LAXMI SAINI, Jaipur V. ACIT, Alwar

ITA 820/JPR/2015

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 5283 (ITAT-JAIPUR)
• Duration Of Justice: 6 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-05-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Not Allotted
• Assessment Year: 2006-2007
• Appeal Filed On: 30-11-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: S K JAIN DCIT DHK
• Keywords: Unexplained investment; Opportunity of being heard; Initiation of penalty proceedings; Revised return
• Section: 143(3); 133A

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 DQY HKKJR] U;KF;D LNL; ,OA JH VH-VKJ-EHUK] YS[KK LNL; DS LE{K BEFORE: SHRI KUL BHARAT, JM & SHRI T.R.MEENA, AM VK;DJ VIHY LA -@ ITA NO. 820/JP/2015 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2006-07 LAXMI SAINI, F-296, INDUSTRIAL AREA, BHIWADI, ALWAR. CUKE VS. A.C.I.T., CIRCLE-2, ALWAR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO. AXPPS 6735 G VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI P.C. PARWAL (CA) JKTLO DH VKSJ LS@ REVENUE BY : SHRI S.K. JAIN (DCIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 28/04/2016. MN?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 30/05/2016. VKNS'K@ ORDER PER T.R. MEENA, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER DATED 28/09/2015 PASSED BY THE LD. CIT(A), ALWAR FOR THE AS SESSMENT YEAR 2006-07 WHEREIN THE ASSESSEE RAISED SOLE GROUND AS UNDER: 1. THE LD CIT(A) HAS ERRED ON FACTS AND IN LAW IN CONFIRMING THE PENALTY OF RS. 7,97,119/- OUT OF RS. 7,99,528/- LEVIED BY THE A.O. U/S 271(1)(C) OF THE IT ACT, 1961. ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 2 2. IN THIS CASE, ORIGINAL RETURN WAS FILED ON 12/10/ 2006 DECLARING TOTAL INCOME OF RS. 2,63,392/-. THE CASE WAS SCRUTINIZED U/ S 143(3) OF THE INCOME TAX ACT, 1961 (IN SHORT THE ACT) ON 26/12/200 8. THERE WAS A SURVEY U/S 133A OF THE ACT ON PROPRIETORY CONCERN O F THE ASSESSEE NAMELY M/S PANKAJ BOTTLE MANUFACTURING COMPANY ON 2 9/08/2007. THE LD ASSESSING OFFICER MADE ADDITION OF RS. 41,56,884/- ON ACCOUNT OF SURRENDER MADE DURING THE COURSE OF SURVEY AT RS. 2 5.00 LACS UNDER THE HEAD BUILDING AND RS. 16.00 LACS UNDER THE HEAD UNA CCOUNTED ADVANCES. THE ASSESSEE ALSO MADE CERTAIN DISCLOSURE DURING THE COURSE OF SURVEY AND THE ASSESSEES REVISED RETURN WAS FILED ON 29/1/ 2008 AT RS. 25,63,585/-. THE ASSESSEE CHALLENGED THE ADDITION M ADE BY THE ASSESSING OFFICER BEFORE THE APPELLATE AUTHORITY, WHO HAD DEL ETED THE ADDITION OF RS. 18.00 LACS AND REMAINING INCOME DISCLOSED IN TH E REVISED RETURN WAS ACCEPTED BY THE ASSESSING OFFICER HIMSELF BUT HE IM POSED THE PENALTY ON INCOME ADMITTED IN THE REVISED RETURN. IN QUANTUM P ROCEEDING, THE LD ASSESSING OFFICER INITIATED THE PENALTY PROCEEDINGS U/S 271(1)(C) OF THE ACT BY QUOTING AS PENALTY NOTICE U/S 271(1)(C) IS BEING ISSUED SEPARATELY. THE LD ASSESSING OFFICER HAS NOT SPECIF IED THE PURPOSE OF INITIATION OF PENALTY U/S 271(1)(C) OF THE ACT WHETH ER IT WAS FOR ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 3 CONCEALING THE PARTICULARS OF INCOME OR FOR FURNISH ING INACCURATE PARTICULARS OF INCOME. 2.1 BEFORE IMPOSING THE PENALTY U/S 271(1)(C), THE LD ASSESSING OFFICER GAVE REASONABLE OPPORTUNITY OF BEING HEARD, WHICH WAS AVAILED BY THE ASSESSEE VIDE LETTER DATED 07/8/2013, IT WAS SUBMITT ED AS UNDER:- THERE IS NO PARTICULARS HAVE BEEN HIDE OR CONCEALE D BY ASSESSEE, HOWEVER, THE PENALTY U/S 271(1)(C) CAN ONL Y BE INVOKED WHERE THERE IS A MATTER OF CONCEALMENT OF IN COME, WE ARE HEREWITH REFERRING DECISION OF RAJASTHAN HIGH CO URT IN CASES OF ACIT VS THAHRAYA MAL BALCHAND 124 ITR 111 IN WHICH IT IS WELL ESTABLISHED THAT ADDITION TO GROSS PROFIT AND D ISALLOWANCE OF EXPENDITURE DO NOT ATTRACT PENALTY U/S 271(1)(C). F URTHER IN CASE OF CIT VS HARSVARDHAN CHEMICALS AND MINERALS LT D., ITAT, JAIPUR DECIDED THAT WHEN THE ASSESSEE HAS CLAIMED SO ME AMOUNT THOUGH THAT IS DEBATABLE, IN SUCH CASES, IT CANNOT BE SAID THAT THE ASSESSEE HAS CONCEALED ANY INCOME OR FURNISHED INACCURATE PARTICULARS FOR EVASION OF THE TAX WHICH IS ALSO CONFIRMED BY THE HON'BLE HIGH COURT IN FAVOUR OF TH E ASSESSEE. AFTER CONSIDERING THE ASSESSEES REPLY, THE LD ASSE SSING OFFICER HELD THAT THE ASSESSEE HAD CONCEALED INCOME ON ACCOUNT OF INC OME ADMITTED DURING THE SURVEY OF RS. 7,10,486/-, INCOME ADMITTE D ON ACCOUNT OF UNACCOUNTED ADVANCES OF RS. 16.00 LACS AND FURNISHI NG INACCURATE ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 4 PARTICULARS ON ACCOUNT OF UNEXPLAINED INTRODUCTION OF CAPITAL OF RS. 49,751/-, ON ACCOUNT OF REPAIR TO PLANT AND MACHIN ERY RS. 5,722/- AND ON ACCOUNT OF STAFF WELFARE RS. 1,411/-. HE FURTHER HELD THAT ALL ADDITIONS MADE BY THE ASSESSING OFFICER HAD BEEN CONFIRMED BY THE LD CIT(A). THE CASE LAW REFERRED BY THE ASSESSEE WERE ALSO FOUND DIS TINGUISHABLE TO HIM. THEREFORE, HE IMPOSED PENALTY AT RS. 7,99,528/-, WHI CH IS 100% OF TAX SOUGHT TO BE EVADED ON CONCEALED INCOME. 3. BEING AGGRIEVED BY THE ORDER OF THE ASSESSING OF FICER, THE ASSESSEE CARRIED THE MATTER BEFORE THE LD CIT(A), WHO HAD PART LY CONFIRMED THE PENALTY BY OBSERVING THAT DURING THE COURSE OF SURV EY PROCEEDINGS, VARIOUS EVIDENCES OF UNACCOUNTED INVESTMENT MADE IN BUILDING, CAPITAL INTRODUCTION ETC. OF THE APPELLANT WAS FOUND. THESE INVESTMENTS HAD BEEN SUBSEQUENTLY DECLARED BY THE APPELLANT IN THE RETURNS OF INCOME AND WERE ALSO ASSESSED IN THE HANDS OF THE APPELLANT. THE VERY FACT THAT SUCH INVESTMENTS HAVE BEEN HELD TO BE THE ADDITIONAL INC OME OF THE APPELLANT FIRM IN THE COURSE OF QUANTUM APPEAL PROCEEDINGS PR OVES BEYOND DOUBT THAT SUCH INCOME WOULD NOT HAVE BEEN DISCLOSED IN TH E ABSENCE OF SURVEY PROCEEDINGS. THE CASE LAW RELIED BY THE ASSESSEE BEFO RE THE LD CIT(A) WERE ALSO NOT FOUND APPLICABLE PARTICULARLY DECISION OF HON'BLE SUPREME ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 5 COURT IN THE CASE OF RELIANCE PETRO PRODUCTS PVT. L TD. 322 ITR 158 (SC). THE ADDITIONAL INCOME DISCLOSED BY THE ASSESSEE DURI NG THE COURSE OF SURVEY WAS BASED ON CERTAIN EVIDENCES COLLECTED BY T HE DEPARTMENT. FURTHER HE RELIED ON THE DECISION OF HON'BLE SUPREM E COURT IN THE CASE OF MAK DATA PVT. LTD. VS CIT 358 ITR 593 (SC) WHEREIN IT HAS BEEN HELD THAT EVEN PENALTY CAN BE IMPOSED ON SURRENDER MADE DURIN G THE COURSE OF SURVEY. HE ONLY FOUND THAT DISALLOWANCE OF RS. 5,722 /- UNDER THE HEAD REPAIR EXPENSES AND RS. 1,411/- UNDER THE HEAD STAF F WELFARE WERE NOT JUSTIFIABLE. THUS, HE ALLOWED THE APPEAL PARTLY. 4. NOW THE ASSESSEE IS IN APPEAL BEFORE US. THE AR O F THE ASSESSEE HAS REITERATED THE ARGUMENTS MADE BEFORE THE LD CIT (A) AND FURTHER ARGUED THAT THE LD ASSESSING OFFICER WHILE COMPLETI NG THE ASSESSMENT ORDER, HAD MENTIONED THAT PENALTY NOTICE U/S 271(1) (C) OF THE ACT IS BEING ISSUED SEPARATELY. THERE IS NO MENTION AS TO O N WHICH ADDITION/DISALLOWANCE, PENALTY PROCEEDINGS WAS INITIA TED BY THE ASSESSING OFFICER. EVEN IT HAD NOT STATED AS TO WHETHER THE PE NALTY PROCEEDINGS WERE INITIATED FOR CONCEALMENT OF INCOME OR FOR FURN ISHING OF INACCURATE PARTICULARS OF INCOME. SIMPLY PRINTED FORM HAS BEEN ISSUED BY TICKING THE COLUMN HAVE CONCEALED THE PARTICULARS OF YOUR INCO ME OR FURNISHED ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 6 INACCURATE PARTICULARS OF SUCH INCOME. THEREFORE, O N SUCH VAGUE INITIATION OF PENALTY PROCEEDINGS, NO PENALTY CAN B E LEVIED. HE RELIED UPON THE DECISION OF HONBLE KARNATAKA HIGH COURT IN THE CASE OF CIT VS M/S MANJUNATHA COTTON & GINNING FACTORY & ORS. 359 ITR 5 65 (KAR) (HC) WHEREIN THE HON'BLE SUPREME COURT HAS HELD AS UNDER: - (G) EVEN IF THESE CONDITIONS DO NOT EXIST IN THE A SSESSMENT ORDER PASSED, AT LEAST, A DIRECTION TO INITIATE PROCEEDIN GS UNDER SECTION 271(1)(C) IS A SINE QUA NON FOR THE ASSESSI NG OFFICER TO INITIATE THE PROCEEDINGS BECAUSE OF THE DEEMING PROVISION CONTAINED IN SUB-SECTION (1B). (M) IF THE EXPLANATION OFFERED, EVEN THOUGH NOT SU BSTANTIATED BY THE ASSESSEE, BUT IS FOUND TO BE BONA FIDE AND ALL FACTS RELATING TO THE SAME AND MATERIAL TO THE COMPUTATIO N OF HIS TOTAL INCOME HAVE BEEN DISCLOSED BY HIM, NO PENALTY COULD BE IMPOSED. (N) THE DIRECTION REFERRED TO IN EXPLANATION 1(B) T O SECTION 271 OF THE ACT SHOULD BE CLEAR AND WITHOUT ANY AMBIGUITY . (O) IF THE ASSESSING OFFICER HAS NOT RECORDED ANY SATISFACTION OR HAS NOT ISSUED ANY DIRECTION TO INITIATE PENALTY PR OCEEDINGS, IN APPEAL, IF THE APPELLATE AUTHORITY RECORDS SATIS FACTION, THEN THE PENALTY PROCEEDINGS HAVE TO BE INITIATED BY THE APPELLATE AUTHORITY AND NOT THE ASSESSING AUTHORITY. ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 7 (P) NOTICE UNDER SECTION 274 OF THE ACT SHOULD SPE CIFICALLY STATE THE GROUNDS MENTIONED IN SECTION 271(1)(C), I.E., WH ETHER IT IS FOR CONCEALMENT OF INCOME OR FOR FURNISHING OF I NCORRECT PARTICULARS OF INCOME (Q) SENDING PRINTED FORM WHERE ALL THE GROUNDS MENT IONED IN SECTION 271 ARE MENTIONED WOULD NOT SATISFY THE REQU IREMENT OF LAW. (R) THE ASSESSEE SHOULD KNOW THE GROUNDS WHICH HE HAS TO MEET SPECIFICALLY. OTHERWISE, THE PRINCIPLES OF NATU RAL JUSTICE IS OFFENDED. ON THE BASIS OF SUCH PROCEEDINGS, NO P ENALTY COULD BE IMPOSED TO THE ASSESSEE. (S) TAKING UP OF PENALTY PROCEEDINGS ON ONE LIMB AN D FINDING THE ASSESSEE GUILTY OF ANOTHER LIMB IS BAD IN LAW. (T) THE PENALTY PROCEEDINGS ARE DISTINCT FROM THE A SSESSMENT PROCEEDINGS. THE PROCEEDINGS FOR IMPOSITION OF PENAL TY THOUGH EMANATE FROM PROCEEDINGS OF ASSESSMENT, IT I S INDEPENDENT AND SEPARATE ASPECT OF THE PROCEEDINGS. HE RELIED ON THE FOLLOWING CASE LAWS:- (I) CIT VS MANU ENGINEERING WORKS 122 ITR 306 (GUJ)( HC). (II) CIT VS VIRGO MARKETING PVT. LTD. 171 TAXMAN 156 (DEL)(HC). (III) RADHA MOHAN MAHESHWARI VS. DCIT (ITAT JP) ORDER DATED 18/3/2016 IN ITA NO. 769/JP/2013 FOR A.Y. 2009-10 . ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 8 ON MERIT IT IS ALSO SUBMITTED THAT DURING THE COURS E OF SURVEY, THE ASSESSEE ADMITTED RS. 40.00 LACS INCOME ON ESTIMATE D BASIS BUT WHEN BOOKS OF ACCOUNT OF EARLIER YEAR VERIFIED, IT WAS FO UND THAT THE ASSESSEE HAD NOT CONSIDERED RS. 17.28 LACS WHICH HAD BEEN ACC OUNTED FOR IN THE BOOKS OF ACCOUNT FOR THE PERIOD 01/4/2006 TO 31/3/2 007 AND UP TO 31/3/2006, IT WAS RS. 15,62,443/-. THEREFORE, THE ONL Y DIFFERENCE OF RS. 7.00 LACS WAS REMAINED TO BE EXPLAINED IN CONSTRUCTI ON ACCOUNT, WHICH HAS BEEN ADMITTED BY THE ASSESSEE BY FILING THE REV ISED RETURN. FINALLY RS. 7,10,486/- HAS BEEN ACCEPTED BY THE ASSESSING OFFIC ER. DURING THE COURSE OF SURVEY, NO INCRIMINATING DOCUMENTS WERE FOUND. THE ASSESSEE HAD ONLY ADMITTED THIS UNACCOUNTED CONSTRUCTION DURING THE COURSE OF SURVEY PROCEEDINGS, WHICH IS ON THE BASIS OF ESTIMATION AND WITHOUT ANY COGENT EVIDENCE FOUND DURING THE COURSE OF SURVEY. THE PENA LTY PROCEEDINGS AND ASSESSMENT PROCEEDINGS ARE SEPARATE. DURING THE PEN ALTY PROCEEDINGS, THE LD ASSESSING OFFICER HAD NOT BROUGHT ANY EVIDEN CE THAT THE ASSESSEE HAD CONCEALED INCOME OR FURNISHED INACCURATE PARTIC ULARS OF INCOME. HE FURTHER RELIED ON THE DECISION IN THE CASE OF CIT VS SURESH MITTAL 251 ITR 9 (SC) WHEREIN IT HAS BEEN HELD THAT THE DEPARTMENT HAS NOT DISCHARGED HIS BURDEN OF PROVING THE CONCEALMENT AND HAD SIMPL Y RESTED ITS CONCLUSION ON THE ACT OF VOLUNTARY SURRENDER DONE B Y THE ASSESSEE IN ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 9 GOOD FAITH. THE LD ASSESSING OFFICER ACCEPTED THE R EVISED RETURN, AS SUCH NO PENALTY CAN BE IMPOSED. HE FURTHER RELIED ON THE FOLLOWING CASE LAWS:- (I) ITO VS DR. V GOURISRI (2014) 40 CCH 0197 (HYD.)(TRIB) . (II) GODAVARI TOWNSHIPS PVT. LTD. VS. DCIT (2014) 103 DTR 00 01 (VISAKHAPATNAM) (TRIB). THE LD CIT(A) RELIED ON THE ORDER OF HON'BLE SUPREME COURT IN THE CASE OF MAK DATA PVT. LTD. (SUPRA) BUT THE FACTS OF THE CAS E ARE DIFFERENT AND DISTINGUISHABLE AS DURING THE COURSE OF SURVEY, SUR RENDER WAS MADE ON ACCOUNT OF DETECTION OF CERTAIN DOCUMENTS IN THE CA SE OF ASSESSEES SISTER CONCERN. WHEREAS IN ASSESSEES CASE, NO INCRIMINATI NG DOCUMENT WAS FOUND. HE FURTHER SUBMITTED THAT THERE WAS NO SURREN DER ON ACCOUNT OF ADVANCE OF RS. 16.00 LACS DURING THE SURVEY BUT THE ASSESSEE SUO MOTO GAVE THE LETTER AFTER SURVEY TO THE ASSESSING OFFIC ER THAT HE VOLUNTARILY SURRENDERED RS. 16.00 LACS ON ACCOUNT OF UNRECORDED ADVANCES. SAME INCOME HAS BEEN CONSIDERED IN REVISED INCOME BUT IT WAS ALSO WITHOUT ANY DOCUMENTARY EVIDENCE FOUND DURING THE COURSE OF SURVEY. THEREFORE, HE PRAYED TO DELETE THE PENALTY CONFIRMED BY THE LD CIT(A). 5. AT THE OUTSET, THE LD DR HAS VEHEMENTLY SUPPORTE D THE ORDER OF THE LD CIT(A). ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 10 6. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON THE RECORD. THE AS SESSEE FILED ORIGINAL RETURN ON 12/10/2006 WITHIN TIME. SURVEY U/S 133A WAS CONDUCTED BY THE DEPARTMENT ON 29/8/2007. REVISED RETURN WAS FILE D BY THE ASSESSEE ON 29/1/2008 AGAINST THE ORIGINAL RETURN OF RS. 2,6 3,392/- TO RS. 25,63,585/-, WHICH HAS BEEN ACCEPTED BY THE ASSESSIN G OFFICER. AFTER GIVING THE APPEAL EFFECT, THE INCOME ASSESSED IS EQ UAL TO THE INCOME DECLARED IN REVISED RETURN, MORE OR LESS. IT IS CON CLUDED ON THE BASIS OF PENALTY ORDER THAT NO INCRIMINATING DOCUMENTS WERE F OUND DURING THE COURSE OF SURVEY. THE ASSESSEE MADE SURRENDER ON THE BASIS OF STATEMENT RECORDED U/S 133A OF THE ACT. PARTLY IT WAS RETRACTE D ON ACCOUNT OF CONSTRUCTION AND SOME ADDITIONAL SURRENDER WAS MADE BY THE ASSESSEE THROUGH LETTER BEFORE THE ASSESSING OFFICER ON ACCO UNT OF UNRECORDED ADVANCES, WHICH HAS ALSO BEEN INCLUDED IN COMPUTATIO N OF INCOME IN REVISED RETURN. THE PENALTY IMPOSED BY THE ASSESSING OFFICER IS NOT BASED ON ANY INCRIMINATING DOCUMENTS BUT IMPOSED ON THE R EVISED RETURN FILED BY THE ASSESSEE AS THE HON'BLE SUPREME COURT IN THE CASE OF CIT VS SURESH MITTAL (SUPRA) HELD THAT THE ASSESSING OFFIC ER HAD TO BROUGHT ON RECORD THAT THE ASSESSEE HAS CONCEALED PARTICULARS OF INCOME OR FURNISHED INACCURATE PARTICULARS OF INCOME OTHERWISE PENALTY C ANNOT BE IMPOSED. ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 11 THE OTHER CASE LAWS REFERRED BY THE ASSESSEE ARE ALSO SQUARELY APPLICABLE. 6.1 THE LD ASSESSING OFFICER INITIATED THE PENALTY P ROCEEDING WITHOUT SPECIFYING THE DEFAULT OF THE ASSESSEE WHETHER IT I S FOR CONCEALMENT OF INCOME OR FURNISHING INACCURATE PARTICULARS OF INCO ME. EVEN THE PRINTED FORM, THESE SPECIFICATIONS WERE NOT MADE BY THE ASSE SSING OFFICER. AS THE HON'BLE KARNATAKA HIGH COURT DECIDED IN THE CASE OF CIT VS. M/S MANJUNATHA COTTON & GINNING FACTORY & ORS. (SUPRA) THAT NO PENALTY CAN BE IMPOSED ON NOTICES ISSUED WITHOUT SPECIFYING THE DEFAULT OF THE ASSESSEE. THEREFORE, WE DELETE THE PENALTY CONFIRMED BY THE LD CIT(A). 7. IN THE RESULT, APPEAL OF ASSESSEE IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 30/05/2016. SD/- SD/- DQYHKKJR VH-VKJ-EHUK (KUL BHARAT) (T.R. MEENA) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 30 TH MAY, 2016 RANJAN* VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- SMT. LAXMI SAINI, ALWAR. 2. IZR;FKHZ @ THE RESPONDENT- THE ACIT, CIRCLE-2 ALWAR. ITA NO. 820/JP/2015 LAXMI SAINI VS ACIT 12 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. 820/JP/2015) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR