PUSHPA VIDYA NIKETAN SAMITI,KOTA V. ACIT DCIT,CENTRAL CIRCLE, , KOTA

ITA 313/JPR/2024

AI Insights

The case involves Pushpa Vidya Niketan Samiti, an educational institution, which appealed against the orders of the CIT (A) confirming additions made by the AO regarding alleged suppressed school fees for the assessment years 2015-16 to 2017-18. The additions were based on documents seized during a survey at M/s. Quick Advertisement Co., which were linked to the assessee's fee collection records. The Tribunal examined the legality of the survey, the admissibility of the statements recorded during the survey, and the application of sections 11 & 12 concerning the exemption of income. The Tribunal found that the statements recorded under section 131 during the survey were not automatically binding and that the documents seized did not belong to the assessee, leading to the deletion of the additions made.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 474496 (ITAT-JAIPUR)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-03-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: 2015-2016
• Other Referred Cases: CIT v. S. Khader Khan Son, Smt. Tarulata Shyam v. CIT, L.P. Cardoza v. Agrl. ITO, Orissa State Warehousing Corporation v. CIT, S.C. Cambatta & Co. Ltd. v. CIT, CIT v. Shrishakti Trading Co.
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ANUP SINGH; LD
• Assessee Lawyers: MAHENDRA GARGIEYA; HEMAND GARGIEYA; LD
• Keywords: Documents seized; Benefit of exemption
• Section: 148; 143(2); 250; 11; 12AA; 153; 131; 13; 153C; 234B; 12; 139(4); 133A; 207

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “B”, JAIPUR BEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER ITA Nos. 313 to 315/JPR/2024 (A.Y.s 2015-16 to 2017-18) Pushpa Vidya Niketan Samiti, Village-Alania, Jhalawar Road, Kota 324005 PAN No.: AAAJP0539P ...... Appellant Vs. ACIT Central Circle, Kota ...... Respondent Appellant by : Mr. Mahendra Gargieya, Adv. & Mr. Hemand Gargieya, Adv., Ld. AR Respondent by : Mr. Anup Singh, Addl. CIT- Ld. DR Date of hearing : 11/03/2025 Date of pronouncement : 24/03/2025 O R D E R PER GAGAN GOYAL, A.M: These three appeals by the assessee are directed against the order of Ld. CIT (A), Udaipur-2 dated 25.01.2024 passed u/s. 250 of the Income Tax Act, 1961 (in short ‘the Act’). The assessee has raised the following grounds of appeal vide ITA No. 313/JPR/2024 (A.Y. 2015-16) as under: 2 1. The survey u/s. 133A carried out on the office premises of M/s. Quick Advertisement Co., 149, Ballabhbari, Kota on 02.02.2017 is illegal, void ab initio being without jurisdiction and therefore any inference or implications flowing from such an illegal survey, deserves to be ignored or be not given effect to while adjudicating the other grounds relating to the additions towards the declared income or otherwise. 2. The statements recorded on dated 04.02.2017 u/s 131 of the Act were recorded unauthorized and illegally by the person who was not authorized in law to administer oath. Consequently, there is no evidentiary value of such illegally recorded statement being without authority of law, hence the implication or inference flowing from such statements may be directed to be completely ignored. 3. Rs. 51,14,243/-: The Ld. CIT(A) erred in law as well as on the facts of the case in confirming the addition made by the Ld. AO on account of alleged suppressed school fees, completely ignoring the consistently followed method of accounting, and other material available on record. The addition so made and confirmed being contrary to provision of law and facts the same may kindly deleted in full. 4.1 The Ld. CIT (A) further erred in law as well as on the facts of the case in confirming the denial of the benefit of exemption of income u/s. 11 & 12 of the Act despite the appellant trust already enjoying the registration under S. 12AA. Hence, the benefit so denied and confirmed by the CIT(A) being contrary to the provision of law and facts, the authorities below may be directed to allow the benefit of exemption income, as claimed. 4.2 Alternatively, and without prejudice to above, if the addition of the suppressed school fees of Rs. 51,14,243/- is upheld, the same may kindly be declared as entitled to the exemption u/s. 11 & 12 of the Act and thus, assessing the total income at nil. 5. Rs.9,83,551/-: The Ld. CIT(A) has erred in law as well as in facts in confirming the charging interest made by the AO u/s. 234B & 234D of the Act. The appellant totally denies it liability of charging of any such interest. The interest, so charged, being contrary to the provisions of law and facts, kindly be deleted in full. 6. the appellant prays your honor to add, amend or alter any of the grounds of the appeal on or before the date of hearing. In ITA No. 314/JP/2024 (2016-17), the assessee has raised the following grounds of appeal: 1. The survey u/s. 133A carried out on the office premises of M/s. Quick Advertisement Co., 149, Ballabhbari, Kota on 02.02.2017 is illegal, void ab initio being without jurisdiction and therefore any inference or implications flowing from such an illegal survey, deserves to be ignored or be not given effect to while 3 adjudicating the other grounds relating to the additions towards the declared income or otherwise. 2. The statements recorded on dated 04.02.2017 u/s. 131 of the Act were recorded unauthorized and illegally by the person who was not authorized in law to administer oath. Consequently, there is no evidentiary value of such illegally recorded statement being without authority of law, hence the implication or inference flowing from such statements may be directed to be completely ignored. 3. Rs.36,43,740/-: The Ld. CIT(A) erred in law as well as on the facts of the case in confirming the addition made by the Ld. AO on account of alleged suppressed school fees, completely ignoring the consistently followed method of accounting, and other material available on record. The addition so made and confirmed being contrary to provision of law and facts the same may kindly deleted in full. 4.1 The Ld. CIT (A) further erred in law as well as on the facts of the case in confirming the denial of the benefit of exemption of income u/s. 11 & 12 of the Act despite the appellant trust already enjoying the registration under S.12AA of the Act. Hence, the benefit so denied and confirmed by the CIT (A) being contrary to the provision of law and facts, the authorities below may be directed to allow the benefit of exemption income, as claimed. 4.2 Alternatively, and without prejudice to above, if the addition of the suppressed school fees of Rs. 36,43,740/- is upheld, the same may kindly be declared as entitled to the exemption u/s. 11 & 12 of the Act and thus, assessing the total income at nil. 5. Rs. 8,40,589/-: The Ld. CIT(A) has erred in law as well as in facts in confirming the charging interest made by the AO u/s. 234B of the Act. The appellant totally denies it liability of charging of any such interest. The interest, so charged, being contrary to the provisions of law and facts, kindly be deleted in full. 6. the appellant prays your honor to add, amend or alter any of the grounds of the appeal on or before the date of hearing. In ITA No. 315/JP/2024 (2017-18), the assessee has raised the following grounds of appeal: 1. The survey u/s. 133A carried out on the office premises of M/s. Quick Advertisement Co., 149, Ballabhbari, Kota on 02.02.2017 is illegal, void ab initio being without jurisdiction and therefore any inference or implications flowing from such an illegal survey, deserves to be ignored or be not given effect to while adjudicating the other grounds relating to the additions towards the declared income or otherwise. 4 2. The statements recorded on dated 04.02.2017 u/s. 131 of the Act were recorded unauthorized and illegally by the person who was not authorized in law to administer oath. Consequently, there is no evidentiary value of such illegally recorded statement being without authority of law, hence the implication or inference flowing from such statements may be directed to be completely ignored. 3. Rs. 20,30,710 /-: The Ld. CIT(A) erred in law as well as on the facts of the case in confirming the addition made by the Ld. AO on account of alleged suppressed school fees, completely ignoring the consistently followed method of accounting, and other material available on record. The addition so made and confirmed being contrary to provision of law and facts the same may kindly deleted in full. 4.1 The Ld. CIT (A) further erred in law as well as on the facts of the case in confirming the denial of the benefit of exemption of income u/s. 11 & 12 of the Act despite the appellant trust already enjoying the registration under S. 12AA of the Act. Hence, the benefit so denied and confirmed by the CIT (A) being contrary to the provision of law and facts, the authorities below may be directed to allow the benefit of exemption income, as claimed. 4.2 Alternatively, and without prejudice to above, if the addition of the suppressed school fees of Rs. 20,30,710/- is upheld, the same may kindly be declared as entitled to the exemption u/s. 11 & 12 of the Act and thus, assessing the total income at nil. 5. The ld. CIT (A) has erred in law as well as in facts in confirming the charging interest made by the AO u/s. 234A, 234B & 234C of the Act. The appellant totally denies it liability of charging of any such interest. The interest, so charged, being contrary to the provisions of law and facts, kindly be deleted in full. 6. the appellant prays your honor to add, amend or alter any of the grounds of the appeal on or before the date of hearing. In ITA No. 313/JP/2024, A. The following ground of appeal is modified, as under: “2. The ld. CIT(A) and the AO seriously erred in alleging / taking stand that statement of the assessee recorded during survey on 04.02.2017 were recorded u/s 131, against the correct factual and legal position that the statements were recorded u/s 133A(3)(iii) and therefore such survey statement has no evidentiary value at all. Therefore the reliance placed by the AO and supported by CIT(A) for making/confirming the additions (on this legal aspect that statement were recorded u/s 131 on oath has evidentiary value hence can be used against the assessee), is a complete misinterpretation of law and misreading of the facts on record and hence, the stand of Revenue deserves to be rejected and moreover the implications flowing from such statements may be directed to be completely ignored.” 5 B. The following additional grounds of appeal are being raised, as under: “7. The impugned notice u/s 148 dt. 15.03.2019 is void ab initio and a nullity, having been issued completely without jurisdiction u/s 147, instead of issuing the notice u/s 153C. Consequently, the impugned assessment proceedings having being initiated in consequence to certain material seized during search & seizure proceedings in the case of Allen Group Kota, the assessment proceedings were to carried out u/s 153C only, being a third party case. Hence, the impugned notice u/s 148 dated 15.03.2019 and the consequent impugned assessment order deserves to be quashed and set-aside. 8. The impugned assessment order dated 30.12.2019 is a nullity being non-est and must be considered as never passed in as much as no DIN number has been generated as per the prescribed procedure, which is in violation of the binding instructions of CBDT and hence, the impugned assessment order may kindly be held as non-est and may kindly be quashed. In 314/JP/2024, A. The following ground of appeal is modified, as under: “2. The ld. CIT(A) and the AO seriously erred in alleging / taking stand that statement of the assessee recorded during survey on 04.02.2017 were recorded u/s 131, against the correct factual and legal position that the statements were recorded u/s 133A(3)(iii) and therefore such survey statement has no evidentiary value at all. Therefore the reliance placed by the AO and supported by CIT (A) for making/confirming the additions (on this legal aspect that statement were recorded u/s 131 on oath has evidentiary value hence can be used against the assessee), is a complete misinterpretation of law and misreading of the facts on record and hence, the stand of Revenue deserves to be rejected and moreover the implications flowing from such statements may be directed to be completely ignored.” B. The following additional grounds of appeal are being raised, as under: “7. The impugned notice u/s 148 dt. 15.03.2019 is void ab initio and a nullity, having been issued completely without jurisdiction u/s 147, instead of issuing the notice u/s 153C. Consequently, the impugned assessment proceedings having being initiated in consequence to certain material seized during search & seizure proceedings in the case of Allen Group Kota, the assessment proceedings were to carried out u/s 153C only, being a third party case. Hence, the impugned notice u/s 148 dated 15.03.2019 and the consequent impugned assessment order deserves to be quashed and set-aside. 6 8. The impugned assessment order dated 31.12.2019 is a nullity being non-est and must be considered as never passed in as much as no DIN number has been generated as per the prescribed procedure, which is in violation of the binding instructions of CBDT and hence, the impugned assessment order may kindly be held as non-est and may kindly be quashed. In ITA No. 315/JP/2024, A. The following ground of appeal is modified, as under: “2. The ld. CIT(A) and the AO seriously erred in alleging / taking stand that statement of the assessee recorded during survey on 04.02.2017 were recorded u/s 131, against the correct factual and legal position that the statements were recorded u/s 133A(3)(iii) and therefore such survey statement has no evidentiary value at all. Therefore the reliance placed by the AO and supported by CIT(A) for making/confirming the additions (on this legal aspect that statement were recorded u/s 131 on oath has evidentiary value hence can be used against the assessee), is a complete misinterpretation of law and misreading of the facts on record and hence, the stand of Revenue deserves to be rejected and moreover the implications flowing from such statements may be directed to be completely ignored.” B. The following additional grounds of appeal are being raised, as under: “7. The impugned notice u/s 143(2) dt. 13.11.2019 is void ab initio and a nullity, having been issued completely without jurisdiction, instead of issuing the notice u/s 153C. Consequently, the impugned assessment proceedings having being initiated in consequence to certain material seized during search & seizure proceedings in the case of Allen Group Kota, the assessment proceedings were to carried out u/s 153C only, being a third party case. Hence, the impugned notice u/s 143(2) dated 13.11.2019 and the consequent impugned assessment order deserves to be quashed and set-aside. 8. The impugned assessment order dated 31.12.2019 is a nullity being non-est and must be considered as never passed in as much as no DIN number has been generated as per the prescribed procedure, which is in violation of the binding instructions of CBDT and hence, the impugned assessment order may kindly be held as non-est and may kindly be quashed. 2. For sake of convenience we are taking ITA No. 313/JPR/2024 (A.Y. 2015-16) first as the facts of the matter for all the years are identical, results of this appeal will apply mutatis mutandis to the other two appeals also. The assessee filed its 7 return of income on 31.03.2016 u/s. 139(4) of the Act declaring total income at Rs. 1, 03,060/-. The assessee is running an educational institution; a survey u/s. 133A of the Act was carried out at the premises of the assessee in consequence to the search action in the case of “Allen Group, Kota” on 03.02.2017. Notice u/s. 148 of the Act was issued on 15.03.2019. The assessee again filed its return of income at Rs. 1, 03,060/- in compliance to notice u/s. 148 of the Act. The AO found that the total fee received as per the details in assessment order was 2, 19, 60,470/-, whereas the assessee has shown only 1, 63, 43,957/-, i.e. a difference of Rs. 56, 16,513/-. Although Shri Naresh Jain, Accountant on behalf the assessee surrendered a sum of Rs. 50 Lacs to cover all the error and omissions, but retracted from his statement and not included the same in return of income. Ultimately, the case of the assessee was assessed after making addition of Rs. 56, 16,513/- without giving benefit of section 11 & 12 of the Act. The assessee being aggrieved with the same preferred an appeal before the Ld. CIT (A) - Udaipur-2, who in turn allowed the appeal of the assessee on partly basis. Still, the assessee being aggrieved with the order of the Ld. CIT (A) preferred the present appeal before us. 3. We have gone through the order of the AO, order of the Ld. CIT (A) and submissions of the assessee alongwith grounds taken before us. Ground No. 1 is not pressed, hence dismissed. Ground No. 2 is a legal ground taken by the assessee, wherein it was under challenge that “The statements recorded vide dated:04.02.2017 u/s. 131 of the Act were unauthorized and illegal. Consequently, there is no evidentiary value of such illegally recorded statement being without authority of Law, hence the implication or inference flowing from statements may 8 be directed to be completely ignored.” We have considered the ground taken by the assessee in the light of provisions of section 131 of the Act and judicial pronouncements of various coordinate benches and Hon’ble High Courts and Apex Court. 4. It is found that the similar issue on the validity of statements recorded u/s. 131 of the Act during the survey proceedings u/s. 133A of the Act by the coordinate bench, Jaipur in the case of M/s. Nikhaar Fashions ITA No. 1020/JPR/2024, wherein Accountant Member was author and observed as under: “16. Moreover, as far as the authenticity of the statement recorded during the survey proceedings are concerned, Section 133A does not empower the authorities to record the statements. This is a settle position of law that the statement obtained under section133A would not automatically bind upon the assessee. However, an admission is extremely an important piece of evidence but it cannot be said that it is conclusive; and it is open to the person who made the admission to show that it is incorrect. The burden lies on the assessee to establish that the admission made in the statement at the time of survey was wrong and that there was no additional income. Judgment in CIT v. S. Khader Khan Son [2008] 300 ITR 157 (Mad.) is very important as Supreme Court also affirmed this judgment S. Khader Khan Son's case (supra) where it has been held that the statement, obtained under section133A would not automatically bind upon the assessee.” 5. In view of the above and relying on the decision in the case of CIT vs. S. Khader Khan Son (supra) duly affirmed by the Hon’ble Apex Court, Ground No. 2 taken by the assessee is allowed and it is confirmed that section 133A of the Act does not empower the authorities to record the statements and statements obtained during the survey proceedings would not automatically bind the assessee. However, burden still lying on the assessee to prove the statement otherwise in the light of substantive evidences. 9 6. Ground No. 5 is consequential in nature; hence no specific adjudication is required and Ground No. 6 is general in nature again no specific adjudication is required. Ground Nos. 3, 4.1 and 4.2 are substantive in nature and require specific adjudication by the Bench. The assessee is involved in imparting school education in the name of Bhagat Public School and the administration of the same is being managed by Shri Naresh Jain. A survey was conducted u/s. 133A of the Act at the premises of the assessee and also at M/s. Quick Advertisement Co., Prop. Smt. Nisha Jain. During the survey at M/s. Quick Advertisement Co. certain documents were seized as Annexure A-15/Page No. 37-41, A-15/Page No. 42-49 and A-15/Page No. 1-9 containing list of students, i.e. 12th Allen, 11th Allen and student list of LKG to 12th of Bhagat Public School respectively. These documents were confronted to Shri Naresh Jain who confirmed and admitted that these documents related to class wise actual fee collection of the student of Bhagat Public School and that the lower fee collection has been disclosed as compared to the actual fee collected by the Bhagat Public School and therefore offered for taxation Rs. 50 Lacs for each year, i.e. A.Y.s 2015-16, 2016-17 and 2017-18. 7. Now, here again we would like reiterate that being a survey matter, this bench is relying on the documents being seized in the light of section 292C of the Act and no importance is being given to the statements recorded u/s. 131 of the Act. For sake of ready reference provisions of section 292C of the Act are reproduced herein below as under: “Section - 292C, Income-tax Act, 1961 - FA, 2024 Presumption as to assets, books of account, etc. 292C. (1) Where any books of account, other documents, money, bullion, jewellery or other valuable article or thing are or is found in the possession or control of any person in the course 10 of a search under section 132or survey under section 133A, it may, in any proceeding under this Act, be presumed— (i) that such books of account, other documents, money, bullion, jewellery or other valuable article or thing belong or belongs to such person; (ii) that the contents of such books of account and other documents are true; and (iii) that the signature and every other part of such books of account and other documents which purport to be in the handwriting of any particular person or which may reasonably be assumed to have been signed by, or to be in the handwriting of, any particular person, are in that person's handwriting, and in the case of a document stamped, executed or attested, that it was duly stamped and executed or attested by the person by whom it purports to have been so executed or attested.] (2) Where any books of account, other documents or assets have been delivered to the requisitioning officer in accordance with the provisions of section 132A, then, the provisions of sub-section (1) shall apply as if such books of account, other documents or assets which had been taken into custody from the person referred to in clause (a) or clause (b) or clause (c), as the case may be, of sub-section (1) of section 132A, had been found in the possession or control of that person in the course of a search under section 132.” 8. Now as indicated in bold and underlined (supra) the provisions of section 292C of the Act, “Where any books of account, other documents, money, bullion, jewellery or other valuable article or thing are or is found in the possession or control of any person in the course of a search under section 132or survey under section 133A, it may, in any proceeding under this Act, be presumed that such books of account, other documents, money, bullion, jewellery or other valuable article or thing belong or belongs to such person. Now, in the present case there was a simultaneous survey at the premises of the assessee and M/s. Quick Advertisement Co., Prop. Smt. Nisha Jain. The fact that the documents under consideration were found from M/s. Quick Advertisement Co., Prop. Smt. Nisha Jain and not from the control or possession of the assessee school. 11 9. In view of the provisions of section 292C of the Act he above data was gathered from the business premises of M/s Quick Advertisement Co. and the edifice of the impugned addition is the above statement of Shri Naresh Jain. From the orders of the lower authorities, it is noted that the contents of above extracted statement of Shri Naresh Jain have been taken to be gospel of truth for justifying the impugned addition. This action of the lower authorities has been challenged by the appellant/assessee as untenable both factually as well as legally. It is true that section 133A r.w.s. 292C of the Act, raises a presumption that that the contents of books of account and other documents seized during the course of search is true. But it should be kept in mind that this presumption is only qua the person who is searched and/or from whose possession the books of account and documents are found and none else. Moreover, this presumption is rebuttable. In the given facts of the case, since the documents in question was not found or impounded from the appellant's premises but in the course of survey (not search) conducted against a third party, the presumption set out in Section 292C of the Act does not apply to the appellant. 10. It may also be mentioned that as per well-established law as explained by Hon'ble Supreme Court in the case of Smt. Tarulata Shyam v. CIT 1977 CTR (SC) 275: [1977] 108 ITR 345 (SC), there is no scope for importing into the statute words which are not there. The intention of the legislature is primarily to be gathered from the words used in the statute. Once the assessee comes within the letter of law he must be taxed. In the case of L.P. Cardoza v. Agrl. ITO [1998] 144 CTR (Kar) 474: [1997] 227 ITR 421 (Kar), it has been held by Hon'ble Karnataka High Court that while interpreting a provision in a tax law wherein a legal fiction is 12 created, such provision will have to be strictly interpreted. In the case of Orissa State Warehousing Corporation v. CIT [1999] 153 CTR (SC) 177: [1999] 237 ITR 589 (SC), it has been held that a fiscal statute shall have to be interpreted on the basis of the language used therein and not de hors the same. No words ought to be added and only the language used ought to be considered so as to ascertain the proper meaning and intent of the legislation. In the case of S.C. Cambatta & Co. Ltd. v. CIT [1952] 21 ITR 121 (Bom), it has been held that in a fiscal statute the Court should not permit a wider or more extensive obligation to be cast upon the subject than the clear language of the fiscal statute lays down. In the case of CIT v. Shrishakti Trading Co. [1994] 118 CTR (Bom) 196: [1994] 207 ITR 442 (Bom), it has been held that it is well-settled that legal fictions are for a definite purpose and they are limited for the purpose for which they are created and should not be extended beyond that legitimate field. 11. Moreover, other than this calculation sheets found at the premises of M/s. Quick Advertisement Co. no further working carried out by the AO to substantiate the same that it pertains to the assessee and calculations embedded there are true to be considered for the purposes of taxation. Notwithstanding, the above as held (supra) that the statement recorded during the survey operations 133A of the Act has no evidentiary value and presumptions drawn u/s. 292C of the Act are also not in the favour of the Revenue. Resultantly, Ground No. 3 raised by the assessee is allowed and the AO is directed to delete the addition of Rs. 56, 16,513/-. Ground Nos. 4.1 and 4.2 left undecided as the substantial Ground No. 3 has already been decided in the favour of the assessee, hence the same became infructuous and no adjudication is required and dismissed accordingly. 13 12. Modified Ground No. 2 has already been adjudicated in favour of the assessee and Additional Ground Nos. 7 and 8 left open as the matter has already been reached to the Bench of Hon’ble Apex Court and divergent views of various Hon’ble High Courts are there, hence dismissed. 13. In the Result, ITA No. 313/JPR/2024 (A.Y. 2015-16) is partly allowed in above terms. ITA No. 314/JPR/2024 (A.Y. 2016-17)&ITA No. 315/JPR/2024 (A.Y. 2017-18) 14. As the facts are identical in both the appeals alongwith the grounds taken are also similar, our findings in ITA No. 313/JPR/2024 (A.Y. 2015-16) (supra) will apply mutatis mutandis to these appeals also. 15. In the Result, both the appeals ITA No. 314/JPR/2024 (A.Y. 2016-17) & ITA No. 315/JPR/2024 (A.Y. 2017-18) are partly allowed. Order pronounced in the open court on24th day of March 2025. Sd/- Sd/- (Dr. S. SEETHALAKSHMI) (GAGAN GOYAL) JUDICIAL MEMBER ACCOUNTANT MEMBER Jaipur, िदनांक/Dated: 24/03/2025 14 Copy of the Order forwarded to: 1. अपीलाथ /The Appellant , 2. \u000eितवादी/ The Respondent. 3. आयकर आयु\u0015 CIT 4. िवभागीय \u000eितिनिध, आय.अपी.अिध., Sr.DR., ITAT, 5. गाड फाइल/Guard file. BY ORDER, //True Copy// (Asstt. Registrar) ITAT, Jaipur Details Date Initials Designation 1 Draft dictated on PC on 24.03.2025 Sr.PS/PS 2 Draft Placed before author 24.03.2025 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 "