAIDEEP DHADDA VS ITO 3 5. BEFORE US, THE LD AR OF THE ASSESSEE HAS SUBMITT ED THAT THE PENALTY HAS BEEN LEVIED BY THE ASSESSING OFFICER AGAINST TH E ADDITION WHICH WAS BASED ON ESTIMATION AND FURTHER THE LD. CIT(A) HAS A GAIN ESTIMATED THE ADDITION BY RESTRICTING THE SAID ADDITION FROM 25% TO 7%, THEREFORE, IT IS NOT A CASE OF CONCEALMENT OF INCOME OR FURNISHING I NACCURATE PARTICULARS OF INCOME. IN SUPPORT OF HIS CONTENTION, HE HAS RELIED UPON THE DECISION OF HONBLE JURISDICTIONAL HIGH COURT IN THE CASE OF CI T VS. MAHENDRA SINGH KHEDLA (2012) 252 CTR 453 (RAJ) AS WELL AS THE DECIS ION IN THE CASE OF SHIV LAL TAX VS CIT (2001) 251 ITR 373 (RAJ). THE LD A R HAS ALSO RELIED UPON THE DECISIONS OF THE COORDINATE BENCHES OF THI S TRIBUNAL DATED 16/1/2017 IN THE CASE OF SHRI VIKRAM SINGH VS DCIT IN ITA NO. 143/JP/2016 AS WELL AS DECISION DATED 22/12/2016 IN THE CASE OF DEEPAK DALELA VS ITO IN ITA NO. 1027/JP/2013. THE LD AR HAS ALSO RELIED ON THE FOLLOWING DECISIONS OF THIS TRIBUNAL: (I) ITA NO. 668/JP/2016, SHRI HEMANT SRIVASTAVA VS ITO ORDER DATED 08/01/2018. (II) ITA NO. 237/JP/2016, SMT. SHARMILA JAIN VS ITO ORDE DATED 08/01/2018 6. ON THE OTHER HAND, THE LD DR HAS SUBMITTED THAT THE ADDITION WAS MADE BY THE ASSESSING OFFICER ON THE BASIS OF THE E NQUIRY AND ALSO FOLLOWING THE PRECEDENTS ON THE ISSUE AND THEREFORE, IT IS NOT THE ADDITION ITA 733/JP/2017_ JAIDEEP DHADDA VS ITO 4 MERELY BASED ON ESTIMATION. HE HAS RELIED UPON THE ORDERS OF THE AUTHORITIES BELOW. 7. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WELL AS THE RELEVANT MATERIAL ON RECORD. THERE IS NO DISPUTE THAT WHILE CO MPLETING THE ASSESSMENT U/S 143(3) OF THE ACT, THE ASSESSING OFF ICER REJECTED THE BOOKS OF ACCOUNT OF THE ASSESSEE U/S 145(3) OF THE ACT AN D CONSEQUENTLY THE INCOME IN RESPECT OF UNVERIFIABLE/BOGUS PURCHASES WA S ESTIMATED @ 25% OF SUCH PURCHASES. THE SAID ADDITION MADE BY THE ASS ESSING OFFICER WAS RESTRICTED BY THE LD. CIT(A) TO 7% TO THOSE PURCHASE S AS AGAINST 25% ADDITION MADE BY THE ASSESSING OFFICER. THUS, IT IS CLEAR THAT THE ADDITION SUSTAINED BY THE LD. CIT(A) IS NOTHING BUT IS BASED ON THE ESTIMATION OF INCOME BY TAKING 7% OF SUCH UNVERIFIABLE PURCHASES. THE ORDER OF THE LD. CIT(A) IN QUANTUM APPEAL IS RELEVANT ON THIS ASPECT IN PARA 4.3 AS UNDER: 4.3 I HAVE CAREFULLY PERUSED THE ORDER OF THE AO A ND THE SUBMISSIONS OF THE AR ALONGWITH THE ORDER OF THE HONBLE ITAT, JAIPUR IN THE CASE OF THE ASSESSEE FOR ASSESSMENT YEAR 2006-07. THE HONBLE I TAT, JAIPUR BENCH HAS CONSISTENTLY HELD THAT THE PROVISIONS OF SECTIO N 145(3) CAN BE INVOKED FOR REJECTION OF BOOKS OF ACCOUNTS IN SUCH CASES WH ERE THE PURCHASES REMAIN UNVERIFIABLE. ONCE THE SUMMONS ISSUED WERE N OT COMPLIED WITH THE ONUS SHIFTED ON THE ASSESSEE TO PRODUCE THE SEL LERS ALONGWITH THE STOCK REGISTERS FOR VERIFICATION OF THE TRANSACTION S. THIS WAS NOT DONE AND SO THE ONUS WAS NOT DISCHARGED BY THE ASSESSEE. FUR THER IT IS NOT UNDERSTOOD AS TO HOW THE APPELLANT WAS ABLE TO PROD UCE CONFIRMATIONS FROM THESE ALLEGED SELLERS BUT WAS NOT ABLE TO PROD UCE THEM. IN VIEW OF ITA 733/JP/2017_ JAIDEEP DHADDA VS ITO 5 THE CONSISTENT VIEW TAKEN BY THE HONBLE ITAT, JAIP UR IN THE CASE OF JEWELERS AND THE FACTS OF THE CASE, THE REJECTION O F BOOKS OF ACCOUNTS BY INVOKING THE PROVISIONS OF SECTION 145(3) IS UPHELD . REGARDING ESTIMATION OF INCOME IT IS CLEAR THAT TH E FACTS OF THE ASSESSEE ARE DIFFERENT FROM THE CASE LAWS RELIED ON BY THE A O NAMELY SANJAY OIL CAKE INDUSTRIES VS. CIT. MOREOVER, THE FACTS OF THE CASE ARE COVERED BY THE FINDING OF THE HONBLE ITAT, JAIPUR IN ITS OWN CASE FOR ASSESSMENT YEAR 2006-07, ITA NO.16/JP/2011 DATED 31.3.2011 WHE REIN THE HONBLE ITAT, JAIPUR HAD SUSTAINED THE ADDITION OF RS.20,00 0/- ON TOTAL UNVERIFIABLE PURCHASES OF RS.2.84 LACS. THE HONBLE ITAT, JAIPUR THUS DISALLOWED 0.07% OF THE UNVERIFIED PURCHASES IN THE CASE OF THE APPELLANT. DURING THIS ASSESSMENT YEAR THE UNVERIFI ED PURCHASES ARE RS. 19,81,691/-. A DISALLOWANCE OF 0.07% OF THESE IS RE QUIRED TO BE MADE WHICH IS RS. 1,39,555/- SINCE THE MATTER IS COVERED BY THE ORDER OF THE HONBLE ITAT, JAIPUR, THIS RESULTS IN CONFIRMATION OF TRADING ADDITION OF RS.1,39,555/-. WE FURTHER NOTE THAT THE COORDINATE BENCH OF THIS TR IBUNAL HAVE TAKEN A CONSISTENT VIEW ON THIS ISSUE OF LEVY OF PENALTY AGA INST THE ADDITION MADE BY THE ASSESSING OFFICER BY TAKING THE INCOME @ 25% OF THE UNVERIFIABLE PURCHASES HOLDING THAT THE PENALTY LEVIED AGAINST T HE ADDITION BASED ON ESTIMATION OF INCOME IS NOT SUSTAINABLE. IN THE CAS E OF SHRI HEMANT SRIVASTAVA VS ITO (SUPRA), THE COORDINATE BENCH HAS CONSIDERED THIS ISSUE IN PARA 7 AND 8 AS UNDER: 7. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WEL L AS RELEVANT MATERIAL ON RECORD. THERE IS NO DISPUTE THAT THE ADDITION IN QU ESTION WAS MADE BY THE AO @ 25% OF UNVERIFIABLE PURCHASES WHILE COMPLETING THE ASSESSMENT ITA 733/JP/2017_ JAIDEEP DHADDA VS ITO 6 U/S 143(3). THERE IS NO DEFINITE FINDING BY THE AO THAT THE ASSESSEE HAS INFLATED THE PURCHASE TO THE EXTENT OF 25% BUT IT W AS ONLY ESTIMATION OF THE AO TO MAKE ADDITION WHICH WAS SUBSEQUENTLY REST RICTED BY THIS TRIBUNAL TO 15% OF UNVERIFIABLE PURCHASE. THUS EVEN THE ADDITION IN QUANTUM PROCEEDINGS ATTAINED THE FINALITY IT IS NOT BASED ON THE FINDING THAT THE ASSESSEE HAS INFLATED THE PURCHASES AND SU PPRESSED THE INCOME OR CLAIM OF THE ASSESSEE WAS ABSOLUTELY BOGUS. THE AO HAS ONLY DOUBTED THE PURCHASES FROM CERTAIN PARTIES AND MADE THE ADD ITION ONLY TO THE EXTENT OF 25% OF PURCHASES MADE FROM SUCH PARTIES I NSTEAD OF DISALLOWING ENTIRE PURCHASES FROM THOSE PARTIES. WHEN THE AO HA S NOT GIVEN ANY FINDING OF BOGUS PURCHASES THEN THE DISALLOWANCE MA DE BY THE AO IS ONLY BASED ON ESTIMATION WHICH WAS RESTRICTED BY THIS TR IBUNAL AS REASONABLE ESTIMATED. ACCORDINGLY, THE ISSUE OF LEVY OF PENALT Y U/S 271(L)(C) OF SUCH ADDITION IS NOW COVERED BY THE DECISION OF HON'BLE JURISDICTION HIGH COURT IN CASE OF CIT VS. MAHENDRA SINGH KHEDLA(SUPRA). TH E HON'BLE HIGH COURT WHILE CONSIDERING THE ISSUE OF LEVY OF PENALTY ARIS ING FROM THE ADDITION BASED ON ESTIMATION IN PARA 6 TO 8 AS UNDER:- 6. WE HAVE CONSIDERED THE SUBMISSIONS OF LEARNED COUN SEL FOR APPELLANT AND EXAMINED THE REASONS ASSIGNED BY APPELLATE AUTH ORITY AS WELL AS APPELLATE TRIBUNAL FOR SETTING ASIDE THE PENALTY OR DER. 7. THE APPELLATE AUTHORITY AS WELL AS THE APPELLATE T RIBUNAL BOTH CONSIDERED THE MATTER IN DETAIL AND BY SPEAKING ORD ER SET ASIDE THE PENALTY LEVIED BY ASSESSING OFFICER, IN THE FACTS A ND CIRCUMSTANCES OF THE PRESENT CASE. THE RELEVANT PORTION OF PARA 7 OF ORDER OF THE TRIBUNAL IS REPRODUCED AS UNDER:- 'PARA 7. .....THE ENQUIRY CONDUCTED BY THE AO MAY L EAD TO ARRIVE AT THE FINDINGS AS TO WHETHER THE PARTICULARS DISCLOSE D ARE TRUTHFUL OR FALSE OR NOT PROVED TO BE SATISFACTORY. IN THE FIRS T CASE IT WOULD BE A POSITIVE CASE OF NO CONCEALMENT, IN SECOND CASE IT WOULD BE A POSITIVE CASE OF CONCEALMENT AND IN THIRD CASE BENE FIT OF DOUBT WILL GO IN FAVOUR OF THE ASSESSEE. THE CASE OF THE ASSES SEE FALLS WITHIN THIRD CATEGORY WHERE THE ALLEGED FACT OF INTRODUCTI ON OF CAPITAL IS FOUND TO BE NOT PROVED SATISFACTORILY. THEREFORE, I T IS NOT A CASE OF POSITIVE CONCEALMENT AND BENEFIT OF DOUBT GOES IN F AVOUR OF THE ASSESSEE. THERE IS NO DISPUTE THAT TRADING ADDITION WAS MADE ON THE BASIS OF ESTIMATION BECAUSE THE RESULTS SHOWN BY TH E ASSESSEE WAS NOT ITA 733/JP/2017_ JAIDEEP DHADDA VS ITO 7 FOUND SATISFACTORY BY THE AO. WHERE AN ESTIMATED AD DITION WAS CONCEALMENT OF PARTICULARS OF INCOME OR FURNISHING INACCURATE PARTICULARS THEREOF ON THE PART OF THE ASSESSEE TO THE EXTENT OF AMOUNT IN DIFFERENCE SHOWN BY THE ASSESSEE AND ESTIMATED B Y THE DEPARTMENT DEPENDS UPON THE FACTS AND CIRCUMSTANCES OF THE CAS E. .. UNDER THESE CIRCUMSTANCES WHEN IN THE PRESENT CASE THERE WAS NO POSITIVE EVIDENCE BEYOND DOUBT REGARDING ESTIMATED TRADING ADDITION THAT THE AMOUNT IN DIFFERENCE BETWEEN THE RESULT SH OWN BY THE ASSESSEE AND THAT ESTIMATED BY THE AO WAS RESULTANT OF CONCE ALMENT OF PARTICULARS OF INCOME OR FURNISHING INACCURATE PART ICULARS THEREOF ON THE PART OF THE ASSESSEE, PENALTY UNDER SECTION 271 (1) (C) OF THE ACT CANNOT BE LEVIED. THE AO HAD REJECTED THE BOOKS OF ACCOUNT AND ESTIMATED THE TRADING ADDITION ON THE BASIS THAT THE ASSESSEE HAD NOT MAINTAINED SITE- WISE ACCOUNT, NO HEAD-WISE DETAILS OF CLAIMED PURCH ASES WERE FURNISHED, NO SEPARATE HEAD OF EXPENSES WAS MAINTAI NED, WORK IN PROGRESS WAS NOT DECLARED, SOME WAGES WERE SHOWN OU TSTANDING WITHOUT COMPLETE DETAILS OF CREDITORS, STOCK REGIST ER WAS NOT MAINTAINED AND MISC. EXPENSES ON WATER TRANSPORTATION ETC. WER E NOT VERIFIABLE AND PURCHASE VOUCHERS OF SAND, STEEL, BAJRI ETC. WERE S ELF MADE ETC. ASSESSEE EXPLAINED REASONS FOR THE ABOVE DEFECTS WHICH WERE NOT ACCEPTED BY THE AO AS NOT FOUND SATISFACTORY. THE AO ACCORDINGLY MA DE ESTIMATION. THE CIRCUMSTANCES SUGGEST THAT IT MAY BE JUST AND P ROPER CASE OF MAKING ESTIMATED TRADING ADDITION BUT AN INFERENCE THEREFROM CANNOT BE DRAWN BEYOND DOUBT ESPECIALLY KEEPING IN MIND THE N ATURE OF WORK IN NOT MAINTAINING THOSE BOOKS AND DETAILS SUPPORTED W ITH PROPER VOUCHERS ETC. THAT THERE WAS CONCEALMENT OF PARTICULARS OF I NCOME OR FURNISHING INACCURATE PARTICULARS THEREOF ON THE PART OF THE A SSESSEE TO ATTRACT THE PENAL PROVISIONS. IN VIEW OF ABOVE DISCUSSION AND K EEPING IN MIND THE FACT AND CIRCUMSTANCES OF THE PRESENT CASE, WE ARE OF THE VIEW THAT THE LD. CIT (A) WAS JUSTIFIED IN DELETING THE PENALTY I N ABSENCE OF POSITIVE EVIDENCE WITH THE DEPARTMENT THAT THERE WAS CONCEAL MENT OF PARTICULARS OF INCOME OR FURNISHING INACCURATE PARTICULARS THER EOF ON THE PART OF THE ASSESSEE TOWARDS THE ADDITION IN QUESTION. THE FIRS T APPELLATE ORDER ON THE ISSUE IS THUS UPHELD.' 8. THE ABOVE FINDING OF THE TRIBUNAL MAKES IT CLEAR T HAT ADDITIONS MADE BY THE ASSESSING OFFICER WERE BASED ON ESTIMATION O NLY. A FACT OR ALLEGATION BASED ON ESTIMATION CANNOT BE SAID TO BE CORRECT ONLY, IT CAN BE INCORRECT ALSO. THEREFORE, IN THE FACTS AND CIRC UMSTANCES OF THE CASE, PENALTY WAS WRONGLY LEVIED BY THE ASSESSING OFFICER . THE BASIS FOR LEVYING PENALTY IN THE PRESENT CASE IS ONLY ESTIMAT ION, WHICH IS PURELY A QUESTION OF FACT AND THERE IS A CONCURRENT FINDING OF FACT RECORDED BY FIRST APPELLATE AUTHORITY AS WELL AS THE APPELLATE TRIBUNAL BOTH. 8. IN THE FACTS AND CIRCUMSTANCES AS DISCUSSED ABOV E AS WELL AS RESPECTFULLY FOLLOWING THE DECISION OF HON'BLE JURISDICTION HIGH COURT IN CASE OF CIT VS. ITA 733/JP/2017_ JAIDEEP DHADDA VS ITO 8 MAHENDRA SINGH KHEDLA (SUPRA) WE DELETE THE PENALTY LEVIED U/S 271(1)(C). THE APPEAL OF THE ASSESSEE IS ALLOWED. THEREFORE, IN VIEW OF THE DECISION OF THE HONBLE JUR ISDICTIONAL HIGH COURT IN THE CASE OF CIT VS MAHENDRA SINGH KHEDLA (SUPRA), THE LEVY OF PENALTY AGAINST THE ADDITION MADE ON THE BASIS OF ESTIMATIO N OF INCOME BY TAKING 25% OF THE UNVERIFIABLE PURCHASES WHICH WAS REDUCED IN THE SAID CASE TO 15% WAS FOUND TO BE NOT SUSTAINABLE. THIS VIEW HAS BE EN CONSISTENTLY TAKEN EVEN IN OTHER DECISIONS AS REFERRED BY THE LD AR OF THE ASSESSEE. ACCORDINGLY, TO MAINTAIN THE RULE OF CONSISTENCY AN D IN ABSENCE OF ANY CONTRARY PRECEDENT BROUGHT TO OUR NOTICE, WE DELETE THE LEVY OF PENALTY U/S 271(1)(C) OF THE ACT. 8. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 07 TH JANUARY, 2019. 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:- 07 TH JANUARY, 2019 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- SHRI JAIDEEP DHADDA, JAIPUR. 2. IZR;FKHZ @ THE RESPONDENT- THE I.T.O., WARD 1(1), JAIPUR. 3. VK;DJ VK;QDR @ CIT 4. VK;DJ VK;QDRVIHY @ THE CIT(A) ITA 733/JP/2017_ JAIDEEP DHADDA VS ITO 9 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ @ DR, ITAT, JAIPUR 6. XKMZ QKBZY @ GUARD FILE (ITA NO. 733/JP/2017) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR