DEEP JYOTI COMPANY, Jaipur V. DCIT, Jaipur

ITA 961/JPR/2019

• Counselvise Citation: [2019] 115 COUNSELVISE.COM (IT) 5952 (ITAT-JAIPUR)
• Duration Of Justice: 2 month(s) 11 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-09-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2015-2016
• Appeal Filed On: 15-07-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: BHANWAR SINGH
• Assessee Lawyers: S L PODDAR
• Keywords: Rejection of books of accounts
• Section: 143(3)

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,A JAIPUR JH LAANHI XKSLKBZ] U;KF;D LNL; ,OA JH FOE FLAG ;KNO] YS[KK LNL; DS LE{K BEFORE: SHRI SANDEEP GOSAIN, JM & SHRI VIKRAM SINGH YA DAV, AM VK;DJ VIHY LA- @ ITA NO. 961/JP/2019 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2015-16 M/S. DEEP JYOTI COMPANY B-219, JANTA COLONYU JAIPUR 302 004 CUKE VS. THE ACIT CIRCLE-5 JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AAAFD 7795 H VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI S.L. PODDAR, ADVOCATE JKTLO DH VKSJ LS @ REVENUE BY : SHRI BHANWAR SINGH, (JCIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 25/09/2019 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT: 26/09/2019 VKNS'K@ ORDER PER: SANDEEP GOSAIN, J.M. THE PRESENT APPEAL HAS BEEN FILED BY THE ASSESSEE A GAINST THE ORDER OF CIT(A)-2, JAIPUR DATED 20.05.2019 FOR THE A SSESSMENT YEAR 2015-16 WHEREIN THE ASSESSEE HAS RAISED FOLLOWING G ROUND. THAT THE LD. CIT(A) SUSTAINED THE ADDITION OF RS. 6,00,000/- FOR LUMPSUM DISALLOWANCE MADE BY ACIT, CIR CLE 5, JAIPUR OF RS. 10,00,000/- WITHOUT CONSIDERATION OF BOOK RESULTS, I.E. G.P. & N.P. OF THE ASSESSEE WHICH ARE MORE THAN PREVIOUS YEAR. ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 2 2.1 BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE I S A PARTNERSHIP FIRM AND HAVING INCOME FROM CIVIL CONSTRUCTION WORKS . TH E RETURN OF INCOME DECLARING INCOME AT RS.1,30,047,410/- WAS FILED BY T HE ASSESSEE ON 30-09-2015 FOR THE YEAR UNDER CONSIDERATION. SUBSEQ UENTLY, THE CASE OF THE ASSESSEE WAS SELECTED FOR SCRUTINY AND AFTER SER VING STATUTORY NOTICE AND SEEKING REPLY OF THE ASSESSEE THE ASSESSMENT O RDER U/S 143(3) OF THE ACT ON 26-12-2017 WAS PASSED BY THE AO, MAKING T HE ADDITION OF RS. 10.00 LACS. 2.2 AGGRIEVED BY THE ORDER OF THE AO, THE ASSESSEE PREFERRED FIRST APPEAL BEFORE THE LD. CIT(A) WHO AFTER CONSIDERING T HE MATERIALS AVAILABLE ON RECORDS OF BOTH THE PARTIES PARTLY ALL OWED THE APPEAL OF THE ASSESSEE BY RESTRICTING ADDITION/ DISALLOWANCE TO T HE EXTENT OF RS. 6.00 LACS. 2.3 NOW AGGRIEVED BY THE ORDER OF THE LD. CIT(A), THE ASSESSEE HAS PREFERRED AN APPEAL BEFORE US ON THE GROUND MENTION ED HEREINABOVE. 2.4 THE SOLITARY GROUND RAISED BY THE ASSESSEE RELAT ES TO CHALLENGING THE ORDER OF THE LD. CIT(A) IN SUSTAINING THE ADDITI ON OF RS. 6.00 LACS FOR LUMPSUM DISALLOWANCE MADE BY THE AO (FOR SHORT ACIT, CIRCLE 5, JAIPUR) OF RS. 10.00 LACS WITHOUT CONSIDERING THE B OOK RESULTS I.E. G.P. ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 3 AND N.P. OF THE ASSESSEE WHICH ARE MORE THAN PREVIO US YEARS. THE LD.AR APPEARING ON BEHALF OF THE ASSESSEE RELIED UPON THE FOLLOWING WRITTEN SUBMISSION FILED BY HIM BEFORE THE LD. CIT(A) WHICH ARE CONTAINED AT PARA 2.2 OF LD. CIT(A)S ORDER. 2.2 THE RELEVANT EXTRACT OF THE SUBMISSION OF T HE APPELLANT IS AS UNDER: '1. THE ASSESSEE FIRM IS THE REGISTERED FIRM AND HA VING INCOME FROM CIVIL CONSTRUCTION WORKS AND GET HIS ACCOUNTS AUDIT FROM A QUALIFIED CHARTERED ACCOUNTANT, WHO CHECKED EVERY R ECEIPTS RECEIVED BY THE ASSESSEE FIRM AND ALSO VERIFIED FRO M THE BOOKS OF ACCOUNTS PREPARED BY THE ASSESSEE FIRM. THE ASSESSE E FIRM, RECEIVED ALL THE CONTRACT RECEIPTS FROM THE GOVERNM ENT OR GOVERNMENT DEPARTMENTS OR GOVERNMENT COMPANIES. THE FIRM NOT RECEIVED ANY SINGLE PIE FROM PRIVATE CONTRACTS. THE ASSESSEE FIRM PURCHASED ALL THE MATERIAL FROM THE REGISTERED VEND ER AND MADE MAXIMUM PAYMENT THROUGH BANKING CHANNELS. AS ASSESS EE FIRM COMPLETED IT'S CIVIL CONTRACT WORK ON DIFFERENT PLA CES AND IN REMOTE AREA ALSO, ON THAT PLACE NO BANKING CHANNEL AVAILAB LE, DUE TO ?HIS . ASSESSEE PAID LABOUR CHARGES TO LABOUR IN CASH. NOW WE FURTHER SUBMIT AS UNDER:- 2. IN THIS RESPECT WE WANT TO SAY THAT THE BUSINESS OF THE ASSESSEE MAINLY CONSISTS OF CIVIL CONTRACTOR WHICH RECEIVED CONTRACTS FROM GOVT OF RAJASTHAN DEPARTMENT FOR VARIOUS PLACE S. IN THIS BUSINESS, GOVT NOT MADE PAYMENT FOR THEIR WORK IN T IME TO ASSESSEE, EVEN IN THE MONTH OF MARCH THEY SHOW PAYM ENT MADE BUT ACTUALLY RECEIVED THAT ON THE LAST DAY OF THE M ONTH OR IN THE MONTH OF APRIL IN NEXT FINANCIAL YEAR. ONGOING THRO UGH B/S OF THE ASSESSEE FIRM THE BANK BALANCE AS ON 31/03/2015 OF RS. 2,28,67,792/- OTHER THAN THIS THE GOVT DEPARTMENT A LSO DEDUCT EARNEST MONEY AND DEPOSITS FROM PAYMENT. OTHER THAN THIS THEY ALSO DEMANDED BANK GUARANTEE FOR RELEASE THE PAYMEN T AS WELL AS FOR ACCEPTANCE THE CONTRACT TENDER. IT IS ALSO CLEA R FROM THE B/S OF ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 4 THE ASSESSEE THE DEPOSITS SHOWN OF RS. 10,61,61,247 /- AND EARNEST MONEY OF 70,37,628/- I.E. TOTAL INVESTMENT MADE IN THESE OF RS. 11,31,98,875/- DUE TO THIS CREDITORS OF THE ASSESSE E IS OUTSTANDING. THE LABOUR AND SUPPLIER OF THE ASSESSEE WAS KNOWN A ND THEY WERE READY TO TAKE THE PAYMENT WHEN RECEIVED BY ASSESSEE FROM GOVT DEPARTMENT. 3. WE FURTHER SUBMIT THAT THE PAYMENT OF RS. 9,66,3 8,514/- OUTSTANDING AS ON 31/03/2015 PAID BY THE ASSESSEE I N THE NEXT ASSESSMENT YEAR. AS THE ASSESSEE FIRM COMPLETED CON TRACT WORK IN REMOTE AREAS AND INVOLVE HUGE PERSONS FOR LABOUR WORK DUE TO THIS FIRM PAID LABOUR CHARGES IN CASH. HOWEVER, FIR M MADE PROPER RECORDS FOR THIS ON SITE. 4. NOW WE NARRATE TRADING RESULT OF THE FIRM FOR LAST FOUR YEARS WHICH CLEARLY SAY THAT THE FIRM SHOWN IT'S BETTER RE SULT IN COMPARISON OF LAST YEARS. A.Y. TURNOVER GROSS PROFIT GP RATE NET PROFIT NP RATE 2012 - 13 102803571 9651100 9.38 7761130 7.54 2013 - 14 179387233 16431021 9.5 13240770 7.38 2014 - 15 307983890 26464484 8.59 22707695 7.37 2015 - 16 258056977 24184278 9.37 20955583 8.12 THE ABOVE TRADING RESULT CLEARLY SHOWS THAT ASSESSE E FIRM SHOWS IT'S BETTER RESULT AND ALSO PAID TAX ON BETTER PROFIT IN COMPARISONS OF LAST YEARS, MEANS THERE IS NO LEAKAGE OF REVENUE ON WHIC H BASIS AO MADE DISALLOWANCE OF RS. 10,00,000/- FOR LABOUR EXP ENDITURE. ON GOING THROUGH ASSESSMENT ORDER WE FOUND THAT A.O NO T DETECTED ANY DEFECT IN THE BOOKS OF THE ASSESSEE, EVEN NOT INVOK ING PROVISION OF SECTION 145(3) OF THE INCOME TAX ACT, FOR REJECTING THE BOOKS OF ACCOUNTS OF THE ASSSESSEE AND MADE LUMP SUM/ AD HOC ADDITION OF RS. 10,00,000/- FROM DISALLOWING OF LABOUR EXPENSES ON ESTIMATION WITHOUT FINDING ANY DEFECT IN THE BOOKS OF ACCOUNTS AND VOUCHER OF THE ASSESSEE. IT IS SETTLED LAW THAT THE A.O. NOT MADE ANY ADDITION ON AD-HOC OR ESTIMATE BASIS WITHOUT FINDING ANY DEFECTS IN BOOKS AND VOUCHER OF ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 5 THE ASSESSEE.IN THE ASSESSEE CASE A.O. NOT FOUND AN Y DEFECT IN THE BOOKS AND VOUCHERS OF THE ASSESSEE. IN OUR SUPPORT WE SUBMIT FOLLOWING RULINGS:- JAIPUR TRIBUNALS:- IN THE CASE OF M/S GOODWILL IMPEX LIMITED V/S DCIT APPEAL NO. ITA NO. 544/JP/2018 DATED 18/03/ 2019. ITAT KOLKATA:- CIT V/S M/S LEXICON AUTO LTD. ITA NO. 1354/KOL/2016 ITAT MUMBAI BRCINCH ITA NO 5010/MUM/2016 ACIT CIRCLE 6(3)(2)MUMBAI V/S M/S KAMANI OIL INDUSTRIES LTD M/S KAMANI OIL INDUSTRIES LTD V/S DCIT 6(3)(1) MUMB AI. DELHI TRIBUNAL :- ACIT V/S MODI RUBBER LTD ITA NO. 1952/DEL/2014 SUPREME COURT OF INDIA J.J. ENTERPRISESV/S COMMISSI ONER OF INCOME TAX NOW WE SAY THAT THE ABOVE RULINGS CLEARLY SAID THAT DISALLOWANCES ON AD HOC OR LUMP SUM BASIS NOT ALLOWED AS DONE IN THE ASSESSEE FIRM: CASE. WE PRAY TO YOUR HONOUR GOOD SELVES KINDLY ALLOWED TH E APPEAL AND DELETE THE ADDITION MADE BY A.0.' IT WAS SUBMITTED BY THE LD.AR OF THE ASSESSEE DURIN G THE COURSE OF HEARING THAT ALTHOUGH LD. CIT(A) HAD ADMITTED THAT THE ASSESSEE HAD FILED GP CHART AND NP CHART WHICH SHOWS THAT PROFIT R ATE IS BETTER IN COMPARISON TO LAST YEAR YET HE HAD RESTRICTED THE D ISALLOWANCE TO THE EXTENT OF RS. 6.00 LACS WHICH IS NOT SUSTAINABLE IN LAW. THE LD.AR OF THE ASSESSEE RELIED ON THE DECISION OF ITAT JAIPUR BENC H IN THE CASE OF ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 6 GOODWILL IMPEX LIMITED VS DCIT (ITA NO.544/JP/2018 DA TED 18-03- 2019). 2.5 ON THE OTHER HAND, THE LD. DR RELIED ON THE ORD ERS OF THE REVENUE AUTHORITIES. 2.6 WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. WE NOTICED THAT AS PER FACTS O F THE PRESENT CASE THE ASSESSEE HAD SHOWN SUNDRY CREDITORS TO THE TUNE OF R S. 10,22,847/- AND ON VERIFICATION BY THE AO IT WAS FOUND THAT SINCE TH E ASSESSEE COULD NOT PRODUCE THE PARTIES BEFORE HIM, THEREFORE, IN ORDER TO PROTECT PROBABLE LEAKAGE OF REVENUE, THE AO MADE DISALLOWANCE OF RS. 10.00 LACS OUT OF LABOUR EXPENSES. WE HAVE ALSO CONSIDERED THE WRITTEN SUBMISSION FILED BY THE ASSESSEE BEFORE THE LD. CIT(A). IN THAT WRITTE N SUBMISSION AND THE ARGUMENTS BEFORE US, IT WAS THE SPECIFIC STAND O F THE ASSESSEE THAT ASSESSEE FIRM COMPLETED ITS CIVIL CONSTRUCTION WORKS AT DIFFERENT PLACES IN REMOTE AREAS WHERE NO BANKING CHANNEL WAS AVAILAB LE. THEREFORE, DUE TO THAT FACT, THE ASSESSEE HAD PAID LABOUR CHA RGES TO LABOURERS IN CASH. THE ASSESSEE HAD ALSO SUBMITTED THE COMPARATI VE CHART OF LAST YEAR IN ORDER TO SHOW THAT RESULTS OF GP/NP RATES WER E BETTER AND THE SAID CHART IS ALSO CONTAINED IN THE SAID WRITTEN SUB MISSION BEFORE THE LD. ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 7 CIT(A). AFTER PERUSAL OF THE RESULT CHART, WE ALSO NO TICED THAT THE ASSESSEE FIRM HAD SHOWN BETTER RESULTS AND IT HAD AL SO PAID TAXES ON BETTER PROFIT IN COMPARISON TO LAST YEAR WHICH SHOWS THAT THERE WAS NO LEAKAGE OF REVENUE. IT IS PERTINENT TO MENTION THAT LD. CIT(A) IN HER FINDINGS HAD ADMITTED THAT THE ASSESSEE FILED THE C HART OF NP/GP WHICH SHOWS THAT PROFIT RATE WAS BETTER IN COMPARISON TO LA ST YEAR AND THUS THE NPR DECLARED BY THE ASSESSEE WAS BETTER AS COMPA RED TO EARLIER YEARS. WE HAVE ALSO CONSIDERED THE DECISION OF ITAT JAIPUR BENCH IN THE CASE OF GOODWILL IMPEX LTD VS DCIT (SUPRA) AND ITS OP ERATIVE PORTION IS REPRODUCED AS UNDER:- 5. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSE D THE MATERIAL AVAILABLE ON RECORD. THE ASSESSING OFFICER HAS REJECTED THE BOOKS OF ACCOUNTS BY INVOKING THE PROV ISIONS OF SECTION 145(3) AND THE SAME HAS BEEN SUSTAINED B Y THE LD CIT(A). ONCE THE BOOKS OF ACCOUNTS ARE REJECTED, ONLY COURSE OF ACTION LEFT WITH THE ASSESSING OFFICER IS TO ASSESS THE INCOME OF THE ASSESSEE ON THE BASIS OF BEST JUD GEMENT. WHERE THE ASSESSEE HAS A SETTLED PAST HISTORY, IN S UCH CASES, ACCEPTED G.P RATE FOR THE PAST YEARS IN ASSE SSEES OWN CASE HAS BEEN HELD BY THE RAJASTHAN HIGH COURT A S PROPER AND REASONABLE BASIS FOR ESTIMATION OF G.P R ATE FOR THE CURRENT YEAR. IN THE INSTANT CASE, THE AO HAS MADE AN ADHOC TRADING ADDITION OF RS 2 LACS AND IN THE PROC ESS, HAS ESTIMATED THE G.P RATE OF 16.47% ON THE DECLARED TU RNOVER OF THE ASSESSEE AND WHICH HAS BEEN UPHELD BY THE LD CIT(A). THERE IS NO BASIS WHICH HAS BEEN SPECIFIED BY THE AO WHILE MAKING THE ADDITION OF RS 2 LACS AND WE ALSO FIND THAT THE ASSESSEES OWN PAST HISTORY HAS ALSO NOT BE ING ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 8 TAKEN INTO CONSIDERATION. ONCE THE BOOKS OF ACCOUNT S HAVE BEEN REJECTED DUE TO NON-MAINTENANCE OF STOCK REGIS TER, QUALITATIVE RECORDS, ETC AND PROVISIONS OF SECTION 145(3) HAVE BEEN INVOKED, THE AUTHORITIES CANNOT RESORT TO MAKE ADDITION ON AN ADHOC BASIS TO PREVENT LEAKAGE OF RE VENUE AS SO STATED BY THE AO. ONLY COURSE LEFT WITH THE AUTHORITIES IS TO ESTIMATE THE GROSS PROFIT RATE BA SED ON BEST JUDGEMENT AND THE PAST RESULTS OF THE ASSESSEE PROVIDES A REASONABLE BASIS FOR SUCH ESTIMATION. FO R THE YEAR UNDER CONSIDERATION, THE ASSESSEE HAS DECLARED G.P RATE OF 16.38% AS AGAINST 14.14 % IN AY 2012-13, 12 .05% IN AY 2011-12 AND 11.97% IN AY 2010-11 AND HAS THUS DECLARED A BETTER G.P RATE FOR THE YEAR UNDER CONSI DERATION AS COMPARED TO AVERAGE G.P RATE FOR THE PAST THREE YEARS. EVEN WHERE THE BOOKS OF ACCOUNTS ARE REJECTED, THERE IS THUS NO BASIS FOR MAKING THE ADDITION IN THE HANDS OF THE ASSESSEE COMPANY. IT IS A SETTLED LEGAL PROPOSITION THAT MERE REJECTION OF BOOKS OF ACCOUNTS ARE NOT SUFFICI ENT TO HOLD THAT THE TRADING ADDITIONS HAVE TO BE NECESSAR ILY MADE IN THE HANDS OF THE ASSESSEE COMPANY. WHERE THE ASSESSEE COMPANY HAS DECLARED A BETTER TRADING RESU LTS AS COMPARED TO PREVIOUS YEARS, SUCH RESULTS PROVIDE A REASONABLE BASIS TO HOLD THAT THERE SHOULD NOT BE A NY ADDITION IN THE HANDS OF THE ASSESSEE COMPANY. IN LIGHT OF ABOVE DISCUSSIONS AND IN THE ENTIRETY OF FACTS AND CIRCUMSTANCES OF THE CASES, THE TRADING ADDITION SO MADE BY THE AO AND SO CONFIRMED BY THE LD CIT(A) ARE HERE BY DIRECTED TO BE DELETED AND THE TRADING RESULTS SO D ECLARED BY THE ASSESSEE ARE DIRECTED TO BE ACCEPTED. THE IS SUE REGARDING REJECTION OF BOOKS OF ACCOUNTS SO RAISED BY THE ASSESSEE THUS BECOMES ACADEMIC AND WE DONOT DEEM IT APPROPRIATE TO ADJUDICATE THE SAME ON MERITS. AFTER HAVING GONE THROUGH THE FACTS OF THE PRESENT CASE AND ALSO THE DECISION RELIED ON BY THE LD.AR OF THE ASSESSEE (SU PRA), WE FIND THAT THE ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 9 ITAT JAIPUR BENCH IN THE CASE OF GOODWILL IMPEX LTD V S DCIT (SUPRA) HAD CATEGORICALLY HELD THAT WHERE THE ASSESSEE COMPA NY HAD DECLARED BETTER TRADING RESULTS AS COMPARED TO PREVIOUS YEAR AND SUCH RESULT PROVIDES A REASONABLE BASIS TO HOLD THAT THERE SHOU LD NOT BE ANY ADDITION IN THE HANDS OF THE ASSESSEE COMPANY. IT I S ALSO NOTED THAT THE AO HAD NOT DETECTED ANY DEFECT IN THE BOOKS OF THE ASSESSEE AND AO HAS NOT INVOKED THE PROVISIONS OF SECTION 145(3) OF THE ACT FOR REJECTING THE BOOKS OF ACCOUNT OF THE ASSESSEE BUT MADE THE L UMSUM/ ADHOC ADDITION ON ACCOUNT OF LABOUR EXPENSES ON ESTIMATIO N BASIS WITHOUT FINDING ANY DEFECTS IN THE BOOKS OF ACCOUNT AND VOU CHERS OF THE ASSESSEE. HENCE, RELYING UPON THE DECISION OF ITAT J AIPUR IN THE CASE OF GOODWILL IMPEX LTD VS DCIT (SUPRA), WE ARE OF THE VIEW THAT ONCE THE ASSESSEE COMPANY HAD DECLARED BETTER TRADING RESULT S AS COMPARED TO PREVIOUS YEAR, SUCH RESULTS PROVIDE A REASONABLE BA SIS TO HOLD THAT THERE SHOULD NOT BE ANY ADDITION IN THE HANDS OF THE ASSE SSEE COMPANY. THUS IN THE LIGHT OF THE ABOVE DISCUSSIONS AND KEEPING I N VIEW THE ENTIRETY OF THE FACTS AND CIRCUMSTANCES OF THE CASE, THE ADDITI ON SO MADE BY AO AND RESTRICTED BY LD. CIT(A) ARE DELETED. THUS THE S OLITARY GROUND OF THE ASSESSEE IS ALLOWED. ITA NO. 961/JP/2019 M/S. DEEP JYOTI COMPANY VS ACIT, CIRCLE 5, JAIPUR 10 3.0 IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS ALLOWED WITH NO ORDER AS TO COST. ORDER PRONOUNCED IN THE OPEN COURT ON 26 /09/2019 . SD/- SD/- FOE FLAG ;KNO LANHI XKSLKBZ (VIKRAM SINGH YADAV) (SANDEEP GOSAIN) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 26 /09/2019. * SANTOSH. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- M/S. DEEP JYOTI COMPANY, JAIPUR 2. IZR;FKHZ@ THE RESPONDENT-THE ACIT, CIRCLE -5, 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. 961/JP/2019} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSTT. REGISTRAR