GEETA AGARWAL, Jaipur V. DCIT, Alwar

ITA 889/JPR/2014

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 5252 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 5 month(s) 20 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-06-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: 2003-2004
• Appeal Filed On: 26-12-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: S L PODDAR
• Keywords: Unexplained cash credit; Gift; Salary income; Additional evidence
• Section: 153A; 68

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 HKKXPAN] YS[KK LNL; ,OA JH YFYR DQEKJ] U;KF;D LN L; DS LE{K BEFORE: SHRI BHAGCHAND, AM & SHRI LALIET KUMAR, JM VK;DJ VIHY LA- @ ITA NOS. 889 TO 892/JP/2014 FU/KZKJ.K O'K Z @ ASSESSMENT YEARS : 2003-04, 2004-05, 2006-07 & 2007-08 GEETA AGARWAL, 5/2, PUNJABI BAGH EXTN., CLUB ROAD, DELHI. CUKE VS. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-ALWAR. LFKK;H YS[KK LA-@THVKBZVKJ L A-@ PAN/GIR NO.: ACOPA 8344 H VIHYKFKHZ @ APPELLANT IZR;FKHZ @ RESPONDENT FU/KZKFJRH DH VKSJ LS @ ASSESSEE BY : SHRI S.L. PODDAR (ADV) JKTLO DH VKSJ LS @ REVENUE BY : SHRI M.S. MEENA (CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 14/06/2016 MN?KKS'K .KK DH RKJH[ K @ DATE OF PRONOUNCEMENT : 16/06/2016 VKNS'K @ ORDER PER BENCH ALL THESE APPEALS FILED BY THE SAME ASSESSEE AROSE AGAINST THE ORDER DATED 14/11/2014 PASSED BY THE LD CIT(A), ALWAR FOR THE A.Y. 2003-04, 2004-05, 2006-07 AND 2007-08. THE EFFECTIVE GROUNDS OF ALL THE APPEALS ARE AS UNDER:- GROUNDS OF ITA NO. 889/JP/2014 1 THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE ORDER PASSED BY THE LD ASSESSING OFFICER U/S 143(3)/153A IS VOID-AB-INITIO. ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 2 2. THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS. 3,00,000/- ON ACCOUNT OF GIFT RECEIVED BY THE ASSES SEE WITHOUT CONSIDERING THE SUBMISSION OF THE ASSESSEE. 3. THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE LD CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS . 7,00,000/- ON ACCOUNT OF UNSECURED LOAN WITHOUT CONSIDERING THE SUBMISSION OF THE ASSESSEE. GROUNDS OF ITA NO. 890/JP/2014 1 THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE ORDER PASSED BY THE LD ASSESSING OFFICER U/S 143(3)/153A IS VOID-AB-INITIO. 2. THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS. 5,51,000/- ON ACCOUNT OF GIFT RECEIVED BY THE ASSES SEE WITHOUT CONSIDERING THE SUBMISSION OF THE ASSESSEE. GROUNDS OF ITA NO. 891/JP/2014 1 THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE ORDER PASSED BY THE LD ASSESSING OFFICER U/S 143(3)/153A IS VOID-AB-INITIO. 2. THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS. 9,00,000/- U/S 68 ON ACCOUNT OF UNSECURED LOAN WITHOUT CONSIDERING THE SUBMISSION OF THE ASSESSEE. GROUNDS OF ITA NO. 892/JP/2014 1 THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE ORDER PASSED BY THE LD ASSESSING OFFICER U/S 143(3)/153A IS VOID-AB-INITIO. 2. THAT UNDER THE FACTS AND CIRCUMSTANCES OF THE CAS E, THE CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS. ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 3 4,00,000/- U/S 68 ON ACCOUNT OF UNSECURED LOAN WITHOUT CONSIDERING THE SUBMISSION OF THE ASSESSEE. 2. ALL THE APPEALS OF THE ASSESSEE ARE BEING HEARD TOGETHER, THEREFORE, FOR THE SAKE OF CONVENIENCE, COMMON ORDER IS BEING PASSED. 3. THE BRIEF FACTS OF THE CASE ARE THAT T HE ASSESSEE IS AN INDIVIDUAL AND DERIVES INCOME FROM SALARY, HOUSE PROPERTY, CAPITAL GAIN AND INCOME FROM OTHER SOURCES. IN THIS CASE ORIGINAL RETURN WAS FILE D ON 30.09.2003 DECLARING INCOME OF RS. 3,74,070/-. SUBSEQUENTLY SE ARCH WAS CONDUCTED ON 17.09.2008. NOTICE U/S 153A WAS ISSUED ON 15.04.2 009. IN RESPONSE RETURN WAS FILED ON 19.11.2010 DECLARING SAME INCOME OF RS. 3,74,070/- AS DECLARED IN THE RETURN FILED ORIGINALLY ON 30.09 .2003. THE ASSESSEE DISCLOSED THE SAME INCOME BECAUSE NO INCRIMINATING MATERIAL WAS FOUND DURING THE COURSE OF SEARCH. THE LEARNED ASSESSING O FFICER HAS COMPLETED THE ASSESSMENT U/S 153A/143(3) OF THE INCOME TAX ACT , 1961 ON 29.06.2011 DETERMINING TOTAL INCOME AT RS. 13,74,07 0/-. THEREFORE, THE LD AR MADE ADDITIONS OF RS. 3,00,000/- ON ACCOUNT OF U NEXPLAINED GIFT AND RS. 7,00,000/- ON ACCOUNT OF UNEXPLAINED LOANS. 4. THE ASSESSEE FEELING AGGRIEVED BY THE ORDER PASSE D BY THE LD ASSESSING OFFICER HAS TAKEN UP THE MATTER IN THE AP PEAL TO THE LD CIT(A). THE LD CIT (A) VIDE ORDER DATED 14/11/2014 HAS CONFIR MED THE ADDITIONS. WE WOULD LIKE TO REPRODUCE THE FINDING OF THE LD CIT( A) FOR THE PURPOSE OF ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 4 THEIR REFERENCE:- 5.4 DURING THE COURSE OF APPELLATE PROCEEDINGS, TH E APPELLANT HAS FILED ADDITIONAL EVIDENCE IN THE FORM OF COPY OF GIFT DEED, AFFIDAVIT, BANK STATEMENT, COPY OF ITR OF THE DONOR SMT. VANDANA GUPTA. THE ADDITIONAL EVIDENCE FILED BY THE APPELLANT WAS FORWARDED TO THE AO FOR COMMENTS AND EXAMINATION. THE AO HAS VIDE LETTER DATED 14-10-2013 OBJECTED TO THE FILING OF ADDITIONAL EVIDENCE UNDER RULE 46A OF THE IT RULES B Y THE APPELLANT AND HAS ALSO STATED THAT SUFFICIENT OPPORTUNITY WAS GIVEN TO THE APPELLANT IN THE COURSE OF ASSESSMENT PROCEEDINGS. THE SAME COMMENTS WERE REITERATED BY THE AO VIDE LETTER DATED 04-12-2013. 5.5 CONSIDERING THE MATERIAL AVAILABLE ON RECORD, IT IS WELL SETTLED LAW THAT IF THE ADDITIONAL EVIDENCES GOES TO THE FOOT OF THE MATTER, AND HELPS IN CLINCHING AND APPRECIATING THE CORRECT FACTS THE SAME SHOULD NORM ALLY NOT BE DENIED TO BE SUBMITTED. IT HAS BEEN UPHELD B Y VARIOUS COURTS THAT POWER OF THE FIRST APPELLATE AUTHORITY ARE CO TERMINUS TO THE POWERS OF THE ASSESSING OFFICER, AND IN SUCH PROCEEDINGS THE FIRS T APPELLATE AUTHORITY CAN CURE THE DEFICIENCIES NOTED IN THE ASSESSMENT PROCEEDINGS. I HOLD THAT IT WOULD BE FAIR, JUST AND IN THE INTEREST OF JUSTICE TO ADMIT THE SAME. ACCORDINGLY, THE ADDITIONAL EVIDENCE FILED BY THE APPELLANT IN THE COURSE OF PRESENT PROCEEDINGS IS ADMITTED UNDER RULE 46A OF THE IT RULES. ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 5 5.6 THE AO WAS ASKED VIDE THIS OFFICE LETTER NO. 166 3 DATED 23-12-2013 TO FURNISH A COMPREHENSIVE REMAND REPORT AFTER EXAMINATION ON MERITS OF THE ADDITIONA L EVIDENCE FILED. IT WAS ALSO STATED THAT THE ADDITIO NAL EVIDENCE FILED BY THE APPELLANT HAS BEEN FOUND TO B E ADMISSIBLE UNDER RULE 46A OF THE IT RULES. THE AO HOWEVER HAS FAILED TO OFFER ANY COMMENTS ON MERITS O F THE CASE. AGAIN, VIDE THIS OFFICE LETTER NO. 1917 D ATED 25-02-2014, AO WAS ASKED TO SEND THE REMAND REPORT ON MERITS OF THE CASE. AGAIN VIDE LETTER NO. 102 DA TED 10-04-2014, AO WAS REMINDED TO SEND THE REMAND REPORT. THEREAFTER, FURTHER REMINDERS WERE ALSO GIVEN TO THE AO FOR FURNISHING OF REMAND REPORT. A COPY OF T HE LETTERS WAS ALSO FORWARDED TO THE JT. CIT, CENTRAL RANGE, JAIPUR FOR ENSURING COMPLIANCE. NO SUCH REPO RT HAS BEEN RECEIVED TILL DATE. 5.7 IN VIEW OF THESE FACTS, I PROCEED TO EXAMINE TH E ADDITIONAL EVIDENCE FILED BY THE APPELLANT ON MERIT S OF THE CASE. THE APPELLANT HAS FILED A COPY OF AFFIDAVI T OF SMT. VANDANA GUPTA ALONG-WITH A DECLARATION, WHEREIN IT IS STATED THAT AN AMOUNT OF RS. 3,00,000 WAS GIVE N TO THE APPELLANT, VIDE CHEQUE NO. 52966 DATED 16-10- 2002 FOR AN AMOUNT OF RS. 3,00,000 DRAWN ON STANDARD CHARTER BANK, NEW DELHI. COPY OF THE ITR FILED BY THE DONOR FOR A.Y. 2002-03 (FOR THE PRECEDING YEAR) HAS BEEN ENCLOSED. IT IS FURTHER STATED THAT THE INCOME DECLARED BY THE DONOR IS RS. 4,45,300/-. A COPY OF THE ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 6 BANK ACCOUNT FROM WHERE THE CHEQUE WAS ISSUED BY THE DONOR HAS ALSO BEEN FILED. THE APPELLANT HAS ALSO PLACED RELIANCE ON NUMBER OF JUDGMENTS ON THIS ISSU E. 5.8 CONSIDERING ALL THESE FACTS, I FIND THAT THE F INANCIAL CAPACITY OF THE N&-- DONOR IS NOT SUCH SO AS TO MAK E A GIFT OF AN AMOUNT TO THE EXTENT OF 70% OF THE ANNUA L INCOME TO AN UN-RELATED PERSON. THE APPELLANT HAS FAILED TO PROVE THE RELATIONSHIP BETWEEN DONOR AND DONEE AND ALSO THE OCCASION ON WHICH SUCH GIFT WAS MADE. IN THE ABSENCE OF ANY SUCH MATERIAL, I HOLD T HAT THE APPELLANT HAS NOT BEEN ABLE TO DISCHARGE THE ON US WHICH LAY UPON HIM TO PROVE THE CREDITWORTHINESS OF T HE DONOR ARID GENUINENESS OF THE TRANSACTION. ACCORDIN GLY, I CONFIRM THE ADDITION OF RS. 3,00,000 MADE BY THE AO U/S 68 OF THE IT ACT. REGARDING ADDITION OF RS. 7,00,000/-, THE LD CIT(A) HAS HELD AS UNDER:- 6.3 I HAVE GONE THROUGH THE ASSESSMENT ORDER AS WELL AS SUBMISSIONS MADE BY THE APPELLANT ALONG-WITH JUDICIA L CITATIONS GIVEN THEREIN AND FIND THAT AO HAD MADE A N ADDITION OF RS. 7,00,000 ON ACCOUNT OF UNEXPLAINED CASH CREDITS. DURING THE PERIOD UNDER CONSIDERATION A LOAN OF RS. 3,00,000 HAS BEEN RECEIVED FROM SH. DIN ESH KUMAR GOYAL AND RS. 4,00,000 FROM SMT. SANGEETA GOYAL. THE ADDITION WAS MADE AS THE APPELLANT COULD NOT ESTABLISH THE IDENTITY, CREDITWORTHINESS OF THE CREDITOR AND GENUINENESS OF THE LOAN. ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 7 6.4 DURING THE COURSE OF APPELLATE PROCEEDINGS, THE APPELLANT HAS FILED ADDITIONAL EVIDENCE IN THE FORM OF CONFIRMATIONS OF THE CREDITORS. THE ADDITIONAL EVIDE NCE FILED BY THE APPELLANT WAS FORWARDED TO THE AO FOR COMMENTS AND EXAMINATION. THE AO HAS VIDE LETTER DATED 14-10-2013 OBJECTED TO THE FILING OF ADDITION AL EVIDENCE UNDER RULE 46A OF THE IT RULES BY THE APPELLANT AND HAS ALSO STATED THAT SUFFICIENT OPPOR TUNITY WAS GIVEN TO THE APPELLANT IN THE COURSE OF ASSESSME NT PROCEEDINGS FOR FILING OF EVIDENCE. 6.5 CONSIDERING THE MATERIAL AVAILABLE ON RECORD, I T IS WELL SETTLED LAW THAT IF THE ADDITIONAL EVIDENCES GOES TO THE ROOT OF THE MATTER, AND HELPS IN CLINCHING AND APPRECIATING THE CORRECT FACTS THE SAME SHOULD NORM ALLY NOT BE DENIED TO BE SUBMITTED. IT HAS BEEN UPHELD B Y VARIOUS COURTS THAT POWER OF THE FIRST APPELLATE AUTHORITY ARE CO TERMINUS TO THE POWERS OF THE ASSESSING OFFICER, AND IN SUCH PROCEEDINGS THE FIRS T APPELLATE AUTHORITY CAN CURE THE DEFICIENCIES NOTED IN THE ASSESSMENT PROCEEDINGS. I HOLD THAT IT WOULD BE FAIR, JUST AND IN THE INTEREST OF JUSTICE TO ADMIT THE SAME. ACCORDINGLY, THE ADDITIONAL EVIDENCE FILED BY THE APPELLANT IN THE COURSE OF PRESENT PROCEEDINGS IS ADMITTED UNDER RULE 46A OF THE IT RULES. 6.6 THE AO WAS ASKED VIDE THIS OFFICE LETTER NO. 1663 DATED 23-12-2013 TO FURNISH A COMPREHENSIVE REMAND REPORT AFTER EXAMINATION ON MERITS OF THE ADDITIONAL EVIDE NCE ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 8 FILED. IT WAS ALSO STATED THAT THE ADDITIONAL EVIDEN CE FILED BY THE APPELLANT HAS BEEN FOUND TO BE ADMISSI BLE UNDER RULE 46A OF THE IT RULES. THE AO HOWEVER HAS FAILED TO OFFER ANY COMMENTS ON MERITS OF THE CASE. AGAIN, VIDE THIS OFFICE LETTER NO. 1917 DATED 25-02 - 2014, AO WAS ASKED TO SEND THE REMAND REPORT ON MERITS OF THE CASE. AGAIN VIDE LETTER NO. 102 DATED 10- 04-2014, AO WAS REMINDED TO SEND THE REMAND REPORT. THEREAFTER, FURTHER REMINDERS WERE ALSO GIVEN TO THE AO FOR FURNISHING OF REMAND REPORT. A COPY OF THE LETT ERS WAS ALSO FORWARDED TO THE JT. CIT, CENTRAL RANGE, JAIPUR FOR ENSURING COMPLIANCE. NO SUCH REPORT HAS BEEN RECEIVED TILL DATE. 6.7 IN VIEW OF THESE FACTS, I PROCEED TO EXAMINE TH E ADDITIONAL EVIDENCE FILED BY THE APPELLANT ON MERIT S. THE APPELLANT HAS FILED A COPY OF CONFIRMATIONS OF T HE CREDITORS TO PRODUCE OR FURNISH ANY OTHER EVIDENCE TO PROVE THE CREDITWORTHINESS OF THE CREDITORS AND GENUINENESS OF THE TRANSACTIONS. 6.8. I HAVE CONSIDERED THE EVIDENCE FILED BY THE AP PELLANT AND FIND THAT THE APPELLANT HAS FAILED TO FILE ANY EVIDENCE IN THE FORM OF PHOTO IDENTITY OF THE CREDI TOR, NO PAN COPY, NO VOTER ID CARD ETC. FURTHER, COPY OF THE BANK ACCOUNT OF THE CREDITOR FROM WHERE THE LOAN CHEQUE WAS ISSUED WAS NOT FURNISHED IN THE COURSE OF APPELLATE PROCEEDINGS. THE LEVEL OF INCOME DECLARED BY THE CREDITORS AS STATED BY THE AO IN THE ASSESSMENT ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 9 ORDER DO NOT INDICATE THE CREDITWORTHINESS OF THE CREDITOR, SO AS TO ADVANCE A LOAN OF RS. 3 LACS/4 L ACS ON INTEREST FREE BASIS. FAILURE TO FURNISH THESE EVIDE NCE BEFORE THE AO AT THE TIME OF ASSESSMENT AND SUBSEQUENTLY EVEN IN THE COURSE OF APPELLATE PROCEEDINGS IS A LAPSE ON THE PART OF THE APPELLANT . HE RELIED ON THE VARIOUS DECISIONS AND FINALLY HE CONF IRMED THE ADDITION OF RS. 7,00,000/- MADE BY THE LD ASSES SING OFFICER U/S 68 OF THE ACT. 5. NOW THE ASSESSEE IS IN APPEALS BEFORE US. THE LD A R OF THE ASSESSEE HAS SUBMITTED THAT NO INCRIMINATING MATERIAL WAS FOU ND DURING THE COURSE OF SEARCH CONDUCTED BY THE REVENUE AND THEREFORE, T HE ASSESSING OFFICER HAS NO JURISDICTION TO MAKE ADDITION IN VIEW OF THE JUDGMENT LAID DOWN BY THE LD HONBLE DELHI HIGH COURT IN THE CASE OF CIT V S. KABUL CHAWLA (2016) 380 ITR 573 (DEL). 6. ON THE OTHER HAND, THE LD CIT DR HAS SUBMITTED TH AT THE ISSUE OF JURISDICTION HAS RAISED BY THE ASSESSEE BEFORE US, IS NOT MAINTAINABLE IN VIEW OF THE SPECIFIC FINDINGS RECORDED BY THE LD CIT( A) AT PAGE NO. 2 IN RESPONSE TO GROUND NO. 1 OF THE ASSESSEES APPEAL, WHICH IS AS UNDER:- THE GROUND NO. 1 IS NOT PRESSED BY THE AR OF THE AP PELLANT AND HENCE APPEAL FILED ON THIS GROUND IS DISMISSED. ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 10 IN REBUTTAL, THE LD DR HAS SUBMITTED THAT THIS GROU ND HAS BEEN AGITATED BY THE ASSESSEE BEFORE THE LD CIT(A), WHICH IS CLEAR FRO M THE WRITTEN SUBMISSIONS FILED BY THE ASSESSEE BEFORE THE LD CIT (A). IT WAS FURTHER SUBMITTED THAT THIS GROUND IS A LEGAL GROUND AND IT GOES TO THE ROOT OF THE MATTER, SINCE THE GROUND IS LEGAL AND IT GOES TO TH E ROOT OF THE MATER, THEREFORE IT CAN ALWAYS BE RAISED AT ANY STAGE UPTO THE HON'BLE SUPREME COURT. 7. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON THE RECORD AS WELL AS GONE THROUGH THE ORDERS PASSED BY THE AUTHORITIES BELOW. THE LD DR FOR THE RE VENUE HAS FAIRLY CONCEDED THAT THERE IS NO INCRIMINATING MATERIAL FO UND DURING THE COURSE OF SEARCH IN RESPECT TO ALL THE ASSESSMENT YEARS UN DER CONSIDERATION HOWEVER, IT WAS SUBMITTED THAT THE ADDITIONS WERE MAD E ON THE BASIS OF RETURN ALREADY FILED BY THE ASSESSEE FOR THE YEAR U NDER CONSIDERATION. IT WAS SUBMITTED THAT ON SCRUTINY OF THE RETURN AND THE DOCUMENTS FILED ALONGWITH THE RETURN, THE NEW ADDITIONS WERE MADE BY T HE AO UNDER THE IMPUGNED ORDERS. IN OUR VIEW, THE ISSUE WHETHER THE INCRIMINATING MATERIAL WAS THERE OR NOT OR FOUND DURING THE COURSE OF SEARCH, IS NO MORE REQUIRED TO BE EXAMINED IN VIEW OF THE SPECIFIC STAT EMENT GIVEN BY THE LD DR FOR THE REVENUE. HOWEVER, SINCE THE GROUND WAS NOT PRESSED BEFORE ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 11 THE LD CIT(A), IT WILL BE IN THE INTEREST OF JUSTICE TO RELEGATE THE MATTER TO THE FILE OF THE LD CIT(A) TO DECIDE THIS ISSUE AFRE SH IN VIEW OF THE JUDGMENT OF HON'BLE DELHI HIGH COURT IN THE CASE OF CIT VS. KABUL CHAWLA (2016) 380 ITR 573 (DEL), WHEREIN THE HON'BLE HIGH COURT HA S HELD THAT SINCE NO INCRIMINATING MATERIAL WAS UNEARTHED DURING THE SEAR CH, NO ADDITIONS COULD HAVE BEEN MADE TO THE INCOME ALREADY ASSESSED . IN VIEW THEREOF, ALL THE APPEALS ARE ALLOWED FOR STATISTICAL PURPOSES ONLY. SINCE WE ARE REMANDING THE APPEALS TO THE FILE OF THE LD CIT(A), IT IS EXPECTED THAT THE OBJECTIONS/APPEALS SHALL BE DECIDED BY THE LD CIT(A) EXPEDITIOUSLY. THE ASSESSEE IS ALSO DIRECTED TO RENDER ALL POSSIBLE AS SISTANCE FOR THE EARLIEST DISPOSAL OF THE APPEALS. 8. IN THE RESULT, THE ALL THE APPEALS OF THE ASSESS EES ARE ALLOWED FOR STATISTICAL PURPOSES ONLY. ORDER PRONOUNCED IN THE OPEN COURT ON 16/6/2016. SD/- SD/- HKKXPAN YFYR DQEKJ (BHAGCHAND) (LALIET KUMAR) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ @ JAIPUR FNUKAD @ DATED:- 16 TH JUNE, 2016 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- SMT. GEETA AGARWAL, DELHI. 2. IZR;FKHZ @ THE RESPONDENT- THE D.C.I.T., CENTRAL CIRCLE, ALWAR. ITA 889 TO 892/JP/2014_ GEETA AGARWAL VS DCIT 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. 889 TO 892/JP/2014) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR