ITO, Jaipur V. SMT. TARUNA BANGWAL, Jaipur

ITA 934/JPR/2012

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 87578 (ITAT-JAIPUR)
• Duration Of Justice: 2 year(s) 3 month(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-03-2015
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: A
• Assessment Year: 2009-2010
• Appeal Filed On: 20-12-2012
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: NEENA JEPH JCIT DR B
• Assessee Lawyers: PG P VIHYKFKHZ IZRFKHZ
• Keywords: Principle of natural justice; Additional evidence; Assessment record
• Section: 194C

Judgement Text

ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 1 VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR JH VKJ-IH-RKSYKUH] U;KF;D LNL; ,OA JH VH-VKJ-EHUK] YS[KK LNL; DS LE{K BEFORE: SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM VK;DJ VIHY LA-@ ITA NO. 934/JP/2012 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2009-10 THE ITO WARD- 1(2) JAIPUR CUKE VS. SMT. TARUNA GANGWAL, P/O M/S.DELUX PAPER CONVERTERS G-7,DHAMANI MARKET, CHOURA RASTA, JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: ABYPG 2646 P VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT JKTLO DH VKSJ LS@ REVENUE BY :SMT. NEENA JEPH, JCIT DR FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : NONE LQUOKBZ DH RKJH[K@ DATE OF HEARING : 23/02/2015 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 27/03/2015 VKNS'K@ ORDER PER R.P. TOLANI, JM THIS IS AN APPEAL FILED BY THE REVENUE AGAINST THE ORDER OF THE LD. CIT(A)-1, JAIPUR DATED 25-10-2012 FOR THE ASSESSME NT YEAR 2009-10 WHERE IN THE REVENUE HAS RAISED FOLLOWING GROUNDS. 1. DELETING THE ADDITION OF RS. 6,85,414/- MADE B Y THE AO ON ACCOUNT OF DISALLOWANCE OF EXPENSES. IT HAS BEEN OBSERVED THAT THE EXPENSES CLAIMED IN THE PROFIT AN D LOSS ACCOUNT DID NOT APPEAR TO BE REASONABLE SINCE THE NET PROFIT RATE ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 2 SHOWN BY THE ASSESSEE DECLINED FROM 1.09% IN THE I MMEDIATELY PRECEDING ASSESSMENT YEAR TO 0.66% DURING THIS ASSE SSMENT YEAR. THE ASSESSEE WAS ASKED TO PRODUCED BOOS/BILLS /VOUCHERS BUT HE FAILED TO DO SO BECAUSE IT WAS CLAIMED THAT THEY WERE DESTROYED IN FIRE AT THE BUSINESS PREMISES ON 3-10- 2009. THEREFORE, A BEST JUDGEMENT ASSESSMENT WAS MADE OF THE EXPENSES TO BE ALLOWED. THE AO COMPARED THE EXPENSE S IN THE PREVIOUS ASSESSMENT YEAR TO THIS ASSESSMENT YEAR AN D DISALLOWED A PROPORTIONATE AMOUNT OF EXPENSES RESUL TING IN A DISALLOWANCE OF EXPENSES CLAIMED IN THE PROFIT AND LOSS ACCOUNT OF RS. 8,19,983/-. 2. DELETING THE DISALLOWANCE OF RS. 19,48,099/- MAD E BY THE AO ON ACCOUNT OF NON-DEDUCTION OF TDS ON TH E PAYMENT OF JOB WORK, WAGES AND INTEREST TO BANK AND OTHER EXPENSES U/S 40(A)(IA). IT HAS BEEN OBSERVED THAT P AYMENT OF INTEREST TO NBFCS AND OTHER INSTITUTIONS LIKE CHOLO MANDALAM, MONEY LINK BANK, ABN AMRO BANK WAS NOT COVERED BY T HE BANKING REGULATION ACT, 1949. IT WAS FURTHER OBSERV ED THAT THE ASSESSEE HAD MADE INTEREST PAYMENT OF RS. 6,59,72/- TO NBCS WHICH DO NOT FALL IN ANY OF THE CATEGORIES OF BANKI NG COMPANY TO WHICH THE BANKING REGULATION ACT, 1949 APPLIES. THEREFORE, THE INTEREST PAYMENT TO THE EXTENT OF RS. 6,59,772/ - WAS DISALLOWED U/S 40(A)(IA) FOR VALUATION OF PROVISION OF SECTION 194A(3)(III)(A). 2.1 NONE APPEARED ON BEHALF OF THE ASSESSEE IN SPIT E OF SERVICE OF NOTICE OF THIS HEARING. CONSEQUENTLY WE ARE LEFT WITH NO A LTERNATIVE BUT TO DECIDE THE APPEAL ON MERITS, EX PARTE QUA THE ASSESSEE, AF TER HEARING LD. DR AND AFTER PERUSAL OF THE MATERIALS AVAILABLE ON RECORD. 3.1 BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE I S ENGAGED IN WHOLESALE TRADING OF PAPER AND MANUFACTURING OF EXERCISE NOTE S BOOKS ETC. ASSESSEE ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 3 FAILED TO PRODUCE PROPER RECORD AND BOOKS OF ACCOUN TS BEFORE AO CLAIMING TO BE PARTLY DESTROYED BY THE FAIR. THE FIRE DESTRU CTION THEORY WAS NOT ACCEPTED BY AO FINDING IT TO BE UNSUBSTANTIATED. DU E TO NON PRODUCTION OF BOOKS AND VOUCHERS AO RECOURSED TO BEST JUDGMENT AS SESSMENT. ASSESSEE PROPOSED THAT HIS TRADING RESULTS ARE BETTER THAN T HE EARLIER YEARS. AO HOWEVER ADOPTED THE VERIFIABILITY OF EXPENSES AND E STIMATED THEM AS ONE OF THE REASONABLE METHOD OF ESTIMATE. AO COMPARED THE ASSESSEES EXPENSES WITH ASSESSMENT YEAR 2008-09, WHICH IS GIVEN AT PAG E 3 OF THE AOS ORDER. IT WAS HELD THAT AGGREGATE OF EXPENSES AS COMPARED TO PRECEDING YEAR OF RS. 8,56,882/- HAD INCREASED TO RS. 18,13,866/- WHICH W AS NOT IN PROPORTION TO INCREASE IN BUSINESS TURNOVER I.E. FROM RS.3,44,17, 924/- TO RS. 3,99,85,626/-. ACCORDING TO AO, NO CLAIM OF DESTRUCTION OF BOOKS W AS RAISED BEFORE THE INSURANCE COMPANY AND THEREFORE, THE ASSESSEE HAD D ELIBERATELY AVOIDED THE PRODUCTION OF BOOKS OF ACCOUNT. IN VIEW THEREOF, EX PENDITURE OF RS. 8,19,983/- WAS DISALLOWED WHICH INCLUDED THE PERS ONAL ELEMENT IN USE OF CAR AND TELEPHONE. 3.2 APROPOS SECOND GROUND, THE AO FOUND THAT THE AS SESSEE HAD MADE INTEREST PAYMENT OF RS. 11,49,684/- TO THE BANKS AN D RS. 3,07,807/- NBFCS INCLUDING INTEREST TO PRIVATE PARTIES. FURTHER THE ASSESSEE HAS ALSO SHOWN VARIOUS PAYMENTS LIKE JOB WORK RS. 2,47,268/-, WAGE S RS. 13,71,715/- ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 4 THEREFORE, THERE WAS EVERY PROBABILITY OF TDS LIABI LITY ON THE PART OF THE ASSESSEE BUT THE ASSESSEE HAS AVOIDED FURNISHING TH E DETAILS. THE NOTICE WAS ISSUED TO THE ASSESSEE IN THIS BEHALF. THE AO FURTH ER OBSERVED THAT THE ASSESSEE HAD MADE CERTAIN PAYMENTS UNDER THE HEAD W AGES WHICH WERE IN THE NATURE OF CARRYING OUT CONTRACT WORK AND JOB WORK. THE ASSESSEE VIDE LETTER DATED 20-12-2011 FILED A REPLY CONTENDING THAT IMPU GNED AMOUNTS WERE NOT LIABLE FOR TDS. AFTER CONSIDERING THE REPLY AO HELD THAT PAYMENTS MADE TO NBFC, WAGES AND JOB WORK WERE LIABLE FOR TDS. ACCO RDINGLY, A SUM OF RS. 20,80,247/- ( I.E. RS. 12,28,425 + RS. 1,61,250 + R S. 6,59,772 + RS. 30,800) WAS DISALLOWED U/S 40(A)(IA) OF THE ACT. 3.3 AGGRIEVED, THE ASSESSEE PREFERRED FIRST APPEAL WHEREIN THE LD. CIT(A) HELD AS UNDER:- (I) THE INCIDENT OF FIRE WAS REPORTED TO FIRE BRIGA DE DEPTT. AND DISPUTE ABOUT INSURANCE CLAIM WAS LODGED AGAINS T UNITED INSURANCE COMPANY BEFORE THE CONSUMER COURT. (II) THE ASSESSMENT RECORD WAS CALLED FOR AND FOUND THAT THE ASSESSEE WAS GIVEN REPEATED OPPORTUNITY TO PRODUCE THE SUPPORTING BILLS AND VOUCHERS FOR VERIFICATION OF T HE ENTRIES IN THE BOOKS OF ACCOUNT. HE CONSISTENTLY FAILED TO DO SO WHEREAS DURING THE COURSE OF APPELLATE PROCEEDINGS, BILLS O F PURCHASE OF FIXED ASSETS, BILLS OF PAYMENTS TO MADHU PRINTERS W ERE SUBMITTED. IT IS NOT CLEAR HOW SENSITIVE BILLS BENE FICIAL TO THE ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 5 CASE OF THE APPELLANT WERE SAVED FROM THE FIRE. NON -PRODUCTION OF BILLS/ VOUCHERS IS THEN HELD TO BE A DELIBERATE ATTEMPT BY THE ASSESSEE TO PREVENT THE DEPARTMENT FROM PROPER SCRU TINY OF HIS ACCOUNTS. (III) THE GROSS PROFIT OF THE ASSESSEE IS 9% AS COM PARED TO 5.82% IN THE IMMEDIATELY PRECEDING ASSESSMENT YEAR. WHILE THE NET PROFIT RATE DECLINED SHARPLY TO 0.66% FROM 1.09 % IN THE PREVIOUS ASSESSMENT YEAR. NO DOUBT THIS GIVES RISE TO SUSPICION. WHEN THE AO GAVE AN OPPORTUNITY TO THE ASSESSEE TO PRODUCE THE BOOKS OF ACCOUNT ALONG WITH SUPPORTING BILLS AN D VOUCHERS HE CONSISTENTLY FAILED TO DO SO. (IV) THE LD. AR HAS SUBMITTED THE BILLS OF PURCHASE OF NEW PLANT AND MACHINERY TO JUSTIFY CLAIM OF DEPRECIATIO N ALONG WITH THE SUBMISSION THAT THE SALARY INCREASED FROM 1,84, 200/- TO RS. 3,31,967/- DURING THIS ASSESSMENT YEAR BECAUSE PEOP LE WERE NEEDED TO OPERATE THESE MACHINES. 3.4 APROPOS SECOND GROUND, THE LD. CIT(A) ON NON-DE DUCTION OF TDS ON WAGES, INTEREST, JOB WORK HELD AS UNDER:- WAGES - THERE IS NO FINDING ON RECORD BY THE AO T HAT THE PAYMENTS WERE MADE TO CONTRACTORS FOR SUPPLY OF LABOUR OR FOR CARRYING OUT OF WORK, IN FACT, HE HIMSELF HAS M ENTIONED THAT THE PAYMENTS WERE FOR WAGES. THEREFORE, PRIMA FACIE THESE PAYMENTS OF WAGES ARE NOT COVERED U/S 194C AND THER EFORE, THE DISALLOWANCE OF RS. 12,28,425/- U/S 40(A)(IA) IS DE LETED ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 6 INTEREST - I AGREE WITH THE OBSERVATION OF THE AO THAT PAYMENT OF INTEREST MADE TO THE NBFCS IS COVERED U/ S 194A(3)(III)(A) FOR PURPOSE OF DEDUCTION OF TAX. HO WEVER, ON PERUSAL OF THE RECORD AND AS PER THE FINDING OF THE AO HIMSELF ON PAGE 5 OF HIS ORDER, THE AMOUNT OF RS. 6,59,772/ - WAS PAID AS INTEREST DURING THIS YEAR. THEREFORE, THE MATTER IS COVERED BY THE JUDICIAL PRONOUNCEMENT BY THE SPECIAL BENCH IN THE CASE OF MERILYN SHIPPING & TRANSPORTS VS. ADDL. CIT , 70 DT R 81(VISAKHA) , 81 /146 TTJ (1) (SB) (VISAKA) AND FOL LOWED BY THE JAIPUR TRIBUNAL IN THE CASE OF AO VS. ANIL KUMA R SAPRA, ITA NO. 134/JP/12 DATED 22-05-2012. THEREFORE, THE DISALLOWANCE OF RS. 6,59,772/- MADE U/S 40(A)(IA) I S DELETED. JOB WORK - THUS THE SUBMISSION OF THE A.R. THAT T HE ASSESSEE HAD PAID FOR PURCHASE OF GOODS LIKE BINDIN G CLOTH FOR WHICH HE WAS NOT LIABLE TO DEDUCT TDS U 194C HAD BE EN FOUND TO BE INCORRECT FACTUALLY IN VIEW OF THE BILLS SUBM ITTED. IT IS SEEN THAT NO MATERIAL WAS PURCHASED FROM MADHU PRINTERS. PAYMENT WAS BIFURCATED FOR SETTING OF THE PLAT FOR PRINTING . THEREFORE, AS PER THE BILLS OF MADHU PRINTERS, IT IS CLEAR THAT N O MATERIAL WAS PURCHASED FROM IT BY THE ASSESSEE AND CONTRACT FOR PRINTING WAS GIVEN TO IT. THEREFORE, THE FACT OF THE CASE ARE DI FFERENT FROM THE FACTS OF THE CASES RELIED ON BY THE A.R. ON THE BAS IS OF THE EVIDENCE FURNISHED, IT IS HELD THAT A CONTRACT OF R S. 2,58,298/- WAS GIVEN BY THE ASSESSEE TO MADHU PRINTERS ON WHIC H NO TAX WAS DEDUCTED AT SOURCE AS PER PROVISIONS OF SECTION 194C. THUS AMOUNT PAYABLE ON WHICH TAX WAS NOT DEDUCTED IS REQ UIRED TO BE ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 7 DISALLOWED U/S 40(A)(IA). IN VIEW OF THE FINDINGS O F SPECIAL BENCH IN THE CASE OF MERILYN SHIPPING & TRANSPORT V S. ADDL. CIT 70 DTR 81 (VISAKHA) 81/146 TTJ (1)(SB) (VISAKHA ) AND FOLLOWED BY JAIPUR TRIBUNAL IN THE CASE OF AO VS. A NIL KUMAR SAPRA ITA NO. 134/JP/12 DATED 2-05-2012, THE AMOUN T OF DISALLOWANCE U/S 40(A)(IA) IS CONFIRMED TO RS. 1,32 ,148/- (RS. 2,58,298/- RS. 1,26,150) BEING THE AMOUNT PAYABLE T O THE PARTY AT THE END OF THE YEAR. 3.5 AGGRIEVED ON THIS RELIEF TO ASSESSEE, THE REVEN UE IS BEFORE US. 3.6 THE LD. DR CONTENDS THAT THERE IS A CLEAR CUT F INDING BY THE AO THAT NO CLAIM WAS LODGED WITH THE INSURANCE COMPANY AND REP ORT OF THE FIRE BRIGADE IS ALSO NOT MENTIONED IN THE AOS ORDER. FURTHER TH E LD. CIT(A) AT PARA 2 OF HIS ORDER HAS HELD THAT DESPITE REPEATED OPPORTUNIT IES, THE ASSESSEE DID NOT PRODUCE THE VOUCHERS OF BILLS AND BOOKS OF ACCOUNT FOR VERIFICATION WHEREAS IN THE COURSE OF APPELLATE PROCEEDINGS, THE BILLS O F PURCHASE OF FIXED ASSETS PAYMENTS AND PAYMENTS OF MADHU PRINTERS WERE PRODUC ED. FURTHER LD. CIT(A) HAS GONE TO THE EXTENT TO MENTION THAT IT IS NOT CLEAR HOW SELECTIVE BILLS FAVORABLE TO ASSESSEE WERE PRODUCED AND THERE WAS A DELIBERATE ATTEMPT BY THE ASSESSEE IN THIS BEHALF. WITH THESE OBSERVAT IONS AVAILABLE ON RECORD, THE APPEAL DID NOT DESERVED TO BE AWARDED SUBSTANTI AL RELIEF. THUS THE LD. CIT(A)S ORDER IS SELF-CONTRADICTORY BESIDES ENTERT AINING THE ADDITIONAL ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 8 EVIDENCE WITHOUT PASSING ANY ORDER UNDER RULE 46A. IN ANY CASE, IF THE LD. CIT(A) DESIRED TO ENTERTAIN ANY NEW MATERIAL BY WAY OF ANY ADDITIONAL EVIDENCE OR BASED ON ENQUIRY, A PROPER REMAND REPOR T FROM THE AO OUGHT TO HAVE BEEN CALLED THEREON. THUS RELIEF HAS BEEN ACCO RDED WITHOUT COMPLYING WITH PRINCIPLES OF NATURAL JUSTICE. 3.7 APROPOS SECOND GROUND, IT IS PLEADED REGARDING NON-DEDUCTION OF TDS THAT RELIEF GIVEN BY THE LD. CIT(A) IS WITHOUT APPR ECIATING THE FACT THAT THE ASSESSEE WAS MAKING PAYMENT FOR CONTRACT LIABLE FOR TDS U/S 194C BY MISNAMING THE HEAD AS WAGES. SIMILARLY JOB WORK WA S LIABLE FOR TDS INCLUDING PAYMENT OF INTEREST TO NBFC AND PRIVATE P ARTIES. NO COGENT REASONING HAS BEEN GIVEN BY THE LD. CIT(A) AS TO HO W THE IMPUGNED AMOUNTS HAVE BEEN HELD TO BE NOT LIABLE FOR TDS. THUS THE O RDER OF THE LD. CIT(A) SUFFERS FROM INFIRMITY, SELF CONTRADICTION AND LACK OF PROPER REASONS, THEREFORE, THE SAME MAY BE REVERSED AND THAT OF AO RESTORED. 3.8 WE HAVE HEARD THE LD. DR AND PERUSED THE MATERI ALS AVAILABLE ON RECORD. THE FACTS AS NARRATED BY THE LD. DR WHICH E MERGES FROM THE RECORD CLEARLY INDICATE THAT THE ASSESSEE CHANGED HER STAN D FROM FORUM TO FORUM IN A SELECTIVE MANNER. IT IS SURPRISING THAT ENTIRE BOOK S OF ACCOUNT ARE NOT DESTROYED BUT SELECTIVE VOUCHERS WHICH ARE IN FAVOU R OF THE ASSESSEE COULD ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 9 BE SAVED AND REST OF THEM ARE DESTROYED. FROM RECOR D AN IMPRESSION IS EMERGING THAT KNOWLEDGE ABOUT FIR COMPLAINT WITH FI RE BRIGADE DEPT AND DISPUTE IN INSURANCE CLAIM WAS GIVEN AT CIT(A) STAG E BY ASSESSEE. IT WILL BE DESIRABLE TO VERIFY THE CONTENTS CLAIMS MADE BEFORE FIRE BRIGADE AUTHORITY AND BEFORE CONSUMER COURT IN ORDER TO TEST THE BONAFIDE S OF THE ASSESSEE. IT IS TO BE ASCERTAINED AS TO HOW THE PARTIAL RECORD WITH FA VOURABLE TO THE ASSESSEE IS SAVED AND REST OF THEM ARE DESTROYED. APROPOS SECO ND REVENUES GROUND ALSO, WE FIND THAT THE NATURE OF THE PAYMENT UNDER THE HEAD WAGES HAS NOT BEEN MENTIONED AND RELIEF HAS BEEN GIVEN ON NAME WA GES ONLY. THE AO ALSO OBSERVED TO THE EFFECT THAT REAL NATURE OF THE PAYMENT IS FOR CONTRACT PAYMENTS. SIMILARLY RELIEF GIVEN IN THE TDS AND INT EREST TO NBFCS LACKS MENTIONING OF REASONS ABOUT SPECIFIC DETAILS. IT MA Y BE FURTHER MENTIONED THAT THE CASE OF MERILYN SHIPPING & TRANSPORTS VS. ADDL. CIT (SUPRA) (SPECIAL BENCH) HAS BEEN OVER RULED BY SOME OF THE HON'BLE HIGH COURTS. THUS IN THE ENTIRETY OF THE FACTS AND CIRCUMSTANCES , WE ARE OF THE VIEW THAT THE MANNER OF GIVING RELIEF IS NOT JUSTIFIABLE SINC E NEW MATERIAL HAS BEEN ENTERTAINED WITHOUT FOLLOWING THE STATUTORY PROCEDU RE AND ADHERING TO PRINCIPLES OF NATURAL JUSTICE . THUS WE SET ASIDE T HE ISSUES BACK TO THE FILE OF THE AO TO DECIDE THE SAME DENOVO AFTER GIVING REASO NABLE OPPORTUNITY OF ITA NO. 934/JP/2012 ITO , WARD- 1 (2), JAIPUR VS. SMT. TARUNA GANGWAL 10 BEING HEARD TO THE ASSESSEE AND TO CONSIDER THE ADD ITIONAL EVIDENCES OF THE ASSESSEE IN ACCORDANCE WITH LAW. 4.0 IN THE RESULT, THE APPEAL OF THE REVENUE IS A LLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 27/03/201 5. SD/- SD/- VH-VKJ-EHUK VKJ-IH-RKSYKUH (T.R. MEENA) (R.P.TOLANI) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 27 TH MARCH, 2015 *MISHRA VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- THE ITO, WARD- 1(2), JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- SMT. TARUNA GANGWAL, JAIPUR 3. VK;DJ VK;QDRVIHY ) @ CIT(A), 4. VK;DJ VK;QDR@ CIT, 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO.934/JP/2012) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR