SMT. HARJYOTNA KAUR, Jaipur V. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, Jaipur

ITA 919/JPR/2018

• Counselvise Citation: [2018] 119 COUNSELVISE.COM (IT) 0568 (ITAT-JAIPUR)
• Duration Of Justice: 4 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-11-2018
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2009-2010
• Appeal Filed On: 30-07-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: J C KULHARI
• Keywords: Unexplained investment
• Section: 143(3); 27

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE A 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. 919/JP/2018 FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2009-10 SMT. HARJYOTNA KAUR B-68, YASH PATH, TILAK NAGAR, JAIPUR CUKE VS. DCIT CENTRAL CIRCLE-2 JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: BMXPK8022L VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RES PONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI P. C. PARWAL (CA) JKTLO DH VKSJ LS @ REVENUE BY : SHRI J. C. KULHARI (JCIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 01/10/2018 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 30/11/2018 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)-4, JAIPUR DATED 01.05.2018 FOR ASSESSMENT YEAR 2009-10 WHEREIN THE ASSESSEE HAS TAKEN THE FOLLOWING GROUNDS OF APP EAL:- 1. THE LD. CIT(A) HAS ERRED ON FACTS AND IN LAW IN CONFIRMING THE LEVY OF PENALTY U/S 271AAA ON ADDITION OF RS. 3 ,78,600/- MADE ON ACCOUNT OF ALLEGED UNEXPLAINED INVESTMENT I N JEWELLERY. 2. BRIEFLY STATED, THE FACTS OF THE CASE ARE THAT S EARCH OPERATIONS WERE CONDUCTED ON 28.1.2009 IN UNIQUE GROUP OF WHIC H THE ASSESSEE IS ONE OF THE MEMBERS. NO SURRENDER WAS MADE BY THE A SSESSEE DURING THE COURSE OF SEARCH PROCEEDINGS. THE ASSESSEE FILE D HER RETURN ON ITA NO. 919/JP/2018 SMT. HARJYOTNA KAUR, JAIPUR VS. DCIT, JAIPUR 2 7.07.2010 DECLARING NIL INCOME WHICH WAS ASSESSED U /S 143(3) AT TOTAL INCOME OF RS.9,80,240/- BY MAKING ADDITION OF RS. 9 ,80,240/-/- ON ACCOUNT OF UNEXPLAINED INVESTMENT IN JEWELLERY AND PENALTY PROCEEDINGS U/S 271AAA WERE INITIATED. AGAINST THE ASSESSMENT O RDER, THE ASSESSEE FILED APPEAL BEFORE LD. CIT(A) WHO VIDE ITS ORDER, DT. 07.11.2014 DELETED THE ADDITION ON ACCOUNT OF UNEXPLAINED JEWE LLERY BY HOLDING THAT THOUGH THE JEWELLERY TO THE EXTENT OF RS. 4,08,450/ - REMAINS UNEXPLAINED BUT THE SAME IS TO BE SET OFF AGAINST A DDITION MADE IN THE HANDS OF VIBHISHEK PAL SINGH SUBJECT TO THE RIDER T HAT IF ANY ADDITION IS DELETED IN THE HANDS OF VIBHISHEK PAL SINGH, THE AD DITION OF RS. 40,84,50/- WOULD BE CONFIRMED IN THE HANDS OF ASSES SEE. AGAINST THE ORDER OF LD. CIT(A), ASSESSEE FILED APPEAL BEFORE T HE TRIBUNAL WHO VIDE ORDER DT. 23.08.2017 IN ITA NO. 77/JP/15 CONFIRMED THE ADDITION ON ACCOUNT OF UNEXPLAINED JEWELLERY AT RS.3,78,600/- A ND THE SAME HAS THUS ATTAINED FINALITY AS FAR AS QUANTUM PROCEEDING S ARE CONCERNED. 2.1 IN THE PENALTY PROCEEDINGS DULY INITIATED DURIN G THE COURSE OF ASSESSMENT PROCEEDINGS, AFTER CONSIDERING THE ASSES SEES SUBMISSIONS AND THE ORDER OF LD. CIT(A), THE AO IMPOSED PENALTY OF RS.40,845/- U/S 271AAA, I.E. @ 10% OF THE ALLEGED UNEXPLAINED INCOM E OF RS.40,84,50/. ON APPEAL, THE LD CIT(A) HELD THAT THE ASSESSEE IS NOT ABLE TO PROVE THAT HER CASE FALLS INTO THE THREE CONDITIONS FOR THE IM MUNITY OF PENALTY U/S 271AAA AND THEREFORE, HE CONFIRMED THE LEVY OF RS.4 0,845/-. NOW, THE ASSESSEE IS IN APPEAL BEFORE US. 3. IT WAS SUBMITTED BY THE LD AR THAT THE ASSESSEE WAS MARRIED TO SH. VIBHISHEK PAL SINGH ON 26.06.2005. IN THE SEARC H CARRIED OUT AT THE RESIDENTIAL PREMISES OF ASSESSEE AND HIS FAMILY MEM BERS ON 28.01.2009, 8568.18 GMS OF GOLD JEWELLERY WAS FOUND. OUT OF THE JEWELLERY SO ITA NO. 919/JP/2018 SMT. HARJYOTNA KAUR, JAIPUR VS. DCIT, JAIPUR 3 FOUND, ASSESSEE CLAIMED 800 GMS OF JEWELLERY AS BEL ONGING TO HER. THE SOURCE OF JEWELLERY WAS EXPLAINED AS RECEIVED ON TH E OCCASION OF MARRIAGE AND ON THE BIRTH OF FIRST CHILD. THE JEWEL LERY OF 800 GMS CLAIMED BY THE ASSESSEE AS BELONGING TO HER WAS ACC EPTED BY THE AO BUT HE DID NOT ACCEPT THE SOURCE AND MADE ADDITION OF RS. 9,80,240/- BY TREATING THE ENTIRE JEWELLERY CLAIMED BY HER AS UNEXPLAINED. THE LD. CIT(A) ALLOWED BENEFIT OF 500 GMS OF JEWELLERY IN V IEW OF CBDT INSTRUCTION NO.1916 DT. 11.03.1994 AND THUS TREATED 300 GMS AS UNEXPLAINED, THEREBY REDUCING THE ADDITION TO RS. 4 0,84,50/-.THE TRIBUNAL CONFIRMED THAT 300 GMS REMAINS UNEXPLAINED BUT REDUCED THE QUANTUM OF ADDITION TO RS.37,86,00/-. 3.2 FROM THESE FACTS, IT CAN BE NOTED THAT THE ENTI RE ADDITION MADE BY THE AO AND PARTLY CONFIRMED BY THE CIT(A)/ITAT IS O N THE ASSUMPTION THAT CREDIT OF PERSONAL JEWELLERY TO THE EXTENT OF 500 GMS ONLY CAN BE ALLOWED. IT IS SUBMITTED THAT THE APPELLANT BELONGS TO A HIGHLY REPUTED GROUP OF BUILDERS. SHE WAS MARRIED ON 26.06.2005. C ONSIDERING THE FAMILY STATUS, THE CLAIM OF 800 GMS OF JEWELLERY RE CEIVED ON THE OCCASION OF MARRIAGE FROM HER PARENTS, RELATIVES AN D OTHER SOCIAL OBLIGATIONS CANNOT BE TERMED AS UNREASONABLE. THE C BDT INSTRUCTION ONLY LAYS DOWN THE MINIMUM QUANTITY OF GOLD JEWELLE RY WHICH MAY BE TREATED AS EXPLAINED. THEREFORE, CONSIDERING THE FA MILY STATUS, 800 GMS OF JEWELLERY IN HER HAND CANNOT BE CONSIDERED AS AB NORMAL. IN THIS CONNECTION, RELIANCE IS PLACED ON THE DECISION OF H ONBLE DELHI HIGH COURT IN CASE OF ASHOK CHADDHA VS. ITO 69 DTR 82 WH ERE GOLD JEWELLERY WEIGHING 906 GMS FOUND IN SEARCH WAS HELD TO BE NOT SUBSTANTIAL AS BEING STRI DHAN OF THE ASSESSEES WIFE AND ACCORDINGLY ADDITION U/S 69A WAS DELETED. AGAIN THE ITAT DELHI BENCH IN CASE OF VIBHU AGGARWAL VS. DCIT (2018) 170 ITD 580 WHERE JE WELLERY OF ITA NO. 919/JP/2018 SMT. HARJYOTNA KAUR, JAIPUR VS. DCIT, JAIPUR 4 2531.50 GMS WAS FOUND AT THE ASSESSEES RESIDENTIAL PREMISES, CONSIDERED THE SAME AS REASONABLE BY HOLDING THAT I N VIEW OF CBDT INSTRUCTION NO. 1916 DT. 11TH MAY, 1994, THE EXCESS JEWELLERY FOUND IN THE CASE OF ASSESSEE, HIS PARENTS, HIS WIFE, THEIR CHILDREN AND THE HUF WAS VERY NOMINAL AND WAS VERY MUCH REASONABLE KEEPI NG IN MIND THE RICHES AND HIGH STATUS AND MORE CUSTOMARY PRACTICES . IN THE PRESENT CASE ALSO, CONSIDERING THE FAMILY BACKGROUND OF THE ASSESSEE, 750 GMS OF JEWELLERY CLAIMED BY HER IS REASONABLE PARTICULA RLY WHEN NO EVIDENCE WAS FOUND IN SEARCH TO SUGGEST THAT ASSESSEE MADE A NY UNEXPLAINED INVESTMENT IN JEWELLERY. 3.3 FROM THE ABOVE, IT CAN BE NOTED THAT THE ADDITI ON CONFIRMED BY LD. CIT(A)/ ITAT IS ONLY ON ACCOUNT OF LOWER ESTIMA TION OF THE JEWELLERY WHICH THE ASSESSEE CLAIMED AS RECEIVED ON OCCASION OF MARRIAGE AND BIRTH OF THE CHILD. SECTION 271AAA DOES NOT LAID DO WN THAT IN EACH AND EVERY CASE WHERE THERE IS AN ADDITION TO THE INCOME , PENALTY MUST NECESSARILY BE IMPOSED. THIS IS BECAUSE SECTION 271 AAA USES THE WORD MAY. THE WORD MAY INDICATES DISCRETION OF THE A UTHORITY EITHER TO LEVY OR NOT TO LEVY A PENALTY. IN OTHER WORDS, THE IMPOSITION OF PENALTY IS NOT MANDATORY. IT WOULD DEPEND ON THE FACTS AND CIRCUMSTANCES OF EACH CASE. THE AO IS NOT OBLIGED TO LEVY THE PENALT Y IN EACH AND EVERY CASE IN A ROUTINE MANNER. HE HAS TO APPLY HIS MIND AS TO WHETHER THE FACTS AND CIRCUMSTANCES OF THE CASE JUSTIFY IMPOSIT ION OF PENALTY. DISCRETION IS TO BE EXERCISED JUDICIALLY HAVING REG ARD TO THE NATURE AND EXTENT OF BREACH AND OTHER RELEVANT CIRCUMSTANCES. THEREFORE, IT IS NOT MANDATORY TO IMPOSE THE PENALTY BUT A DISCRETION IS VESTED NOT TO IMPOSE THE PENALTY CONSIDERING THE FACTS AND CIRCUM STANCES OF THAT CASE. ITA NO. 919/JP/2018 SMT. HARJYOTNA KAUR, JAIPUR VS. DCIT, JAIPUR 5 3.4 IT MAY BE NOTED THAT THE LANGUAGE OF SECTION 27 1AAA IS SIMILAR TO THAT OF SECTION 158BFA(2). SECTION 158BFA(2) PROVID ES THAT THE ASSESSING OFFICER MAY DIRECT THAT A PERSON SHALL PAY BY WAY OF PENALTY...'. WITH REFERENCE TO THIS SECTION, VARIOU S COURTS INCLUDING THE RAJASTHAN HIGH COURT HAVE HELD THAT PENALTY UNDER T HIS SECTION IS DISCRETIONARY AND NOT MANDATORY AND RELIANCE IS PLA CED ON THE FOLLOWING DECISIONS: CIT VS. SATYENDRA KUMAR DOSI 315 ITR 172 (RAJ.) CIT VS. DR. GIRIRAJ AGARWAL GIRI (2012) 346 ITR 152 (RAJ.) CIT VS. DODSAL LTD. 312 ITR 112 (BOM.) (HC) 3.5 IN THE ABOVE BACKGROUND AND THE INTERPRETATION OF SECTION 271AAA, IT IS EVIDENT THAT ADDITION HAS BEEN MADE O N ACCOUNT OF UNEXPLAINED JEWELLERY BY ESTIMATING THE JEWELLERY R ECEIVED AS PER SOCIAL CUSTOM BY THE ASSESSEE AT A LOWER QUANTITY. THERE I S NO EVIDENCE BROUGHT ON RECORD THAT ASSESSEE PURCHASED ANY JEWEL LERY IN THE YEAR UNDER CONSIDERATION. THEREFORE, EVEN THOUGH THE ADD ITION IS SUSTAINED BY THE TRIBUNAL, THE SAME WOULD NOT AUTOMATICALLY L EAD TO A CONCLUSION THAT SUCH ADDITION REPRESENTS THE UNDISCLOSED INCOM E OF THE ASSESSEE. IN VIEW OF ABOVE, PENALTY CONFIRMED BY LD. CIT(A) B E DIRECTED TO BE DELETED. 4. THE LD DR IS HEARD WHO HAS VEHEMENTLY ARGUED TH E MATTER AND TOOK US THROUGH THE FINDINGS OF THE LOWER AUTHORITI ES. 5. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. IT IS A CASE WHERE THE PROVIS IONS OF SECTION 271AAA HAVE BEEN INVOKED BY THE AO FOR THE PURPOSES OF LEV Y OF PENALTY. THE SAID PROVISIONS PROVIDES THAT THE ASSESSING OFFICER MAY DIRECT THAT WHERE ITA NO. 919/JP/2018 SMT. HARJYOTNA KAUR, JAIPUR VS. DCIT, JAIPUR 6 THE SEARCH HAS BEEN INITIATED ON OR AFTER JUNE 1, 2 007, THE ASSESSEE SHALL PAY BY WAY OF PENALTY AT THE RATE OF 10% OF T HE UNDISCLOSED INCOME OF THE SPECIFIED PREVIOUS YEAR. THEREFORE, THE ESSENTIAL CONDITION WHICH NEEDS TO BE SATISFIED BEFORE ANY PE NALTY IS LEVIED IS THAT THERE IS AN UNDISCLOSED INCOME OF THE SPECIFIED PRE VIOUS YEAR FOUND DURING THE COURSE OF SEARCH. THE UNDISCLOSED INCOM E HAS BEEN DEFINED IN THE EXPLANATION TO SECTION 271AAA TO MEAN ANY IN COME OF THE SPECIFIED PREVIOUS YEAR REPRESENTED EITHER WHOLLY O R PARTLY BY ANY MONEY, BULLION, JEWELLERY OR OTHER ARTICLE OR THING FOUND DURING THE COURSE OF SEARCH WHICH HAS NOT BEEN RECORDED ON OR BEFORE THE DATE OF SEARCH IN THE BOOKS OF ACCOUNT OR OTHER DOCUMENTS M AINTAINED IN THE NORMAL COURSE RELATING TO SUCH PREVIOUS YEAR. 6. IN THE INSTANT CASE, WE FIND THAT 8568.18 GMS OF JEWELLERY WAS FOUND DURING THE COURSE OF SEARCH OUT OF WHICH THE ASSESSEE CLAIMS 800 GMS OF JEWELLERY AS BELONGING TO HER WHICH WAS BROU GHT TO TAX BY THE ASSESSING OFFICER. THE SOURCE OF JEWELLERY SO EXPLA INED BY THE ASSESSEE AS RECEIVED ON OCCASION OF HER MARRIAGE IN THE YEAR 2005 AND ON BIRTH OF HER CHILD IN YEAR 2006 WAS HOWEVER NOT FOUND ACC EPTABLE TO THE ASSESSING OFFICER. OUT OF 800 GMS, THE JEWELLERY W ORTH 500 GMS HAS BEEN CONSIDERED AS EXPLAINED BY THE LD CIT(A) ACCEP TING THE EXPLANATION OF THE ASSESSEE REGARDING FAMILY CUSTOM S OF RECEIVING JEWELLERY ON THE OCCASION OF MARRIAGE/BIRTH OF CHIL D, AND ALSO TAKING INTO THE CONSIDERATION CBDT INSTRUCTION NO. 1916 AND THE REMAINING 300 GMS OF JEWELLERY AS UNEXPLAINED. HOWEVER, IN OUR VIEW, THE SAID FINDING OF THE LD CIT(A) CANNOT BE READ AND UNDERSTOOD TO MEAN THAT INCOME REPRESENTED BY 300 GMS OF JEWELLERY IS TO BE CONSID ERED FOR THE PURPOSES OF LEVY OF PENALTY U/S 271AAA AS WHAT HAS TO BE SEEN IS THE UNDISCLOSED INCOME OF THE SPECIFIED PREVIOUS YEAR F OUND DURING THE ITA NO. 919/JP/2018 SMT. HARJYOTNA KAUR, JAIPUR VS. DCIT, JAIPUR 7 COURSE OF SEARCH AND NOT THE FINAL OUTCOME OF THE A SSESSMENT PROCEEDINGS. WHAT HAS BEEN FOUND DURING THE COURSE OF SEARCH IS 800 GMS OF JEWELLERY BELONGING TO THE ASSESSEE, THE REFORE, THE BASIS FOR LEVY OF PENALTY IS 800 GMS AND NOT 300 GMS OF JEWEL LERY. THEREFORE, THE CONTENTION OF THE LD AR THAT WHAT HAS BEEN CONFIRME D BY THE TRIBUNAL DURING THE QUANTUM PROCEEDINGS SHOULD FORM THE BASI S FOR LEVY OF PENALTY U/S 271AAA IS NOT FOUND ACCEPTABLE. 7. HAVING SAID THAT, WE FIND THAT THERE IS NO FINDI NG RECORDED BY THE ASSESSING OFFICER BEFORE LEVY OF PENALTY THAT THE J EWELLERY SO FOUND DURING THE COURSE OF SEARCH REPRESENTS THE INCOME O F THE SPECIFIED PREVIOUS YEAR 2008-09 RELEVANT TO IMPUNGED ASSESSME NT YEAR 2009-10. A PRESUMPTION CAN BE DRAWN THAT WHERE THE JEWELLERY IS FOUND IN POSSESSION OF THE ASSESSEE, IT BELONGS TO THE ASSES SEE UNLESS PROVED OTHERWISE. A FURTHER PRESUMPTION THAT IT REPRESENT S THE INCOME OF THE ASSESSEE OF THE PREVIOUS YEAR IN WHICH IT IS FOUND IN POSSESSION OF THE ASSESSEE (DRAWN IN CONTEXT OF SECTION 69B) AND WHET HER SUCH A PRESUMPTION CAN BE APPLIED IN CONTEXT OF PENALTY PR OVISIONS UNDER SECTION 271AAA WHICH REQUIRES A STRICT INTERPRETATI ON AND THAT TOO IN ALL CASES IS A LARGER QUESTION THAT ARISES FOR CONSIDER ATION. EACH CASE NEEDS TO BE EXAMINED IN THE PECULIAR FACTS AND CIRCUMSTAN CES OF THE CASE. IN THE PRESENT CASE, WE FIND THAT THE AO HAS NOT INVOK ED THE PROVISIONS OF SECTION 69B OF THE ACT. FURTHER, THERE IS NO SURRE NDER WHICH HAS BEEN MADE BY THE ASSESSEE FOR THE IMPUNGED YEAR EITHER A T THE TIME OF SEARCH OR SUBSEQUENT DISCLOSURE WHILE FILING HER RE TURN OF INCOME, RATHER THE EXPLANATION OF THE ASSESSEE HAS BEEN THAT THE J EWELLERY HAS BEEN RECEIVED BY HER ON OCCASION OF HER MARRIAGE IN THE YEAR 1998 AND ON BIRTH OF HER FIRST CHILD IN YEAR 2003. IT MAY BE TH AT THE ASSESSEES EXPLANATION HAS NOT BEEN ACCEPTED DURING THE COURSE OF QUANTUM ITA NO. 919/JP/2018 SMT. HARJYOTNA KAUR, JAIPUR VS. DCIT, JAIPUR 8 PROCEEDINGS AND THE ADDITIONS HAVE BEEN CONFIRMED. HOWEVER, IN THE CONTEXT OF PENALTY PROVISIONS WHICH REQUIRES A STRI CT INTERPRETATION, THERE IS HEAVY BURDEN CAST ON THE REVENUE AND UNLESS THER E IS A SPECIFIC FINDING RECORDED BY THE ASSESSING OFFICER BASED ON TANGIBLE VERIFIABLE MATERIAL THAT THE JEWELLERY SO FOUND DURING THE COU RSE OF SEARCH REPRESENTS THE INCOME OF THE SPECIFIED PREVIOUS YE AR, THE ESSENTIAL CONDITION FOR INVOKING SECTION 271AAA IS NOT SATISF IED. FURTHER, THE ASSESSEE HAS REPORTED NIL INCOME AND IS NOT REQUIRE D TO MAINTAIN ANY BOOKS OF ACCOUNTS AND INFACT, THERE IS A FINDING OF THE AO IN THE ASSESSMENT ORDER THAT ASSESSEE DIDNT MAINTAIN AND FURNISH THE BALANCE SHEET OR STATEMENT OF AFFAIRS, THEREFORE, THE OTHER CONDITION REQUIRED FOR INVOKING SECTION 271AAA OF SUCH INCOME NOT BEEN REC ORDED ON OR BEFORE THE DATE OF SEARCH IN THE BOOKS OF ACCOUNT O R OTHER DOCUMENTS MAINTAINED IN THE NORMAL COURSE RELATING TO SUCH PR EVIOUS YEAR IS NOT APPLICABLE AND THUS NOT BEEN SATISFIED IN THE INSTA NT CASE. IN LIGHT OF THE SAME, THE PENALTY SO LEVIED BY THE AO U/S 271AA A IS HEREBY DIRECTED TO BE DELETED. ORDER PRONOUNCED IN THE OPEN COURT ON 30/11/20 18. 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:- 30/11/2018 * GANESH KR. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SMT. HARJYOTNA KAUR, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- DCIT, CENTRAL CIRCLE-2, 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. ITA NO. 919/JP/2018 SMT. HARJYOTNA KAUR, JAIPUR VS. DCIT, JAIPUR 9 6. XKMZ QKBZY@ GUARD FILE { ITA NO. 919/JP/2018} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR