ACIT, Jaipur V. BHIVARAM PANNALAL, Jaipur

ITA 966/JPR/2013

• Counselvise Citation: [2017] 130 COUNSELVISE.COM (IT) 5565 (ITAT-JAIPUR)
• Duration Of Justice: 3 year(s) 2 month(s) 19 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 28-02-2017
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2010-2011
• Appeal Filed On: 09-12-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: R A VERMA
• Assessee Lawyers: SITARAM SHARMA
• 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 BENCHE S, JAIPUR JH DQY HKKJR] U;KF;D LNL; ,OA JH FOE FLAG ;KNO] YS[KK LNL; DS LE{K BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YA DAV, AM VK;DJ VIHY LA- @ ITA NO. 966/JP/2013 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2010-11. ASSTT. COMMISSIONER OF INCOME-TAX, CIRCLE-6, JAIPUR. CUKE VS. M/S. BHIVARAM PANNALAL, 602, ELEMENT MALL, DCM, AJMER ROAD, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AABFB 3002 C VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT CROSS OBJECTION NO. 7/JP/2014 (ARISING OUT OF ITA NO. 966/JP/2013 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2010-11. M/S. BHIVARAM PANNALAL, 602, ELEMENT MALL, DCM, AJMER ROAD, JAIPUR. CUKE VS. ASSTT. COMMISSIONER OF INCOME-TAX, CIRCLE-6, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AABFB 3002 C VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT JKTLO DH VKSJ LS @ REVENUE BY : SHRI R.A. VERMA (ADDL. CIT) FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI SITARAM SHARMA (C.A) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 14/02/2017 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 28/02/2017 VKNS'K@ ORDER PER SHRI KUL BHARAT, J.M. THE REVENUE AND THE ASSESSEE HAVE CHALLENGED THE O RDER OF LD. CIT (APPEALS)-II, JAIPUR DATED 08.10.2013 PERTAINING TO ASSESSMENT YEAR 2010-11 BY FILING APPEAL AND CROSS OBJECTION RESPECTIVELY. BOTH THE APPEAL AND THE 2 ITA NO. 966/JP/2013 M/S. BHIVARAM PANNALAL CROSS OBJECTION ARE TAKEN UP TOGETHER AND ARE BEING DISPOSED OF BY WAY OF A COMMON ORDER, FOR THE SAKE OF CONVENIENCE. 2. FIRST, WE TAKE UP THE REVENUES APPEAL IN ITA NO . 966/JP/2013 WHEREIN THE MODIFIED GROUNDS AS TAKEN BY THE REVENUE READS AS UNDER :- 1. WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. CIT (APPEALS) WAS JUSTIFIED IN R EDUCING THE ADDITION IN CONTRACT RECEIPTS TO RS. 3,87,00,000/- (CASH RECEIPTS ONLY) AGAINST ADDITION OF RS. 9,41,35,821/- MADE BY THE AO IN THE CONTRACT RECEIPTS ON THE BASIS OF AGREEMENT AND FIN AL BILL STATEMENT FOUND DURING THE SURVEY PROCEEDINGS. 2. THE APPELLANT CRAVES ITS RIGHTS TO ADD, AMEND OR ALTER ANY OF THE GROUNDS ON OR BEFORE THE HEARING. 3. BRIEFLY STATED THE FACTS ARE THAT THE CASE OF T HE ASSESSEE WAS PICKED UP FOR SCRUTINY ASSESSMENT AND THE ASSESSMENT UNDER SE CTION 143(3) OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO AS TH E ACT) WAS FRAMED VIDE ORDER DATED 01.03.2013. WHILE FRAMING THE ASSESSME NT, THE AO NOTICED VARIOUS DEFECTS IN THE BOOKS OF ACCOUNTS AND PROCEE DED TO REJECT THE BOOK RESULT AND APPLIED THE NET PROFIT @ 10% ON THE TOTA L CONTRACT RECEIPTS OF RS. 28,51,47,718/-. THE AO MADE ADDITION INTO THE CONT RACT RECEIPTS IN RESPECT OF THE FINAL BILL SEIZED IN THE CASE OF M/S. SHIVGYAN DEVELOPERS PVT. LTD. I.E. THE DEVELOPER WHERE THE ASSESSEE HAD CARRIED OUT THE CO NSTRUCTION WORK. AGGRIEVED BY THIS, THE ASSESSEE PREFERRED AN APPEAL BEFORE LD. CIT (A), WHO AFTER CONSIDERING THE SUBMISSIONS PARTLY ALLOWED TH E APPEAL THEREBY THE LD. 3 ITA NO. 966/JP/2013 M/S. BHIVARAM PANNALAL CIT (A) CONFIRMED THE ESTIMATION OF PROFIT @ 10%. H OWEVER, HE RESTRICTED THE UNACCOUNTED CONTRACT RECEIPTS TO RS. 3,87,00,000/- AGAINST THE ACCOUNTED CONTRACT RECEIPTS OF RS. 9,41,35,821/-. AGGRIEVED BY THIS, BOTH THE REVENUE AND ASSESSEE ARE BEFORE THIS TRIBUNAL BY WAY OF APP EAL AND CROSS OBJECTION. 4. AT THE OUTSET, THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT HE DOES NOT WISH TO PRESS CROSS OBJECTION. THE LD. D/R HAS NO OBJECTION. ACCORDINGLY, THE CROSS OBJECTION NO. 7/JP/2014 OF THE ASSESSEE I S DISMISSED AS NOT PRESSED. 5. NOW WE TAKE UP REVENUES APPEAL IN ITA NO. 966/J P/2013. THE SOLITARY GROUND OF THE REVENUES APPEAL IS AGAINST REDUCING THE CONTRACT RECEIPTS FROM RS. 9,41,35,821/- TO RS. 3,87,00,000/-. THE LD. D/ R SUBMITTED THAT LD. CIT (A) WAS NOT JUSTIFIED IN REDUCING THE CONTRACT RECEIPTS . HE SUBMITTED THAT THE DISPUTE RELATES TO THE FINAL BILL RECOVERED FROM TH E PREMISES OF M/S. SHIVGYAN DEVELOPERS. HE DREW OUR ATTENTION TO PAGE 4 OF THE PAPER BOOK OF THE REVENUE WHEREIN THE FINAL BILL HAS BEEN ENCLOSED. HE SUBMITTED THAT THE ASSESSEE HAS NOT DISPUTED THE OTHER CONTENTS OF THE BILL EXCEPT THE PAYMENT MADE TOWARDS STEEL AND CEMENT. HE SUBMITTED THAT ON THE SAME BILL THERE IS A MENTION OF PAYMENT MADE BY CASH OF RS. 3,87,00,00 0/- WHICH HAS BEEN INCLUDED BY THE ASSESSEE IN ITS RETURN OF INCOME AN D THE TAXES HAVE BEEN PAID. HOWEVER, HE SUBMITTED THAT IN RESPECT OF THE PAYMENT MADE TOWARDS 4 ITA NO. 966/JP/2013 M/S. BHIVARAM PANNALAL STEEL AND CEMENT IS NOT ACCEPTED I.E. AMOUNT OF RS. 2,78,20,000/- TOWARDS STEEL AND RS. 1,62,01,000/- TOWARDS CEMENT. 5.1. ON THE CONTRARY, LD. COUNSEL FOR THE ASSESSEE OPPOSED THE SUBMISSIONS OF LD. D/R AND SUBMITTED THAT THERE IS NO DESCRIPTI ON AS TO HOW THIS PAYMENT WAS MADE TO THE ASSESSEE. HE POINTED OUT THAT THER E ARE TWO PAYMENTS ONE BY CASH AND ANOTHER BY CHEQUE. THE TOTAL AMOUN T AS PAID TO THE ASSESSEE WAS RS. 3,87,00,000/- AND RS. 3,14,53,887/ -. THE OTHER PAYMENTS WERE MADE DIRECTLY TO THE SUPPLIERS. 5.2. WE HAVE HEARD RIVAL CONTENTIONS, PERUSED THE M ATERIAL AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHORITI ES BELOW. THE ONLY ISSUE TO BE DECIDED IS WHETHER THE ASSESSEE HAS RECEIVED A SUM OF RS. 2,78,20,000/- RELATED TO STEEL AND RS. 1,62,01,000/ - RELATE TO CEMENT. FOR THE SAKE OF CLARITY, THE RELEVANT CONTENTS OF THE F INAL BILL ARE REPRODUCED AS UNDER :- DETAIL OF PAYMENT TO BHIVARAM PANNALAL AS FOLLO W : STEEL : 1070000 KGS @ 26 2,78,20,000/- CEMENT : 95300 BAGS @ 170 1,62,01,000/- CASH PAID 3,87,00,000/- PAID BY CHEQUE 3,14,53,887/- SUPPLIERS BILLS PAID 1,13,62,585/- ------------------ 12,55,37,472/- ------------------ IN THIS BACKGROUND, THE LD. CIT (A) DECIDED THE ISS UE BY OBSERVING AS UNDER :- 5 ITA NO. 966/JP/2013 M/S. BHIVARAM PANNALAL 3.3. I HAVE CONSIDERED THE FACTS OF THE CASE; A SSESSMENT ORDER AND APPELLANTS WRITTEN SUBMISSION. APPELLANT WAS CONTR ACTOR OF M/S SHIVGYAN DEVELOPERS PVT. LTD. DURING THE COURSE OF SEARCH/SURVEY TWO AGREEMENTS OF THE SAME DATE WERE FOUND. AS PER FIRS T AGREEMENT, APPELLANT WAS TO CARRY OUT CONSTRUCTION WORK WITH M ATERIAL AND AS PER SECOND AGREEMENT, APPELLANT WAS TO UNDERTAKE ONLY LABOUR WORK. APPELLANT HAS ACCOUNTED FOR LABOUR RECEIPT OF RS. 3 ,14,53,887/- FROM M/S SHIVGYAN DEVELOPERS PVT. LTD. WHEREAS A DOCUMEN T FOUND DURING SEARCH, WHICH IS ANNEXURE TO THE ASSESSMENT ORDER, INDICATED PAYMENT OF RS. 125537472/-. BASED ON THIS DOCUMENT, ASSESSI NG OFFICER INCREASED APPELLANTS TURNOVER FROM RS. 31453887/- TO RS. 125537472/- AND APPLIED 10% NET PROFIT TO IT. APPELLANT DID NO T AGREE TO THE AOS CONTENTION THAT FIRST AGREEMENT IS RELEVANT AFTER E NTERING INTO SECOND AGREEMENT FOR THE SAME CONTRACT. SINCE AO HAS TAKEN TURNOVER FIGURES FROM SEIZED PAPER ANNEXED TO ASSESSMENT ORDER, THE CONTROVERSY REGARDING APPLICABILITY OF 1 ST AGREEMENT OR 2 ND IS NOT RELEVANT. EVEN APPELLANT ALSO SUBMITTED EXPLAINING THE SEIZED DOCU MENT THAT ON THE SAME PAGE THE ENTIRE PAYMENT DETAILS TO THE ASSESSE E IS MENTIONED AND AS PER THIS PAYMENTS WERE GIVEN TO HIM BY WAY OF STEEL, CEMENT AND OTHER SUPPLIERS BILLS APART FROM CASH AND CHEQ UE PAYMENT. APPELLANT FURTHER AGREED TO INCLUDE CASH RECEIVED R S. 3,87,00,000/- AS APPEARING IN THE SEIZED PAPER AS HIS TURNOVER FOR T HE PURPOSE OF ESTIMATING PROFIT. EXCEPT THESE TWO PAYMENTS, APPEL LANT DID NOT RECEIVE ANY PAYMENT OTHER THAN SUPPLIED GIVEN BY M/S. SHIV GYAN DEVELOPERS PVT. LTD. IT IS NOT IN DISPUTE THAT APPELLANT ACTU ALLY RECEIVED FROM M/S SHIVGYAN DEVELOPERS PVT. LTD. RS. 3,87,00,000/- AND RS. 3,14,53,887/-. BALANCE AMOUNT WAS GIVEN BY WAY OF STEEL, CEMENT AN D OTHER SUPPLIERS BILLS. ASSESSING OFFICER APPLIED NET PROFIT RATE OF 10% ON THE ENTIRE AMOUNT INCLUDING PAYMENT ON ACCOUNT OF STEEL, CEMEN T AND SUPPLIERS BILLS. APPELLANT SUBMITTED THAT THERE IS NO ELEMENT OF PROFIT IN THE SUPPLY OF STEEL CEMENT ETC BY M/S SHIVGYAN DEVELOPERS PVT. LTD. THE FACT OF SUPPLY OF STEEL, CEMENT AND OTHER MATERIAL IS CLEAR LY MENTION IN THE SAME SEIZED PAPER WHICH CANNOT BE IGNORED. APPELLA NT RELIED UPON SEVERAL DECISIONS INCLUDING DECISIONS OF JURISDICT IONAL HIGH COURT IN WHICH IN THE SIMILAR FACTS, IT IS HELD THAT MATERIA L SUPPLIED BY THE PARTY CANNOT BE INCLUDED IN TURNOVER OF THE CONTRACTOR FO R ESTIMATING PROFIT. THE RELEVANT PART OF THE DECISIONS RELIED UPON BY T HE APPELLANT ARE QUOTED BELOW- 6 ITA NO. 966/JP/2013 M/S. BHIVARAM PANNALAL 1- THE SUPREME COURT WHILE DECIDING THE APPEAL IN BRIJ BHUSHAN LAL PARDUMAN KUMAR V. CIT (1978) 115 ITR 524 HELD AS U NDER: IN SUBSTANCE AND IN REALITY, SUCH STORES/MATERIA L ALWAYS REMAINS THE PROPERTY OF THE DEPARTMENT AND THE CONTRACTOR HAS M ERELY THE CUSTODY OF IT AND HE FIXES OR INCORPORATES THE SAME INTO TH E WORKS. IT SEEMS TO US CLEAR THAT IN SUCH CIRCUMSTANCES AND HAVING REGA RD TO THE TERMS AND CONDITIONS ON WHICH SUCH SUPPLY OF STORES/MATERIAL S IS MADE THERE IS NOT EVEN A THEORETICAL POSSIBILITY OF ANY ELEMENT OF PROFIT BEING INVOLVED IN THE TURNOVER REPRESENTED BY THE COST OF SUCH STORES/MATERIAL WHEN STORES/MATERIAL IS, SUPPLIED BY THE GOVERNMENT DEPARTMENT AT FIXED RATES FOR BEING SUED, FIXED OR INCORPORATED IN THE WORK ON TERMS INDICATED ABOVE, THERE WOULD BE NO EL EMENT OF PROFIT INVOLVED IN THE TURNOVER REPRESENT BY THE COST OF S UCH MATERIAL. IT IS TURN THAT, ORDINARILY, WHEN A WORKS CONTRACT IS PUT THROUGH OR COMPLETED BY A CONTRACTOR THE INCOME OR PROFITS DERIVED BY TH E CONTRACTOR FROM SUCH CONTRACT IS DETERMINED ON THE VALUE OF THE CON TRACT AS A WHOLE AND CANNOT BE DETERMINED BY CONSIDERING SEVERAL ITEMS THAT GO TO FORM SUCH VALUE OF THE CONTRACT BUT IN OUR VIEW WHERE CE RTAIN STORES/MATERIAL IS SUPPLIED AT FIXED RATES BY THE DEPARTMENT TO THE CONTRACTOR SOLELY FOR BEING USED OR FIXED OR INCORPORATED IN THE WORKS UN DERTAKEN ON TERMS AND CONDITIONS MENTIONED ABOVE, THE REAL TOTAL VALU E OF THE ENTIRE CONTRACT WOULD BE THE VALUE MINUS THE COST OF SUCH STORES/MATERIALS SO SUPPLIED. THEREFORE, SINCE NO ELEMENT OF PROFIT WAS INVOLVED IN THE TURNOVER REPRESENTED BY THE COST OF STORES/MATERIAL SUPPLIED BY THE M.E.S. TO THE ASSESSEE-FIRMS, THE INCOME OR PROFITS DERIVED BY THE ASSESSEE-FIRMS FROM SUCH CONTRACTS WILL HAVE TO BE DETERMINED ON THE BASIS OF THE VALUE OF THE CONTRACT REPRESENTED BY THE CASH PAYMENTS RECEIVED BY THE ASSESSEE-FIRMS FROM THE M.E.S. DEPA RTMENT EXCLUSIVE OF THE COST OF THE MATERIALS/ STORES RECEIVED FOR BEIN G USED, FIXED OR INCORPORATED IN THE WORKS UNDERTAKEN BY THEM. (P.5 32) 2- THE RAJASTHAN HIGH COURT IS CASE OF CIT VS RAMESHWA R DAS NARSINGH DAS & CO. ( 1985) 155 ITR 270 (RAJ). IT IS WELL SETTLED THAT THE VALUE OF THE MATERIAL S SUPPLIED BY THE GOVERNMENT DEPARTMENTS TO A CONTRACTOR FOR BEING US ED IN THE EXECUTION OF THE WORKS IS TO BE EXCLUDED WHILE DETE RMINING THE TURNOVER OF THE ASSESSEE- CONTRACTOR. ACCORDINGLY, THE COST OF MATERIALS SUPPLIED BY THE GOVERNMENT WAS NOT INCLUDIBLE IN THE GROSS R ECEIPTS FOR THE PURPOSE OF ESTIMATING THE NET INCOME OF THE ASSESSE E. 7 ITA NO. 966/JP/2013 M/S. BHIVARAM PANNALAL 3- THE RAJASTHAN HIGH COURT IN CASE OF ADDL. CIT VS. H EMAN DAS DHANRAJMAL (1985) 155 ITR 533 THE VALUE OF THE MATERIALS SUPPLIED BY THE STATE G OVERNMENT TO THE CONTRACTOR FOR BEING EXCLUSIVELY USED FOR THE EXECU TION OF THE WORK WAS TO BE EXCLUDED WHILE DETERMINING THE TURNOVER OF THE CONTRACTOR-ASSESSEE. THE TRIBUNAL WAS, THEREFORE, RIGHT IN HOLDING THAT THE COST OF MATERIALS SUPPLIED BY THE STATE GOVERNMENT COULD NOT BE INCL UDED IN THE GROSS RECEIPT OF THE BUSINESS OF THE ASSESSEE WHILE CALCU LATING THE NET PROFITS OF THE ASSESSEES BUSINESS. 4- THE RAJASTHAN HIGH COURT IN CASE OF GIRDHARI LAL A ND CO. VS. CIT (1998) 230 ITR 510 ( RAJ.) IN THE INSTANT CASE, THE TRIBUNAL, WHILE HOLDING THAT RECEIPTS BY WAY OF ADJUSTMENT OF RAW MATERIALS WERE TO BE INCLUDED IN THE GROSS RECEIPTS FOR PURPOSE OF ESTIMATION OF GROSS PROFIT, HAD, AFT ER TAKING INTO CONSIDERATION THE VARIOUS CLAUSES OF CONTRACT, FOUN D THAT THE CASE OF THE ASSESSEE WAS HAVING SIMILAR FACTS AS WERE IN THE CA SE OF BRIJ BUSHAN LAL V. CIT [1971] 81 ITR 497 ( PUN) & HAR.) DECIDED BY THE ALLAHABAD HIGH COURT. SINCE THE SAID DECISION HAD ALREADY BEEN OV ERRULED BY THE APEX COURT IN BRIJ BHUSHAN LAL PRADUMAN KUMAR V. CIT [ 1978] 115 ITR 524, THE NATURAL COROLLARY WOULD BE THAT THE ASSESSEE WO ULD BE ENTITLED FOR REDUCING THE COST OF MATERIALS SUPPLIED FROM THE GR OSS AMOUNT OF THE CONTRACT AND THE TAX LIABILITY WOULD BE ONLY ON THE BALANCE PAYMENT. FROM THE AFORESAID DECISION OF SUPREME COURT AND JU RISDICTIONAL HIGH COURT, IT IS CLEAR THAT THAT MATERIAL DIRECTLY SUP PLIED BY THE PARTY OR RECEIPTS BY WAY OF ADJUSTMENT OF RAW MATERIAL ARE T O BE EXCLUDED FROM THE TURNOVER OF THE CONTRACTOR FOR THE PURPOSE OF C ALCULATING NET PROFIT. IN THE CASE OF APPELLANT, APART FROM MONEY RECEIVED BY CHEQUE RS. 3,14,53,887/- AND CASH RS. 3,87,00,000/-, OTHER PAY MENTS ARE EITHER DIRECT MATERIAL SUPPLIED OR ADJUSTMENT IN RESPECT O F MATERIAL SUPPLIED AND THEREFORE THE SAME HAS TO BE EXCLUDED FROM THE TURNOVER OF APPELLANT WHILE ESTIMATING NET PROFIT. ASSESSING OF FICER INCLUDED RS. 9,41,35,821/- AS APPELLANTS UNACCOUNTED TURNOVER W HICH INCLUDES ADJUSTMENT IN RESPECT OF STEEL, CEMENT AND SUPPLIER S BILLS. THIS ALSO INCLUDES CASH PAYMENT OF RS. 3,87,00,000/- WHICH A PPELLANT HAS ALSO ACCEPTED AS PART OF HIS TURNOVER. RESPECTFULLY FOLL OWING THE DECISIONS OF JURISDICTIONAL HIGH COURT AND SUPREME COURT, ASSES SING OFFICER IS DIRECTED TO EXCLUDE ADJUSTMENT IN RESPECT OF STEEL, CEMENT AND SUPPLIERS 8 ITA NO. 966/JP/2013 M/S. BHIVARAM PANNALAL BILLS FROM THE GROSS BILLS FOR THE PURPOSE OF ESTIM ATION OF NET PROFIT IS THEREFORE REDUCED FROM RS. 9,41,35,821 TO RS. 3,87, 00,000. THE ABOVE FINDING OF FACT IS NOT CONTROVERTED BY TH E REVENUE BY PLACING ANY CONTRARY MATERIAL ON RECORD. MOREOVER, THE FINAL BI LL AS RELIED BY THE REVENUE STATES PAYMENT BY CASH AND CHEQUE AND THE DESCRIPTI ON IS CLEAR THAT THERE IS NO AMBIGUITY IN THIS REGARD. THEREFORE, WE DO NOT SEE ANY REASON TO INTERFERE INTO THE ORDER OF LD. CIT (A), THE SAME IS HEREBY A FFIRMED. THE GROUND RAISED BY THE REVENUE IS DISMISSED. 6. IN THE RESULT, APPEAL OF THE REVENUE AND CROSS O BJECTION OF THE ASSESSEE ARE DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 28/02/201 7. SD/- SD/- FOE FLAG ;KNO DQY HKKJR (VIKRAM SINGH YADAV) (KUL BHARAT) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 28/02/2017. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- THE ACIT, CIRCLE-6, JAIPUR. 2. IZR;FKHZ@ THE RESPONDENT- M/S. BHIVARAM PANNALAL, 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. 966/JP/2013 & CO NO. 7/JP/14} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR 9 ITA NO. 966/JP/2013 M/S. BHIVARAM PANNALAL