SMT. KAMALA CHOUDHARY, JAIPUR V. INCOME TAX OFFICER, WARD-3-4, JAIPUR

ITA 786/JPR/2017

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 3583 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 6 month(s) 2 day(s)
• Appeal Type: Income Tax (International Taxation) Appeal
• Pronouncement Date: 29-04-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2008-2009
• Appeal Filed On: 27-10-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: MOHAN CHOUDHARY
• Keywords: Sale consideration of property below Jantri Value; Capital asset; Gift
• Section: 143(3); 50C; 147

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 FOT; IKWY 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. 786/JP/2017 FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2008-09 SMT. KAMLA CHOUDHARY C-4, HATHI BABU MARG, BANI PARK, JAIPUR (RAJ.) CUKE VS. ITO, WARD-3(4), INCOME TAX, JAIPUR (RAJ.) LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: ADDPC8911C VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI MOHAN CHOUDHARY (ADV.) JKTLO DH VKSJ LS @ REVENUE BY : SHRI ANUP SINGH (ADDL.CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 29/05/2018 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 01/06/2018 VKNS'K@ ORDER PER: VIKRAM SINGH YADAV, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST TH E ORDER OF LD. CIT(A)-1, JAIPUR DATED 20.09.2017 FOR ASSESSMENT YE AR 2008-09 WHEREIN THE ASSESSEE HAS TAKEN THE FOLLOWING GROUND S OF APPEAL AS UNDER:- 01. THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. COMMISSIONER (APPEALS)-1, INCOME TAX, JAIPUR VIDE O RDER DATED 20.09.2017 HAS GROSSLY ERRED IN CONFIRMING THE ENHA NCED RETURNED INCOME OF THE APPELLANT-ASSESSEE BY RS. 60 ,283/- LEVIED BY THE ASSESSING OFFICER, WARD-3(4), INCOME TAX JAI PUR IN THEIR ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 2 ORDER PASSED ON 05.02.2016 U/S 143(3) OF THE ACT, T HEREON TREATING THE TRANSFER OF CAPITAL ASSET UNDER THE FA MILY SETTLEMENT/ARRANGEMENT BETWEEN BROTHERS WIFE AND H ER BROTHER- IN-LAW AS SHORT TERM CAPITAL GAIN LIABLE FOR TAX. 2. THAT THE ORDER IS BAD IN LAW. 2. THE LD AR SUBMITTED THAT THE ASSESSEE IS A HOUSE WIFE AND HER SOURCE OF INCOME IS RENTAL INCOME. SHE FILED HE R RETURN OF INCOME FOR THE AFORESAID ASSESSMENT YEAR DECLARING THE RENTAL INCOME OF RS.1,19,200/-. TO BE PRECISE, IT IS SUBMI TTED THAT THE FATHER-IN-LAW OF THE ASSESSEE NAMELY, SHRI LAXMI NA RAYAN CHOUDHARY EXECUTED A TRANSFER/SALE DEED OF A PLOT O F LAND IN FAVOUR OF THE ASSESSEE ON 02.02.2005 AS SHE WAS LOO KING AFTER HIS DAY-TO-DAY ACTIVITIES IN THE OLD AGE AND PROVID ING THE REGULAR SERVICES. SUCH PROPERTY WAS TRANSFERRED TO THE APPE LLANT- ASSESSEE BY HER FATHER-IN-LAW OUT OF NATURAL LOVE A ND AFFECTION BEING THE GIFT TO HIS ELDER DAUGHTER-IN-LAW FOR THE STATED REASON. THIS HAS RESULTED INTO FAMILY DISPUTE AND FRACTIONS AROSE AMONG THE OTHER FAMILY MEMBERS WITH THE FAMILY OF THE APP ELLANT- ASSESSEE ITSELF. ACCORDINGLY, A CIVIL SUIT BEARING NO. 76/2005 WAS ALSO FILED BEFORE THE COURT OF ADDITIONAL DISTRICT & SESSION JUDGE NO. 3, JAIPUR CITY, JAIPUR BY THE AGGRIEVED FAMILY MEMBERS AGAINST OTHER MEMBERS INCLUDING THE APPELLANT-ASSES SEE AND HER HUSBAND SHRI DAMODAR LAL CHOUDHARY. ULTIMATELY, A S ETTLEMENT WAS ENTERED INTO AND PRODUCED BEFORE THE COURT IN W HICH IT WAS DECIDED THAT THEY WILL BE BOUND BY EARLIER DISTRIBU TION MUTUALLY DECIDED AMONG THE FAMILY MEMBERS IN THE YEAR OF 199 5 AND ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 3 ACCORDINGLY, TO SETTLE THE FAMILY DISPUTES, THE APP ELLANT-ASSESSEE HAD TO REVERT/RE-TRANSFER THE PART PROPERTY IN FAVO UR OF HER BROTHER-IN-LAW. THOUGH SUCH TRANSFER/ SALE DEED DAT ED 24.09.2007 WAS EXECUTED BY THE APPELLANT-ASSESSEE IN FAVOUR OF HER BROTHER- IN-LAW NAMELY, SHRI MOHAN LAL CHOUDHARY, WHICH WAS ALSO BEING THE PARTY IN THE SUIT TITLED AS 'MOHAN LAL JAT S/O SHRI LAXMI NARAYAN JAT V/S VIRENDRA KUMAR, RAM GOPAL & OTHERS' . THIS TRANSACTION TOOK PLACE AS A FAMILY SETTLEMENT/ARRAN GEMENT AMONG FAMILY MEMBERS AND NOT AS ACTUAL SALE OR TRANSFER O F CAPITAL ASSET LIABLE FOR LEVY OF INCOME TAX. 3. IT WAS SUBMITTED BY THE LD AR THAT THE REGISTRY WAS EXECUTED BY THE APPELLANT-ASSESSEE IN FAVOUR OF HER BROTHER-IN- LAW MERELY TO SETTLE THE FAMILY DISPUTE IN PURSUANC E OF THE 'RAJINAMA (SETTLEMENT)' FILED BEFORE THE COURT OF L AW AND IN COMPLIANCE OF DECREE PASSED BY THE COURT. MERELY A TOKEN AMOUNT OF RS.50,000/- WAS MENTIONED IN THE SAID TRA NSFER DEED DATED 24.09.2007. HOWEVER, THE REGISTERING AUTHORIT Y ADOPTED THE VALUE AS RS.5,60,800/- FOR STAMP DUTY PURPOSE. THUS , THE SAID VALUE ADOPTED BY THE SUB-REGISTER IS NOT APPLICABLE IN THE INSTANT CASE BECAUSE THE SAID TRANSACTION IS ONLY A FAMILY SETTLEMENT/ARRANGEMENT IN PURSUANCE OF OR IN COMPLI ANCE OF THE COURTS DECREE. IT IS STATED THAT THE TRANSACTION I S NOT OF ACTUAL SALE BUT IS A SETTLEMENT IN PURSUANCE OF COURTS DE CREE. IT IS, THEREFORE, HUMBLY & RESPECTFULLY SUBMITTED THAT THE PROVISIONS OF SECTION 50C OF THE ACT ARE ALSO NOT APPLICABLE IN T HE PRESENT CASE ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 4 IN VIEW OF THE AFOREMENTIONED FACTS AND CIRCUMSTANC ES OF THE CASE. 4. IT WAS FURTHER SUBMITTED THAT IN THE PRESENT CAS E, THE ASSESSMENT OF THE AFORESAID APPELLANT-ASSESSEE FOR THE SAID ASSESSMENT YEAR HAS BEEN COMPLETED ON 05.02.2016 AD DING THE INCOME OF RS.60,283/- AS SHORT TERM CAPITAL GAIN SO URCES. IT IS BEING ALLEGED THAT NEITHER THE NAME OF THE ASSESSEE NOR HER HUSBAND SHRI DAMODAR LAL CHOUDAHRY NAME IS REFLECTE D IN THE FILED SUIT NO. 76/2005 TITLED AS 'MOHAN LAL JAT S/O SHRI LAXMI NARAYAN JAT V/S VIRENDRA KUMAR, RAM GOPAL & OTHERS' BEFORE THE DISTRICT COURT REGARDING THE TRANSFER OF PROPERTY O N WHICH THE CAPITAL GAIN TAX IS LEVIABLE. IT HAS BEEN FURTHER A LLEGED THAT NO DISPUTES HAD ARISEN BETWEEN THE ASSESSEE'S FAMILY A ND OTHER FAMILY MEMBERS REGARDING THE TRANSFER OF SUCH PROPE RTY IN THE TRANSFER DEED EXECUTED BY THE ASSESSEE DULY MADE IN FAVOUR OF SHRI MOHAN LAL CHOUDAHRY ON 24.09.2007 WHICH WAS EA RLIER ON 02.02.2005 TRANSFERRED BY THE FATHER-IN-LAW IN FAVO UR OF THE ASSESSEE. HENCE, ACCORDING TO THE LD. AO, THE SAID TRANSACTION OF TRANSFER IS NOT A FAMILY SETTLEMENT TRANSACTION AND THUS, SECTION 50C OF THE ACT IS APPLICABLE. THUS, ADDED THE SAME TO THE TOTAL INCOME OF THE APPELLANT-ASSESSEE U/S 147 OF THE I.T .ACT, 1961. 5. IN THIS REGARD, IT WAS SUBMITTED BY THE LD AR TH AT THE APPELLANT-ASSESSEE HAD DULY EXPLAINED THE FAMILY RE LATIONS BETWEEN THE TRANSFEROR AND TRANSFEREE IN RELATION O F SUCH TRANSFERRED PROPERTY THROUGH THE WRITTEN SUBMISSION OR ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 5 DOCUMENTS AT THE TIME OF HEARING ALONG WITH LARGER FAMILY PEDIGREE. THAT THE RELATION BETWEEN THE TRANSFEROR AND TRANSFEREE IS OF DEVER AND BHABHI. THE SAID PROPERTY BELONGE D TO THE FATHER-IN-LAW OF THE TRANSFEROR AND FATHER OF THE T RANSFEREE PRIOR TO 02.02.2005. THE APPELLANT-ASSESSEE IS LIVING WIT H HER FATHER- IN-LAW NAMELY, SHRI LAXMI NARAYAN CHOUDAHRY AND DUE TO LOVE AND AFFECTION & LOOKING AFTER DAY-TO-DAY ACTIVITIES IN THE OLD AGE, HE WAS HAPPY WITH THE DAUGHTER-IN-LAW AND THROUGH A WILL, HE MADE TRANSFER OF THE SUCH PROPERTY ON 02.02.2005 IN FAVOUR OF THE APPELLANT-ASSESSEE. LATER ON, DUE TO TRANSFER OF SU CH PROPERTY IN FAVOUR OF THE APPELLANT-ASSESSEE, FAMILY FRACTION & DISPUTES AROSES BETWEEN THE OTHER FAMILY MEMBERS AND APPELLANT-ASSE SSEE FAMILY. THEREFORE, CIVIL SUIT BEARING NO. 76/2005 WAS FILED BEFORE THE COURT TITLED AS 'MOHAN LAL JAT S/O SHRI LAXMI NARAYAN JAT V/S VIRENDRA KUMAR, RAMGOPAL AND OTHERS' FOR DISTRIBUTION OF THE PROPERTY AND IN WHICH, ULTIMATELY SETTLEMENT WAS FILED. ACCORDIN GLY, IN COMPLIANCE OF SAID SETTLEMENT (RAJINAMA), THE APPEL LANT-ASSESSEE TRANSFERRED OR REVERTED THE PART LAND ON 24.09.2007 OUT OF THE SUCH PROPERTY IN FAVOUR OF HER BROTHER-IN-LAW SHRI MOHAN LAL CHOUDHARY. BOTH THE TRANSFEROR AND TRANSFEREE ARE A LSO PERMANENTLY RESIDING AT THE SAME ADDRESS WHICH IS M ENTIONED IN THE TRANSFERRED PROPERTY. ALL THE FAMILY MEMBERS AR E ILL-LITERATE AND THEY DID NOT BELIEVE IN OTHER MODE OF TRANSFER EXCE PT TO THE SALE REGISTRY. THEREFORE, SUCH TRANSACTION IS ONLY OR EN TIRELY IS A FAMILY SETTLEMENT TRANSACTION AND SECTION 50C OF THE ACT I S NOT APPLICABLE IN THE INSTANT PRESENT CASE. THE MAIN REASONS FOR N OT FULLY ACCEPTING THE EXPLANATION OF THE APPELLANT-ASSESSEE IS THAT THE ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 6 NAME OF THE APPELLANT-ASSESSEE AS WELL AS HER HUSBA ND IS NOT MENTIONED IN THE FILED SUIT BEFORE THE COURT AND DI SPUTES BETWEEN THE FAMILY OF APPELLANT-ASSESSEE & FAMILY OF OTHER MEMBERS IS ALSO NOT MENTIONED IN THE TRANSFER DEED DATED 24.09.2007 . IT IS RESPECTFULLY SUBMITTED THAT IT CANNOT BE SAID THAT THE APPELLANT- ASSESSEE AND HER HUSBAND WERE NOT AFFECTED PARTY IN THE FILED SUIT. THE APPELLANT-ASSESSEE AND HER HUSBAND ARE COVERED UNDER THE WORD OTHERS IN THE TITLE OF THE SUIT. ALL JOINT F AMILY MEMBERS OF THE APPELLANT-ASSESSEES FATHER-IN-LAW AS WELL AS F AMILY OF OTHER MEMBERS WERE PERMANENTLY RESIDING AT THE SAID DISPU TED PROPERTY SINCE BEGINNING. 6. IT WAS FURTHER SUBMITTED THAT THE SAID PLOT WAS APPROXIMATELY ADMEASURING 1000 SQYD WHICH WAS PURCH ASED ON 26.12.1959 BY THE FATHER-IN- LAW OF THE APPELLANT. OUT OF SUCH ENTIRE PLOT, A PIECE OF PLOT WAS TRANSFERRED BY THE FATHER-IN-LAW ON 02.02.2005 IN FAVOUR OF THE APPELLANT-ASSESSEE. ALL DISPUTES WERE RELATED TO SUCH PLOT. THE CASE WAS FILED BEFORE THE COURT TITLED AS 'MOHAN LAL JAT S/O SHRI LAXMI NARAYAN JAT V/S VIRED NDRA KUMAR, RAMGOPAL & OTHERS' ALSO HAD THEIR SAME ADDRESSES AN D FOR THE SAME PROPERTY. THEREFORE, IT CANNOT BE SAID THAT TH E APPELLANT- ASSESSEE AND HER HUSBAND WERE NOT THE AFFECTED PART Y. THE APPELLANT-ASSESSEE AND HER HUSBAND ARE COVERED UNDE R THE WORD 'OTHERS' IN THE TITLE OF THE SUIT. IT IS ALSO HUMBL Y SUBMITTED THAT THE DISPUTES WERE SETTLED & IN COMPLIANCE OF COMPRO MISE PRODUCED BEFORE THE COURT BY THE JOINT FAMILY MEMBE RS OF THE APPELLANT-ASSESSEE IN THE CASE OF CIVIL SUIT FILED. ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 7 7. PER CONTRA, THE LD DR HAS RELIED ON THE FINDINGS OF THE AO AND THAT OF THE LD CIT(A) WHICH IS REPRODUCED AS UNDER :- (1) THE BRIEF FACTS OF THE CASE ARE THAT DURING THE YEA R UNDER CONSIDERATION, VIDE REGISTERED SALE DEED DATED 24/0 9/2007, THE APPELLANT HAS SOLD AN IMMOVABLE PROPERTY TO SH. MOH AN LAL CHAUDHARY, BROTHER OF THE HUSBAND OF THE APPELLANT FOR A CONSIDERATION OF RS. 50,000/-, WHICH WAS VALUED AT RS. 5,60,800/- BY THE SUB REGISTRAR OF PROPERTIES FOR THE PURPOSES OF CHARGING STAMP DUTY. THE SAID PROPERTY WAS ACQUIRED BY THE A PPELLANT THROUGH REGISTERED SALE DEED DATED 24.02.2005. ON T HE BASIS OF THESE FACTS, THE AO HAS INVOKED THE PROVISIONS OF S ECTION 50C OF THE ACT AND HAS COMPUTED SHORT-TERM CAPITAL GAINS O N THE SALE OF THE PROPERTY UNDER CONSIDERATION AT RS. 60,283/- AN D MADE THE ADDITION OF THE SAME TO THE INCOME OF THE APPELLANT . (II) DURING THE ASSESSMENT PROCEEDINGS AS WELL AS A PPELLATE PROCEEDINGS, IT WAS SUBMITTED BY THE APPELLANT THAT ACTUALLY THERE WAS NO SALE OR PURCHASE OF ANY IMMOVABLE PROPERTY B Y THE APPELLANT AND IN VIEW OF THE FAMILY SETTLEMENT, A P ART OF THE PROPERTY RECEIVED BY THE APPELLANT FROM HER FATHER- IN-LAW, SH. LAKSHMI NARAYAN CHAUDHARY, AS A GIFT, WAS TRANSFERR ED BY HER TO HER BROTHER IN LAW AND THE TOKEN AMOUNT OF RS. 50,0 00 WAS REFERRED IN THE SALE DEED FOR GETTING THE PROPERTY REGISTERED. (III) I HAVE DULY CONSIDERED THE SUBMISSIONS OF THE APPELLANT, ASSESSMENT ORDER AND THE MATERIAL PLACED ON RECORD. IT IS NOTED THAT THE APPELLANT HAS ACQUIRED THE PROPERTY THROUG H A REGISTERED ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 8 SALE DEED FROM HER FATHER-IN-LAW AND HAS ALSO SOLD A PART OF THE SAID PROPERTY TO HER BROTHER IN LAW, AGAIN THROUGH A REGISTERED SALE DEED. IT IS PERTINENT TO MENTION THAT IN THE SALE D EED DATED 24.09.2007, IT WAS STATED THAT THE APPELLANT HAS PU RCHASED THE PROPERTY FROM SH. LAKSHMI NARAYAN CHAUDHARY. FURTHE R, ON A PERUSAL OF THESE SALE DEEDS, IT IS OBSERVED THAT TH ESE ARE SILENT ABOUT ANY FAMILY SETTLEMENT AS CLAIMED BY THE APPEL LANT. IT IS FURTHER NOTED THAT THE DISPUTE BEFORE THE COURT WAS BETWEEN SH. MOHAL LAL JAT ON THE ONE HAND AND SHRI VIRENDER KUM AR AND SHRI RAM GOPAL ON THE OTHER SIDE. NEITHER THE APPELLANT NOR HER HUSBAND SH. DAMODAR LAL WAS PARTY TO THE SAID SUIT. IT MAY BE MENTIONED THAT THE REGISTERED SALE DEEDS ARE DOCUMENTARY EVID ENCES AND A VERY IMPORTANT PIECE OF EVIDENCE AS REGISTERED BEFO RE A GOVERNMENT AGENCY AND IT CANNOT BE BRUSHED ASIDE EASILY. FURTH ER AS PER INDIAN EVIDENCE ACT, A DOCUMENTARY EVIDENCE CAN BE COUNTER ED BY ONLY A DOCUMENTARY EVIDENCE. HOWEVER, NO SUCH DOCUMENTARY EVIDENCE HAVE BEEN FILED TO CONTRADICT THE CONTENTS OF THE R EGISTERED SALE DEEDS I.E. ONE THROUGH WHICH THE APPELLANT HAS ACQU IRED THE PROPERTY UNDER CONSIDERATION AND THE OTHER ONE THRO UGH WHICH, THE APPELLANT HAS SOLD A PART OF THE SAID PROPERTY. (IV) THEREFORE, IN VIEW OF THE ABOVE DISCUSSION AND LOOKING TO THE TOTALITY OF FACTS AND CIRCUMSTANCES THE CASE, IT IS HELD THAT THE AO WAS JUSTIFIED IN MAKING SHORT TERM CAPITAL GAINS AM OUNTING TO RS. 60,283/- TO THE INCOME OF THE APPELLANT. 8. REGARDING THE FINDINGS OF THE LD CIT(A) THAT NO SUCH DOCUMENTARY EVIDENCE HAVE BEEN FILED TO CONTRADICT THE CONTENTS OF ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 9 THE REGISTERED SALE DEEDS, THE LD AR SUBMITTED A CO PY OF SUPPLEMENTARY DEED REGISTERED WITH THE STAMP AUTHOR ITIES ON 9.2.2018 TO THE ORIGINAL SALE DEED DATED 24.09.2007 EXECUTED BETWEEN THE ASSESSEE AND MOHAN LAL CHAUDHARY STATIN G THAT THE SAID SALE DEED HAS BEEN EXECUTED PURSUANT TO COURT DECREE AND AS PART OF FAMILY SETTLEMENT. SINCE THE SAME IS AN AD DITIONAL EVIDENCE WHICH GOES TO THE ROOT OF THE MATTER, THE SAME IS H EREBY ADMITTED IN THE INTEREST OF JUSTICE AND THE MATTER IS REMAND ED BACK TO THE FILE OF THE LD CIT(A) TO EXAMINE THE MATTER A FRESH TAKI NG INTO CONSIDERATION AFORESAID SUPPLEMENTARY DEED AFTER PR OVIDING OPPORTUNITIES TO BOTH THE PARTIES. WE THEREFORE DON T DEEM IT APPROPRIATE TO EXAMINE THE CONTENTIONS SO ADVANCED ON MERITS BEFORE US AT THIS STAGE. THE ASSESSEE SHALL HOWEV ER, BE AT LIBERTY TO RAISE THE AFORESAID CONTENTIONS BEFORE THE LD CI T(A). IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOWE D FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 01/06/2018. SD/- SD/- FOT; IKWY JKO FOE FLAG ;KNO (VIJAY PAL RAO) (VIKRAM SINGH YADAV) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 01/06/2018. * GANESH KR. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SMT. KAMLA CHOUDHARY, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- ITO, WARD-3(4), JAIPUR ITA NO. 786/JP/2017 SMT. KAMLA CHOUDHARY, JAIPUR VS. ITO, JAIPUR 10 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. 786/JP/2017} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR