NIRMAL KUMAR JAIN,KOTA V. ACIT, KOTA

ITSSA 10/JPR/2025

AI Insights

The case involves appeals by Nirmal Kumar Jain against the orders of the Ld. CIT (A), which confirmed the additions made by the Assessing Officer (AO) under sections 69 and 69A of the Income Tax Act, 1961, following a search operation. The Tribunal examined the legality of the assessment proceedings initiated under section 153A, the nature of the additions made for undisclosed cash loans and unexplained expenses, and the application of section 115BBE. The Tribunal found that the additions for cash loans should be restricted to the peak credit amount due to the nature of the transactions and the lack of specific incriminating evidence for the entire amounts added. However, it upheld the additions related to unexplained marriage and jewellery expenses, noting the absence of sufficient evidence to link these expenses to disclosed sources of income.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 793777 (ITAT-JAIPUR)
• Duration Of Justice: 2 month(s) 5 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 26-09-2025
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Assessment Year: 2018-2019
• Appeal Filed On: 21-07-2025
• Other Referred Cases: DCIT v. Manoj Kumar Gupta (ITA No. 621 & 622/JPR/2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: ALKA GAUTAM; LD
• Assessee Lawyers: VINOD GUPTA; LD
• Keywords: Condonation of delay; Business income; Unexplained expenditure; Unexplained investment; Income from undisclosed sources; Document seized; Peak credit; Documents seized; Loose papers; Notional interest
• Section: 132; 153A; 69; 69C; 139

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “B”, JAIPUR BEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER IT (SS) A Nos. 9 & 10/JPR/2025 (A.Y.s 2017-18 & 2018-19 Nirmal Kumar Jain, B-100, Bhamashah Mandi, Kota. PAN No.: ABNPJ 0423G ..... Appellant Vs. ACIT, Central Circle, Kota. ..... Respondent Appellant by : Mr. Vinod Gupta, Adv., Ld. AR Respondent by : Ms. Alka Gautam, CIT, Ld. DR Date of hearing : 11/09/2025 Date of pronouncement : 26/09/2025 O R D E R PER GAGAN GOYAL, A.M: These two appeals by assessee are directed against the order of Ld. CIT(A), Udaipur-2 dated 21.11.2024 passed u/s. 250 of the Income Tax Act, 1961 (in short ‘the Act’) for A.Y.s 2017-18 & 2018-19. The assessee has raised the following grounds of appeal:- In IT (SS) A No. 9/JPR/2025 1. The Ld. CIT (A) has erred in law as well as on the facts of the case in confirming the action of Ld. AO of initiating the assessment proceeding u/s. Printed from counselvise.com 2 153A of the Income Tax Act. The very action taken u/s. 153A of the act is bad in law and without jurisdiction. Hence, the same may kindly be quashed. 2. The Ld. CIT (A) has erred in law and on facts in confirming the addition of Rs. 77, 50,000/- on account of investment in cash loans from undisclosed sources. The addition so made is unwarranted, excessive and kindly be deleted in full. 3. Without prejudice to the above, the Ld. CIT(A) has further erred in law and on facts in confirming the addition of Rs. 77,50,000/- under section 69 of the Act, instead of treating the same as business income. Even if any addition is to be made, it should be assessed as business income and not as unexplained income under section 69. The addition under section 69 is unjustified, excessive, and not in accordance with the facts and submissions on record, and May kindly be deleted. 4. The Ld. CIT (A) has erred in law as well as on facts in confirming the action of the Ld. AO of invoking the provisions of section 115BBE of the Act. The said invocation is contrary to the law as well as facts and deserves to be quashed. 5. without prejudice, the Ld. CIT (A) has further erred in law as well as on the facts of the case in confirming the action of the Ld. AO of levying tax at the rate of 60% u/s 115BBE. The rate so levied is illegal and bad in law. 6. That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing. In IT (SS) A No. 10/JPR/2025 1. The Ld. CIT (A) has erred in law as well as on the facts of the case in confirming the action of Ld.AO of initiating the assessment proceeding u/s 153A of the Income Tax Act. The very action taken u/s. 153A of the act is bad in law and without jurisdiction. Hence, the same may kindly be quashed. 2. the Ld. CIT (A) has erred in law and on facts in confirming the addition of Rs. 22, 50,000/-on account of investment in cash loans from undisclosed sources. The addition so made is unwarranted, excessive and kindly be deleted in full. 3. Without prejudice to the above, the Ld. CIT(A) has further erred in law and on facts in confirming the addition of Rs. 22,50,000/- under section 69A of the Act, instead of treating the same as business income. Even if any addition is to be made, it should be assessed as business income and not as unexplained money under section 69A. The addition under section 69A is unjustified, Printed from counselvise.com 3 excessive, and not in accordance with the facts and submissions on record, and May kindly be deleted. 4. the Ld. CIT (A) has erred in law and on facts in sustaining the addition of Rs. 32, 22,227/- on account of marriage and jewellery expenses. While telescopic benefit was provided, the entire addition ought to have been deleted, as the source of such expenditure was already explained and taxed. The addition results in double taxation and should be deleted in full. 5. The Ld. CIT (A) has erred in law as well as on facts in confirming the action of the Ld. AO of invoking the provisions of section 115BBE of the Act. The said invocation is contrary to the law as well as facts and deserves to be quashed. 6. That the appellant craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing. In IT (SS) A No. 9/JPR/2025 2. The brief facts of the case are that the assessee is engaged in trading of agricultural produce and also work as an Arat in the agriculture market. The assessee filed his return of income under section 139 of the Act on 27.09.2017, declaring total income at Rs. 62, 57,390/- and agriculture income of Rs. 1, 89,860. A search action under section 132 of the Act was carried out on 18.04.2018 in the case of N.C. Moi Kalan Group, Kota and its associated concerns. Assessee was also searched under section 132 of the Act. Accordingly, notice under section 153A of the Act was issued and in response to this notice, assessee filed return under section 153A on 11.01.2019 declaring total income of 62, 57,390/- and agriculture income of Rs. 1, 89,860. During the search operation at the residential premises of the assessee, investigation wing found certain counter foils which was annexed as Exhibit-1 of Annexure-AS of Party-A2 which was claimed to contain details pertaining to ‘Hundis’. It was stated by the AO, in his assessment order, that the counter foils contain sum of Rs. 77, 50,000/- which was given as cash loans by the Printed from counselvise.com 4 assessee during the year. Further, the AO had also made addition of Rs. 2, 55,750 for the year, on account of interest earned on cash loan given by the assessee. Further, as per the AO, the assessee, in his statement, admitted to have given cash loans to various persons and surrendered the amount but the same was retracted and not reported in the ITR furnished by the assessee post search. During assessment proceedings, the assessee furnished the submissions before the AO. However, AO was not satisfied with the reply of the assessee and accordingly made the addition of undisclosed/unexplained cash loans under section 69 of the Act and also made the addition of unaccounted interest income on advances given to farmers. The assessee being aggrieved with this order preferred an appeal before the Ld. CIT (A), who in turn upheld the addition made by the AO. The assessee, being further aggrieved with this order of the Ld. CIT (A), preferred the present appeal before us. 3. Before we proceed on the appeal filed by the assessee, it is brought to our knowledge that the appeal of the assessee is time barred by 171 days. On this issue, the assessee filed an application for condonation of delay alongwith his affidavit. It is brought to our notice that the assessee’s appeal before the Ld. CIT (A) was disposed of by an order dated: 21.11.2024 and the same was due for filing by 31.01.2025. But the same was filed before us on 21.07.2025, i.e. with a delay of 171 days. For the delay, the assessee submitted that the order was passed during November which is a period of enormous business activity for commission agent and traders of agricultural produce and the mother of the appellant was also critically ill due to which the assessee remained un- aware about the orders. Further, the CA of the assessee had also not Printed from counselvise.com 5 communicated the order to the assessee and the new CA of the assessee informed him about the orders in the last week of June. We have carefully considered the facts of the case, affidavit and application for condonation application filed by the assessee. In the result, taking lenient view, we deem it fit to condone the delay of 171 days in the interest of justice. 4. The DR relied on the orders of the AO and the Ld. CIT (A). 5. We have gone through the assessment order, order of the Ld. CIT (A) and submissions made by the assessee both before the AO and Ld. CIT (A). We have respectfully considered the judicial decisions relied upon by the assessee and the paper book filed by the assessee. Firstly, we take up Grounds of Appeals No. 3 raised with respect to addition made for cash loans given by the assessee. We observe from the assessment order and order of the Ld. CIT (A) that a search action under section 132 was carried out in the case of the assessee on 18.04.2018. During the course of search, certain material inventoried as Exhibit-1 of Annexure-AS of Party-A2 was found and seized. The AR of the assessee has also submitted the material vide his paper book for our perusal. For better understanding of this issue raised by the assessee, we are herein-below reproducing some images of the seized material under consideration: Printed from counselvise.com 6 Printed from counselvise.com 7 Printed from counselvise.com 8 6. The AO and the Ld. CIT (A) held that the contents of such page contain the entries of Hundis which is the cash loans given by the assessee. On the other hand, AR of the assessee highlighted before us the deficiencies in the seized pages and submitted that the seized pages neither indicate name of the appellant, drawer, drawee and payee nor having reference for any loan/cash or any year, hence they are deaf and dumb documents and cannot be held to be representing actual transactions. Further, the AR of the assessee also submitted although section 69 of the Act is not applicable in the current case since the assessee has not made any investment, however, without admitting, the jottings does not represent fresh loans rather they are sourced from the similar cash loans given earlier by the assessee, hence benefit of rotation should be given. 7. With regard to the statement, the AR of the assessee stated that the statement was obtained by coercive measures and assessee has retracted the statement, which is also acknowledged by the AO and the Ld. CIT (A), by not disclosing the same in his ITR and also invited our attention to CBDT Instruction: F. No. 286/2/2003-IT (Inv), dated 10th March, 2003 and judgments of various Hon’ble High Courts in reference to the forced confession. 8. On perusal of the orders of the AO and the Ld. CIT(A) and the submissions made by the appellant before the AO and the Ld. CIT(A) and before us. We notethat the assessee had admitted in his statement that the material seized during search are ‘Hundi Receipt Book’ which contain details of cash loan taken and cash loan given by the assessee. Although, there is no corroborative evidence showing name of recipient of loan, rate of interest, period etc., however in view of the admission during the search and appellant failure to discharge his onus u/s 292C of Printed from counselvise.com 9 explaining the paper seized from him, we are not in agreement with the contention of the assessee that the seized material is deaf and dumb document. 9. Since the document is not deaf and dumb, the only issue that is to be decided as to whether the whole amount so found to have been recorded in that seized material is to be considered as undisclosed income of the assessee or the year wise peak should be added in the total income of the assessee. We find that it is the prevalent practice in the trade of the assessee to give loan for the duration of 2-3 months and the same is also stated by the assessee in his statement which was not been objected by the AO or the Ld. CIT(A). Hence, to this effect, we find that if we are attributing evidentiary value to the statement under the current case, the statement has to be read as a whole without pick and choose theory and the submission of the assessee in his statement that cash loans are given for 2-3 months must also be given required weightage. 10. We also note that the addition of cash loan, made in the current case, is the sum of each entry appearing in the seized material. This fact is also admitted by the assessee in the statement that the addition is the sum of all the entries appearing in the seized material. It is a fact that no other unaccounted income was found during the search. Moreover, the contention of the assessee that cash loans if given is out of repayment received of earlier cash loans cannot be ignored and it would not be proper on the part of the revenue to tax the total of seized material treating the same as cash loans. Further, it is also not in dispute that the seized material is not communicating complete details with respect to cash loans in a sense that they are not stating clearly with regard to the year to which they relate, name of receiver, period etc. and neither the AO nor the Ld. CIT(A) or the Printed from counselvise.com 10 assessee has brought before us any conclusive working about the seized material. We rely on our observation made in our own following judgement: a) DCIT v. Manoj Kumar Gupta (ITA No. 621 & 622/JPR/2025 “…Since, assessee has not provided the name of any such person, considering the statement of the assessee during post search proceedings, a reasonable income is required to be assessed in the hands of the assessee with reference to the total of transactions noted in these diaries in as much as the total receipt as such cannot be held to be income, more particularly when no corresponding asset or investment or expenditure was found in search…” 11. It is also observed by us that for invoking section 69 of the Act, there has to be an unrecorded/ unaccounted investment and that there cannot be any unaccounted investment without there being any unaccounted income. Therefore, for making any unaccounted investment, the assessee must be in possession of some unaccounted income. This position further supports the case of the assessee that the cash loans given were sourced from the repayment receipt of earlier cash loans since there is neither any evidence on record nor any finding of the AO or the Ld. CIT(A) regarding the sourcing of cash loans from any identified source. 12. Thus, in the light of the above facts and situation, to meet the end of justice, we deem it to proper to give benefit of rotation and also hold that only peak/ incremental peak of cash loans transaction can be added, as income, in the hands of the assessee. The basic idea of applying peak theory under the current case is that the real income of the assessee should be taxed. Accordingly, considering the duration of loans to be 3 months (no. of rotation of money in a year = 4), the year wise peak would come to Rs. 19, 37,500 (77, 50,000/4) for the year. Accordingly, the real income of the assessee for the current year, on account of cash loans Printed from counselvise.com 11 given by the assessee, comes to Rs. 19, 37,500. Therefore, we restrict the addition to Rs. 19, 37,500/- under the current case. 13. As far as addition made for interest on cash loans is concerned, it has been observed that the AO has made addition of Rs. 2, 55,750/- for the year. On perusal of the assessment order, it is observed that the AO has just relied on the statement of the assessee for making addition however he has not brought on record any documentary evidence with respect to the interest earned/charged by the assessee on cash loans given by him. In the light of above observations, it can be safely concluded that the whole addition is roaming around the statement of the assessee. In our view, although statement recorded u/s 132(4) has some evidentiary value but assessee could not have subjected to addition merely on the basis of statement recorded u/s 132(4) until the said statement is corroborated by some documentary evidence. It is the duty of the AO to substantiate his addition by bringing something corroborative in support of his claim/ action which is absent in the current case. The Ld. CIT (A) also confirmed the addition ignoring that no incriminating material was found in this regard. Further, the AR of the assessee draws our attention to the seized material relevant for the addition under consideration. On perusal of the seized documents, it has been observed that the same are not speaking anything about the interest charged by the assessee, the year to which it relates and is silent on the said subject. There is no indication from the seized material that interest is charged by the assessee. Mere figure cannot constitute actual transaction until unless corroborated with some evidence. Further, no interest can be added on notional basis. Since, the AO has not brought any evidence which confirms that the assessee has charged any Printed from counselvise.com 12 interest on cash loans; we have no hesitation to delete the addition made in the current case. We rely on our observation made in our following judgment: b) DCIT v. Manoj Kumar Gupta (ITA No. 621 & 622/JPR/2025 “So far as ground of the assessee is concerned, we find from the ledger account of Mohit Trading Co. (PB 128) and Nand Lal Naresh Kumar (PB 129-130), that interest charged by assessee from these concerns is @ 9% p.a. The Ld. CIT(A) has invoked section 40A(2) of the Act in confirming the addition ignoring that AO has not disallowed the expenditure but has made addition for notional interest. There is no section in the Act which empowers the AO to make addition on account of notional income. In search also no evidence/document was found to indicate that assessee has charged interest from the above parties at rate more than what is recorded in books of accounts. Hence in the absence of any incriminating material found in search, no addition for notional interest can be made. Further how much interest is to be charged is to be decided by the businessman. The AO cannot put himself in the shoes of the businessman to decide as to at what rate he should charge the interest as held by Hon’ble Supreme Court in case of Hero Cycles (P.) Ltd. Vs. CIT(Central) (2015) 379 ITR 347.The Ld. CIT(A)has confirmed the addition invoking Sec.40A(2) of the Act ignoring that this section is applicable when interest is paid to a related party which is excessive or unreasonable. In the present case interest is not paid to these parties but rather interest is charged from these parties and therefore Section 40A (2) of the Act is not applicable. In view of above the addition of Rs. 23, 67,618/- confirmed by Ld. CIT (A) is deleted by allowing the ground of the assessee.” 14. Further, we do not find any justification in the action of the Ld. CIT (A) in upholding the addition when no document related to addition was found. Hence, in our considered view, the action of the Ld. CIT (A) is not correct. With these observations, appeal of assessee is allowed and addition is hereby deleted. 15. In the result, appeal of the assessee is partly allowed. In IT (SS) A No. 10/JPR/2025 Printed from counselvise.com 13 16. We have gone through the assessment order, order of the Ld. CIT (A) and submissions made by the assessee both before the AO and Ld. CIT (A). We have respectfully considered the judicial decisions relied upon by the assessee and the paper book filed by the assessee. Firstly, we take up Grounds of Appeals No. 2 raised with respect to voluntary surrender of Rs. 22,50,000/-. It is observed that the AO has just relied on the statement of the assessee for making addition and has not brought on record any documentary evidence with respect to the addition made. In our view, although statement recorded u/s 132(4) has some evidentiary value but assessee could not have subjected to addition merely on the basis of statement recorded u/s 132(4) until the said statement is corroborated by some documentary evidence. It is the duty of the AO to substantiate his addition by bringing something corroborative in support of his claim/ action which is absent in the current case. The Ld. CIT (A) also confirmed the addition ignoring that no incriminating material was found in this regard. Since, the AO has not brought any evidence, the addition cannot sustain. Further, we also agree with the contention of the AR of the assessee that no addition under section 69A can be made without proving ownership. In the current case, there is no whisper about the ownership of money involved. Hence, we find it apt to delete the addition of Rs. 22, 50,000/- made in the current case. 17. As far as addition made for interest on cash loans is concerned, it has been observed that the AO has made addition of Rs. 10, 23,000/- for the year. On perusal of the assessment order, it is observed that AO has made addition for interest on cash loan without adding the cash loan itself which indicate that Printed from counselvise.com 14 the AO presumed that the cash loan advanced by the assessee during F.Y. 2017-18 was outstanding till the current year as there is no other possible reason for adding interest without there being any addition for cash loan. However, no documentary evidence in support of this has been brought on record. We further note that the AO has just relied on the statement of the assessee for making addition however he has not brought on record any documentary evidence with respect to the interest earned/charged by the assessee on cash loans given by him. In the light of above observations, it can be safely concluded that the whole addition is roaming around the statement of the assessee. In our view, although statement recorded u/s 132(4) has some evidentiary value but assessee could not have subjected to addition merely on the basis of statement recorded u/s 132(4) until the said statement is corroborated by some documentary evidence. It is the duty of the AO to substantiate his addition by bringing something corroborative in support of his claim/ action which is absent in the current case. Further, the AR of the assessee draws our attention to the seized material relevant for the addition under consideration. On perusal of the seized documents, it has been observed that the same are not speaking anything about the interest charged by the assessee, the year to which it relates and is silent on the said subject. There is no indication from the seized material that interest is charged by the assessee. Mere figure cannot constitute actual transaction until unless corroborated with some evidence. Further, no interest can be added on notional basis. Since, the AO has not brought any evidence which confirms that the assessee has charged any interest on cash loans, we have no hesitation to Printed from counselvise.com 15 delete the addition made in the current case. We rely on our observation made in our following judgment: c) DCIT v. Manoj Kumar Gupta (ITA No. 621 & 622/JPR/2025 “So far as ground of the assessee is concerned, we find from the ledger account of Mohit Trading Co. (PB 128) and Nand Lal Naresh Kumar (PB 129-130), that interest charged by assessee from these concerns is @ 9% p.a. The Ld. CIT(A) has invoked section 40A(2) of the Act in confirming the addition ignoring that AO has not disallowed the expenditure but has made addition for notional interest. There is no section in the Act which empowers the AO to make addition on account of notional income. In search also no evidence/document was found to indicate that assessee has charged interest from the above parties at rate more than what is recorded in books of accounts. Hence in the absence of any incriminating material found in search, no addition for notional interest can be made. Further how much interest is to be charged is to be decided by the businessman. The AO cannot put himself in the shoes of the businessman to decide as to at what rate he should charge the interest as held by Hon’ble Supreme Court in case of Hero Cycles (P.) Ltd. Vs. CIT(Central) (2015) 379 ITR 347.The Ld. CIT(A)has confirmed the addition invoking Sec.40A(2) of the Act ignoring that this section is applicable when interest is paid to a related party which is excessive or unreasonable. In the present case interest is not paid to these parties but rather interest is charged from these parties and therefore Section 40A (2) of the Act is not applicable. In view of above the addition of Rs. 23, 67,618/- confirmed by Ld. CIT (A) is deleted by allowing the ground of the assessee.” 18. Now we take up Ground of Appeal No. 4 raised for addition of Rs. 32, 22,227/- made for unexplained jewellery and expenses in marriage. The investigation wing found material annexed as Exhibit-7 and 13 of Annexure-AS of Party-A2 which claimed to contain expenditure made for purchase of jewellery and in marriage of Shubham Jain. During the assessment proceedings, the assessee was asked to explain unexplained marriage expenses and expenditure in jewellery. The submission made by the assessee was examined and after examination of the submission, the AO completed the assessment with the addition of Rs. 32, 22,227/- in this regard. The AR of the assessee submitted Printed from counselvise.com 16 that 1113.50 grams of jewellery was found during the search of the assessee which was stated to be belonging to the family members. The said jewellery also included jewellery purchase during marriage of the niece of the assessee and jewellery purchased during marriage of appellant’s nephew: Shubham Jain. The total of such jewellery comes to Rs. 12, 86,528/-. It is the contention of the AR of the assessee that the said jewellery is fully explained in terms of CBDT Instruction No. 19616 dated 11.05.1994 and no addition for Rs. 12, 86,528 should be made. 19. We have gone through the assessment order, order of the Ld. CIT (A) and submissions made by the assessee. We find that the assessee lives in a joint family along with his parents and brother and their family and during the search 1113.50 grams of jewellery were found. They also stated that the jewellery belongs to the family members and also included jewellery of his niece. We further note that there is no evidence in support of the situation that the jewellery purchased during marriage of the niece of the assessee and jewellery purchased during marriage of appellant’s nephew is not included in the jewellery found during search. In this connection, we have also perused instruction No.1916 dated 11-05-1994 which provides that during the search operations, no seizure of gold jewellery and ornaments to the extent of 500 grams per married lady, 250 grams per unmarried lady and 100 grams per male member of the family shall be made. Hence, implying that to that extent, the jewellery is explained. Further, considering the no. of members of the family and the fact that the jewellery belongs to the family, there remains no unexplained jewellery in the current case. Accordingly, in the facts and Printed from counselvise.com 17 circumstance of the case, the jewellery of Rs. 12,86,528/- which is part of the jewellery found during search has to be allowed as explained jewellery and no addition can be made to that extent. Further, since we have deleted the addition to the extent of Rs. 12, 86,528/-, the question of telescoping to that extent, as provided by the Ld. CIT (A), does not arise. 20. As far as the remaining addition of Rs. 19,35,699 (32,22,227 – 12,86,528) is concerned, we note that the assessee has not submitted any documentary evidence in support of his claim that the same have been sourced out of disclosed income of the assessee and his brother. We take note of the substantial amount of income furnished in the ITR by the assessee and his brother and the availability of cash in the firm’s book but this alone cannot prove that the expenditure has been made out of this disclosed income only as the assessee failed to bring any evidence of withdrawal of cash and utilization of the cash against marriage expenses. As mentioned above, there is no direct evidence brought on record which could suggest that the assessee has incurred the expenditure in marriage expenses out of his disclosed income or the available cash. Therefore, in our view, the AO and the Ld. CIT(A) has rightly assessed additional income to the extent of Rs. 19,35,699/- under section 69C of the Act and their orders should be upheld since it is settled law that any unexplained expenditure whose source is not explained is assessable under section 69C of the Act. Further, since the addition has been confirmed, the said addition is liable to be taxed at the rate of 60% as specified in Section 115BBE of the Act. Printed from counselvise.com 18 21. In the result, appeal of the assessee is partly allowed. The Order is pronounced in the open court on 26th day of September 2024. Sd/- Sd/- (Dr. S. SEETHALAKSHMI) (GAGAN GOYAL) JUDICIAL MEMBER ACCOUNTANT MEMBER Jaipur, िदनांक/Dated: 26/09/2025 Copy of the Order forwarded to: 1. अपीलाथŎ/The Appellant , 2. Ůितवादी/ The Respondent. 3. आयकर आयुƅ CIT 4. िवभागीय Ůितिनिध, आय.अपी.अिध., Sr.DR., ITAT, 5. गाडŊ फाइल/Guard file. BY ORDER, //True Copy// (Asstt. Registrar) ITAT, Jaipur Details Date Initials Designation 1 Draft dictated on PC on 26.09.2025 Sr.PS/PS 2 Draft Placed before author 26.09.2025 Sr.PS/PS 3 Draft proposed & placed before the Second Member JM/AM 4 Draft discussed/approved by Second Member JM/AM 5. Approved Draft comes to the Sr.PS/PS Sr.PS/PS 6. Kept for pronouncement on Sr.PS/PS 7. File sent to the Bench Clerk Sr.PS/PS 8 Date on which the file goes to the Head clerk 9 Date of Dispatch of order Printed from counselvise.com "