MAYUR GLOBAL PRIVATE LIMITED , JAIPUR V. ITO WARD 1(3), JAIPUR , JAIPUR

ITA 906/JPR/2024

• Counselvise Citation: [2024] 130 COUNSELVISE.COM (IT) 5464 (ITAT-JAIPUR)
• Duration Of Justice: 1 month(s) 24 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 19-08-2024
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Next Hearing Date: 06-08-2024
• Assessment Year: 2015-2016
• Appeal Filed On: 26-06-2024
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Recovery proceedings; Depreciation; Earning of tax free income; Reasonable cause; Assessment record; Condonation of delay; CHAPTER IV
• Section: 32; 10; 154; 142(1); 14A; 143(1); 143(2); 13(2); 22

Judgement Text

vk;dj vihyh; vf/kdj.k] t;iqj U;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBkSM+ deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 906/JPR/2024 fu/kZkj.k o"kZ@Assessment Years : 2015-16 Mayur Global Private Limited B5, Vrinsavan Vihar Kings Road, Vaishali Nagar, Jaipur. cuke Vs. The ITO, Ward-1(3), Jaipur. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAICM4642B vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri S.L. Jain (Adv.) & Shri Ashok Kumar Gupta (Adv.) jktLo dh vksj ls@ Revenue by : Smt. Monisha Choudhary (Addl.CIT) lquokbZ dh rkjh[k@ Date of Hearing : 07/08/2024 mn?kks"k.kk dh rkjh[k@Date of Pronouncement : 20/08/2024 vkns'k@ ORDER PER: RATHOD KAMLESH JAYANTBHAI, AM This appeal is filed by the assessee aggrieved from the order of the Ld. CIT(A), National faceless Appeal Centre, Delhi dated 10.02.2023 for the assessment year 2015-16, which in turn arise from the order dated 12.03.2018 passed under section 154 of the Income Tax Act,1961 [Here in after referred as “Act” ] by the ITO, Ward-2(3), Jaipur. 2. The assessee has marched this appeal on the following grounds:- ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 2 “1. The impugned Order U/s 154 dated 12/03/2018 which confirmed by Ld. CIT(A) (NFAC) dated 10/02/2023 is illegal, bad in law and on the facts of the case for want of jurisdiction, barred by limitation and various other reasons (grounds), against the provisions and procedure as per law and further contrary to the real facts of the case hence liable to be quashed. 2. The Id. CIT(A) has grossly erred in law as well as on the facts of the case in confirming the action of Ld. AO whereas he did not allowed Dividend Income which is exempted u/s 10(34) of the IT act, of Rs. 7,63,417/- and Profit on sale of Shares which is exempted u/s 10(38) of the act, of Rs. 5,03,712/- but the same time made an addition of Rs. 5,44,650/- u/s 14A of the act, without considering the materials and explanations available on records in their true perspective and sense. Hence the addition so made by Ld. AO and simultaneously not allowing such exempted incomes and confirmed by the Ld. CIT (A) is being contrary to the provisions of the law and facts of the case therefore the same may kindly be deleted in toto. 3. Alternatively and without being prejudiced with above if according to the lower authorities the assessee appellant is not entitled to get the benefit of Exempted Income u/s 10(34) and 10(38) of the Act, as mentioned above, then the addition as made u/s 14A of the act is contrary to the statute because no tax can be charged on both sides and without authority of law. Hence the action of both the lower authorities are being contrary to the provisions of the law and facts of the case therefore the same may kindly be deleted in toto. 4. The ld. AO has grossly erred in law as well as on the facts of the case in charging the interest u/s 234A, B and C. The interest so charged is being totally contrary to the provision of law and on facts of the case and hence same may kindly be deleted in full. 5. That the appellant prays your honour indulgences to add, amend or alter of or any of the grounds of the appeal on or before the date of hearing.” 3.1 At the outset of hearing, the Bench observed that there is delay of 443 days in filing of the appeal by the assessee for which the assessee filed an application for condonation of delay with ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 3 following prayers and the assessee to this effect also filed an affidavit :- “1. In this connection it is submitted that the applicant is Corporate assessee/appellant. The order as passed by Ld. CIT(A) on dated 10/02/2023 was communicated on E-mail ID as mentioned in Income Tax Portal of the assessee. No Physical order has been communicated to the assessee. However as per date of order the appeal was to be filed on or before 10/04/2023 but the same is being filed on by 27/06/2024 i.e by delay of about 444 days. Although actually there is no delay if following facts are being considered. 2. Brief facts apropos to this application are as follows:- The asseessee company is subsidiary company of Mayur Leathers products Pvt. Ltd. (hereinafter referred as the holding company) and the office of both the holding company and Assessee Company is at the same premises i.e. F26A, RIICO INDUSTRIAL AREA, MANPURA MACHEDI, TEHSIL AMER, JAIPUR-303805 At the outset we submit that the staff of the holding company used to manage the administrative and business operations of the assessee company. Further we submit that the holding company availed a credit facility from CANARA BANK (hereinafter referred as the bank) and the assessee company provided corporate guarantee. Further it is pertinent to mention that both the holding and assessee company started facing financial difficulties from the financial year 2016-17 and the situation turned worse when the bank has classified the account of the holding company as Non- Performing Assets (NPA) on 28/02/2023. Thereafter, the bank issued notice u/s 13(2) of the SARFAESI Act to the holding company on 01/03/2023 and further issued notice u/s section 13(4) of the SARFAESI Act on 12/06/2023 and took possession of the mortgaged properties of the holding company and Assessee Company as well. As a result, the office premises of both the companies went into possession of the bank from the said date. And all the actions against the holding company by the bank the assesssee company which is subsidiary company also getting directly ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 4 affected. And it is noteworthy that the holding company has filed an application under Section 10 of IBC Code with NCLT Meanwhile, seeing that the company is facing financial crises and unable to pay salaries and bank accounts also become NPA, the staff of the holding company, which was also used to manage all the functions of assessee company, stopped coming to the office and left their jobs and there were no one to look after the administrative functions and the business operations of the company as the owners and upper management were busy in saving the assets of the company, which were put into the auction process by the bank. In this case it is pertinent to mention that the assessee company filed an appeal before the Ld. CIT (A) and the order to this appeal was passed on 10/02/2023 and sent to the mail id of the company i.e. [e-mail] and, neither the management of the assessee company was aware about the order nor the staff informed them. It is also apposite to mention that the aforesaid e-mail id was operated by the staff of the company only. Further it is pertinent to mention that the management of the company got aware about the impugned order dated 10/02/2023 passed by the Ld. CIT (A), when the director of the company received a call from the income tax department for recovery of tax/outstanding demand in the month of June 2024. Further we submit that both the companies are still facing harsh proceedings under SARFAESI Act and some of the assets of the companies has been auctioned and some are still on the verge of auction. Hence from the above stated factual situation it is clear that the assessee company has sufficient reasons for delay in filing instant appeal. 3. That after the director of the company received a call from the income tax department for recovery of tax/outstanding demand in the month of June 2024, the management came to know about the impugned order dated 10/02/2023 and requested their counsel to prepare this instant appeal to seek justice thereafter, the counsel prepared the appeal and filed before your Honour's on 27/06/2024. 4. Thus as the matter is unique itself therefore nobody could understand what should be done in this situation therefore there was ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 5 no negligence's of either assessee nor the counsels. Thus due to the above the appeal could not be filed within time. In support of these contention an affidavit of a director is enclosed. 5. It is submitted that the Hon'ble Supreme Court in the case of Collector, Land & Acquisition v. Mst. Katiji& Others (1987) 167 ITR 471 (SC) has advocated for a very liberal approach while considering a case for condonation of delay. The following observations of the Hon'ble Court are notable: "The legislature has conferred the power to condone delay by enacting section 5 of the Limitation Act 1963 in order to enable the Courts to do substantial justice to parties by disposing of matters on 'merits'. The expression sufficient cause' employed by the legislature is adequately elastic to enable the Courts to apply the law in a meaningful manner which subserves the ends of Justice-that being the life-purpose of the existence of the Institution of Courts. It is common knowledge that this Court has been making a justifiably liberal approach in matters instituted in this Court. But, the message does not appear to have percolated down to all the other Courts in the hierarchy." The said judgment is a leading case on the subject and has a binding force on all the officers subordinate thereto. 6. Further in the case of Vijayeta Buildcon (P.) Ltd.v.Assistant Commissioner of Income Tax, Central Circle-01, Jaipur Dated :OCTOBER 27, 2020 Hon'ble ITAT JAIPUR condone the delay of 654 days and held that:- "It has been further stated that the matter came to light of the present management on 11-7-2018 when an enquiry was made by the Assessing officer for payment of outstanding demand and thereafter, the appeal papers were prepared and appeal was submitted before the Registry on 20-8-2018 though with a delay of 654 days. We therefore find that there is no culpable negligence or malafide on the part of the assessee company in delayed filing of the present appeal and as soon as it came to know of the old tax matter pertaining to the period prior to change of the management, It took steps and filed the present appeal. Therefore, in the factual matrix of the present case, we find that there exists sufficient and reasonable cause for condoning the delay in filing the present appeal and as held by the Hon'ble Supreme Court, where substantial justice and technical considerations are pitted against each ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 6 other, the cause of substantial justice deserved to be preferred. Therefore, in exercise of powers under section 253(5) of the Act, we hereby condone the delay in filing the present appeal as we are satisfied that there was sufficient cause for not presenting the appeal within the prescribed time and the appeal is hereby admitted for adjudication on merits." 7. The action or inaction by an assessee, on the advice of its counsel, whether correct or Incorrect, if caused a delay, has been held to be reasonable and sufficient cause in these cases also. Kindly refer N. Balakrishnan v. M. Krishna Murthy(1998) 7 SCC 123 published in 30 BCAJ 922, Concord of India Insurance Co. Ltd. v. Smt. Nirmala Devi and Anothers 118 ITR 507. That it is also settled that for the mistake of the Counsel, the party cannot be suffered. Reliance on Mahaveer Prasad Jain v/s CIT, 172 ITR 331(MP), Concord India Insurance Co. Ltd v/s Smt. Nirmala Devi, 118 ITR 507(SC), Kripa Shankar v/s CIT/CWT 181 ITR 183(All), N. Balakrishnan v/s M. Krishanmurthy 7 SSC123. 8. The Hon'ble Jaipur Bench of ITAT has also condoned the delay in the case of Ganesh Himalaya Pvt.Ltd. v. ACIT 22 Tax World 415 (3p) where the filing was delayed because the son of the Managing Director had become victim of some misdeeds committed by the Holigans, particularly when on the similar points in the earlier four years, the appeals were filed in time. In the instant case also, the appeal could not be filed in time because of the above reasons and time taking a various process which were bonafide and was a sufficient cause and there was no melafide intention. 9. Recent Decision of Apex Court in a recent decision, the apex court have again reiterated that the expression "sufficient cause" should receive a liberal construction. The Hon'ble court have also held that advancing of substantial justice should be of prime importance. Kindly refer Vedbai VS. Shantaram Baburam Patil& Others 253 ITR 798 (SC). Prayer: In view of above facts and circumstance and with the sympathy and settled legal position, the delay so caused may kindly be condoned.” ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 7 In support of the contention so raised the assessee filed an affidavit support of the contention so raised in filing the appeal which is delayed by 443 days. 3.2 The ld. AR of the assessee appearing on behalf of the assessee submitted that the assessee is serious on the duties and the delay of 443 days is on account of the company was under SARFAESI Act for recovery of loans obtained from Canara Bank. The bank took possession of the company office and other premises the assessee company’s director when the recovery proceeding started came to know about the raising of the demand and therefore, there is delay in this process. If the assessee appeal is not admitted that will have to suffer irreparable loss even though the merits are in favour of the assessee. Thus, he prayed that Apex Court in the case of Collector, Land & Acquisition Vs. Mst. Katiji& Others 167 ITR 471(SC) directed the other courts to consider the liberal approach in deciding the petition for condonation as the assessee is not going to achieve any benefit for the delay in fact the assessee is at risk. ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 8 3.3 During the course of hearing, the ld. DR fairly not objected to assessee’s application for condonation of delay and prayed that Court may decide the issue as deem fit in the interest of justice. 3.4 We have heard both the parties and perused the materials available on record. The Bench Noted that the assessee for condonation of delay of 443 days has merit because of their business premises were under Bank possession and therefore, they were not in receipt of the communication and therefore, there is a delay in bringing the present appeal. The ld. DR did not controvert the facts of the recovery proceeding by bank and company went under bank possession under SARFAESI Act. Thus, the delay of 443 days in filing the appeal by the assessee is condoned in view of the decision of Hon’ble Supreme Court in the case of Collector, land Acquisition vs. Mst. Katiji and Others, 167 ITR 471 (SC) as the assessee is prevented by sufficient cause. 4. The fact as culled out from the record is that the assessee company is engaged in the business of manufacturing of leather shoes and shoes uppers in the domestic market. The return of income in this case was e-filed on 30/09/2015 declaring total income at Rs.39,88,350/- which was processed u/s 143(1) of the IT Act, 1961. The case was selected for limited scrutiny under the ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 9 CASS. Accordingly, notice u/s 143(2) issued on 26/07/2016, fixing the case for hearing on 18/08/2016. The notice was served upon the assessee through speed post. In compliance to the said notice, the ld. AR of the assessee attended. During assessment proceeding the ld. AO noted from the balance sheet of the assessee, the assessee has made investment of Rs.1,26,25,464/- and expenditure income of Rs.7,63,417/- due to dividend received and Rs. 5,03,712/- profit on sale of share also claimed. On the other hand, the assessee had debited interest expenses of Rs.22,95,858/- in its profit and loss account. There is a nexus between expenditure made and investment made by the assessee. Additionally, managerial / administrative cost of making the above investment cannot be denied. Regarding the investments made, it is evident that the assessee has made certain investments during the period under consideration to generate exempt income there from and also claimed some expenses which were shown as deductions from the taxable income of the assessee. This is against the basic principle of the taxation to pay tax on the net income i.e. gross income minus expenses to earn that income. Expenses incurred can be allowed only to the extent they are relatable to the taxable income. As per show cause notice, the ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 10 assessee was asked to explain as to why disallowance u/s 14A be not made. Assessee did not file any reply on the issue. Consequently ld. AO made addition u/s 14A of Rs.5,44,650/-. After receipt of the order the assessee preferred an application u/s. 154 of the Act stating that the view taken by the ld. AO is incorrect as the assessee has offered the dividend and profit on sale of share as income only the consequential disallowance u/s. 14A cannot be made when the assessee has not claimed any exempt income. Therefore, an application u/s. 154 of the Act was preferred by the assessee which was rejected by the ld. AO by an order dated 12.03.2018. 5. Aggrieved from the above order of the Assessing Officer the assessee preferred u/s. 154 of the Act the assessee preferred an appeal before the ld. CIT(A). After perusing the submissions of the assessee, the ld. CIT(A) has dismissed the appeal of the assessee. The relevant finding of the ld. CIT(A) is as under:- “The assessee company is engaged in the business of manufacturing of leather shoes and shoes uppers in the domestic market. The Return of income in this case was e-filed on 30/09/2015 declaring total income at Rs.39,88,350/- which was processed u/s 143(1) of the IT Act, 1961. The case was selected for limited scrutiny under the CASS. The AO disallowed Rs.5,44,649 /- u/s 14A of the I.T. Act. The assessee filed application u/s 154 before the Assessing Officer, requesting for rectification of assessment order stating that:- ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 11 "01) You had made addition of Rs.5,44,650/- as disallowance u/s 14 A of the Income Tax Act, 1961 for the Interest Expenses claimed against Exempted Incomes u/s 10(34) & 10(38). 1. We are enclosing computation of Total income for the Income Tax Return filed by the Assessee for A.Y 2015-16 in which the return is filed on Total Income including the following Exempted Incomes. 1. Dividend Income Exempt u/s 10(34). Rs.763417/- 2. Profit on Sales of Shares- LTCG Exempt u/s 10(38) Rs.503712/- The assessee had not claimed benefit of Exempted Incomes in the Income Tax Return filed for A.Y 2015-16. We are also enclosing Profit & Loss Account of Assessee which will make it clear that IT Return is filed on Total Income which includes Exempted Incomes also. 03) We are enclosing Revised Computation of Total Income after making disallowance u/s 14A of IT Act, 1961 and simultaneously claiming benefit of Exempted Incomes u/s 10(34) & 10(38) of IT Act, 1961. We request you to please appreciate the fact if disallowance u/s 14A is made then assessee is entitled to claim benefit of Exempted Incomes." The Assessing Officer while rejecting the petition u/s 154 has stated as under: "On verification of assessment record it is found that assessee has not claimed above exemption in the return of income. Assessee also not claimed the above exemptions during the course of assessment proceeding, even when show cause notice issued regarding disallowance of interest u/s 14A of I.T. Act. Hence, the assessee claim is not acceptable as the mistake not being apparent on the face of the record. However, assessee has filed a revised computation along with application u/s 154, but same is not being considered as neither the exemption claimed in return nor brought to notice during the assessment proceeding. ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 12 In view of the above facts assessee's application for rectification u/s 154 is not acceptable, being the mistake pointed out is apparent on the face of assessment records, hence rejected.” In the assessment order, the AO while making the disallowance u/s 14A has stated that As per show cause notice, the assessee was asked to explain as to why disallowance u/s 14A be not made. Assessee not filed any reply on the issue but A/R of assessee admitted on note sheet for proposed addition u/s 14A of Rs. 5,44,650/- In this case, the AO has clearly brought out in the assessment order the rationale for disallowance u/s 14A of the Act which the appellant (through it's A/R) at the time of assessment has admitted to the same. Now the appellant has taken recourse to the provision of Section 154 to state its case against the disallowance. The power of rectification u/s 154 of the Act can be exercised only if there is a mistake apparent from the record of the assessment of the assessee. In other words, in order to attract the power to rectify u/s 154, it is not sufficient, if there is merely a mistake in the order sought to be rectified. The mistake could be rectified must be the one apparent from the record. It, therefore, follows that a decision on a debatable point of law or fact or failure to apply the law to a set of facts, which remain to be investigated, cannot be corrected by way of rectification. A mistake apparent on the record must be an obvious and patent mistake and not something which can be established by a long-drawn process of reasoning on points on which there may be conceivably two opinions; a decision on a debatable point of law is not a mistake apparent from record. In this case, the AO in the assessment order has taken a view with regard to the applicability of Section 14A after bringing on records all the facts. The appellant seeks to review this decision by invoking the provision of Section 154 which is not correct. Therefore, the order of the AO rejecting the Sec 154 application is upheld. In the result, the appeal is dismissed.” ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 13 6. As the assessee did not receive any favour from the appeal so filed before ld. CIT(A). The present appeal filed against the said order of the ld. CIT(A) before this tribunal on the grounds as reiterated in para 2 above. To support this contention the ld. AR of the assessee filed the following evidence:- S. No. Particulars Page No. 1. Original Income tax return dated 30.09.2015 with computation and audited financial statements. 1-39 2. Submission before CIT(A) dated 01.09.2021 40-41 3. Application u/s 154 dated 16.11.2017 43-42 4. Rectified computation for A.Y. 2015-16 44-46 5. SCN dated 31.10.2017 47-48 6. Notice u/s 142(1) 49 6.1 The ld. AR of the assessee to drive home to the contentions so raised has also relied upon the following decisions:- S. No. Particulars Page No. 1. ACIT vs. Decent Financial Services Pvt. Ltd. Delhi HC dated 24.11.2022 in ITA No. 5707/Del/2019 1-6 2. CIT vs. Chettinad Logistics (P.)Ltd. (2018) 95 taxmann.com 250(SC) 7 3. Cheminvest Ltd. vs. CIT (2015) 61 taxmann.com 118 Delhi HC 8-13 4. Pappu Singh Rajpurohit vs. AO in IT(IT) A No. 02& 03/JP/2023 dated 17.04.2023 14-43 7. The ld. AR of the assessee submitted that when there is no income which is claimed as exempt income there cannot be any disallowance u/s. 14A of the Act and this mistake being apparent ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 14 on record is required to be rectified and the view taken by the lower authority is against the fact that the assessee has not claimed any exempt income. Thus, the mistake being apparent on record is required to be corrected as per provision of section 154 of the Act. 8. Per contra, the ld. DR supported the order of the ld. CIT(A). She also stated as there is no mistake apparent on record there is no merit in the appeal so filed by the assessee. 9. We have heard both the parties and perused the materials available on record. The appeal of discord in this case the assessing officer considered that the income so offered in the profit and loss account filed by the assessee is having dividend income and share of profit on shares. These incomes are in the nature of exempt income he computed the disallowance as per provisions of section 14A of the Act. The assessee was given show cause notice but assessee could not response the ld. AO disallowed the amount as per provision of section 14A of the Act. The assessee preferred an application u/s. 154 of the Act which was rejected on the pretext that the assessee could not brought to the contention during the assessment proceeding and consequently the ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 15 rectification application was rejected. The ld. AO on this aspect seems to be too technical when the assessee categorically submit that the income which the ld. AO considered as exempt is already taxed in the hands of the assessee. The relevant facts as is appearing on record shows as under:- “Income from business or profession (chapter IVD) 3988349 Profit as per profit and loss A/c 4407647 Add: Depreciation detailed in P & L A/c 1994725 Donation 2100 Total 6404472 Depreciation as per Chart u/s 32 2416123 2416123 3988349 Gross total income 3988349 Total Income 3988349 Round off u/s 288A 3988350/-“ ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 16 Other Non operating income: Interest on FD/Security Deposite 111,480.97 30,583.00 Interest on incometax refund 4,440.00 - Interest on Mutual Fund investment - 76,746.94 Advanced received 763,417.00 819,917.00 Accrued interest on NSC - 1.756.00 Profit on sale of shares 503,712.00 - Profit on sale of fixed assets 14,395.00 Subsidy on term loan 964,190.00 Interest on loan 135,000.00 75,082.00 ITA No. 906/JPR/2024 Mayur Global Pvt. Ltd. vs.ITO 17 2,496,634,97 1,004,084.94” As it is evident that the income so considered for disallowance u/s. 14A is already taxed in hands of the assessee therefore we see no merits in making the disallowance u/s. 14A in the hands of the assessee and therefore, the application made by the assessee u/s. 154 of the Act is required to be allowed. In the result, the appeal filed by the assessee is allowed. Order pronounced in the open Court on 20/08/2024. Sd/- Sd/- ¼ Mk0 ,l- lhrky{eh ½ ¼ jkBkSM+ deys'k t;UrHkkbZ ½ (Dr. S. Seethalakshmi) (Rathod Kamlesh Jayantbhai) U;kf;d lnL;@Judcial Member ys[kk lnL;@Accountant Member Tk;iqj@Jaipur fnukad@Dated:- 20/08/2024 *Santosh vkns'k dh izfrfyfi vxzsf’kr@Copy of the order forwarded to: 1. vihykFkhZ@The Appellant- Mayur Global Pvt. Ltd., Jaipur. 2. izR;FkhZ@ The Respondent- ITO, Ward-1(3), Jaipur. 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. 906JPR/2024} vkns'kkuqlkj@ By order lgk;d iathdkj@Asst. Registrar `