SANSKRITI BUILD-DEV PRIVATE LIMITED,JAIPUR V. ITO WD 6(2), JAIPUR

ITA 417/JPR/2025

AI Insights

The case involves Sanskriti Build-Dev Pvt. Ltd., the appellant, challenging the validity of a notice issued under section 148 of the Income Tax Act for the assessment year 2014-15. The notice was issued by the Assessing Officer on 23.06.2021, which was claimed to be beyond the permissible time limit as per the Supreme Court's decision in Union of India & Ors. v. Rajeev Bansal. The Income Tax Appellate Tribunal, Jaipur, examined whether the notice was issued within the surviving period allowed by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). The tribunal found that the notice was indeed issued beyond the surviving period, leading to the decision in favor of the appellant.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 775624 (ITAT-JAIPUR)
• Duration Of Justice: 5 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 10-09-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2014-2015
• Appeal Filed On: 18-03-2025
• Other Referred Cases: Union of India & Ors. v. Rajeev Bansal (2024) 167 Taxman 70 (SC), Ashish Agarwal v. Union of India
• Laws Referred To: Income Tax Act
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ANITA RINES H
• Assessee Lawyers: RAKESH KUMAR
• Keywords: Set aside; Opportunity of being heard; Corroborative evidences; Unexplained cash credit; Period of limitation; Time period of passing order
• Section: 148; 132

Judgement Text

"vk;dj vihyh; vf/kdj.k] t;iqj U;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A-Bench” JAIPUR Jh xxu xks;y] ys[kk lnL; ,o aJh ujsUnz dqekj] U;kf;d lnL; ds le{k BEFORE: SHRI GAGAN GOYAL, AM & SHRI NARINDER KUMAR, JM vk;dj vihy la-@ITA No. 417/JPR/2025 fu/kZkj.ko\"kZ@Assessment Year : 2014-15 Sanskriti Build-Dev Private Limited R-19, Raj Aangan, Haldi Chati Marg, Pratap Nagar, Sanganer, Sector-11, jaipur. cuke Vs. The ITO, Ward-6(2), Jaipur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAJCS4565J vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assessee by : Shri Rakesh Kumar, C.A. jktLo dh vksjls@Revenue by: Mrs. Anita Rinesh, JCIT lquokbZ dh rkjh[k@Date of Hearing :08/09/2025 mn?kks\"k.kk dh rkjh[k@Date of Pronouncement: 10/09/2025 vkns'k@ORDER PER: NARINDER KUMAR, JUDICIAL MEMBER . The assessee was in appeal before Learned CIT(A), while challenging assessment order dated 29.05.2023, relating to the assessment year 2014-15. Said appeal has been dismissed vide impugned order dated 29.01.2025, passed by Learned CIT(A), National Faceless Appeal Centre, Delhi, whereby confirming the addition made by the Assessing Officer. Printed from counselvise.com 2 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. 2. Arguments heard. File perused. 3. The only argument advanced before this Appellate Tribunal, on behalf of the appellant is that notice dated 27.07.2022, issued u/s 148 of the Act, by the Assessing Officer, to the assessee was barred by limitation, as the same was required to be issued within 8 days, when calculated as per decision by the Hon’ble Apex Court in Union of India & Ors. Rajeev Bansal (2024) 167 Taxman 70 (SC), but the same came to be issued beyond the prescribed period. The contention raised by Ld. AR for the appellant is that as a result the impugned order, passed by Learned CIT(A) confirming the order issued by the Assessing Officer u/s 148A(d) of the Act, deserves to be set aside. 4. It may be mentioned here that in the course of arguments, Ld. AR for the appellant has specifically submitted that except the above said legal ground, no argument is to be advanced or pressed. 5. Learned DR for the department has submitted that she stands by the reasons recorded by CIT(A) on the basis of decisions relied therein. 6. A perusal of record would reveal that even before Learned CIT(A), only the above said contention was raised i.e. the notice u/s 148 of the Act having been issued on 23.06.2021, in view of decision in Rajeev Bansal’s case (supra), there was only a period of 8 days with the Assessing Officer Printed from counselvise.com 3 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. to issue notice under section 148 A(d), i.e. upto 30.06.2021, but the same having not been issued within the prescribed period, notice was invalid and void-ab-initio. 7. While dealing with the above said contention raised on behalf of the assessee, Learned CIT(A) observed as under:- “I have gone through all the submissions and documents furnished by the appellant. As the appellant has raised objections against re-assessment proceedings, the concerned provisions are reproduced below for reference: The Finance Act, 2021 has also substituted Section 148 of the Act, with effect from 01/04/2021. The provisions u/s 148 of the Act reads as under: \"Section 148 Before making the assessment, reassessment or recomputation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant assessment year, in the prescribed form and verified in the prescribed manner and setting forth such other particulars as may be prescribed; and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139: Provided that no notice under this section shall be issued unless there is information with the Assessing Officer which suggests that the income chargeable to tax has escaped assessment in the case of the assessee for the relevant assessment year and the Assessing Officer has obtained prior approval of the specified authority to issue such notice. The provisions of section 148 of the Act are made subject to the provisions of section 148A of the Act, which provision has been newly enacted by the Finance Act, 2021. The provisions of section 148A of the Act, read as under :- 148A. The Assessing Officer shall, before issuing any notice under section 148, conduct any enquiry, if required, with the prior approval of specified authority. with respect to the information which suggests that the income chargeable to tax has escaped assessment; Printed from counselvise.com 4 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. provide an opportunity of being heard to the assessee, with the prior approval of specified authority, by serving upon him a notice to show cause within such time, as may be specified in the notice, being not less than seven days and but not exceeding thirty days from the date on which such notice is issued, or such time, as may be extended by him on the basis of an application in this behalf. as to why a notice under section 148 should not be issued on the basis of information which suggests that income chargeable to tax has escaped assessment in his case for the relevant assessment year and results of enquiry conducted, if any, as per clause (a); consider the reply of assessee furnished, if any, in response to the show-cause notice referred to in clause (b); decide, on the basis of material available on record including reply of the assessee, whether or not it is a fit case to issue a notice under section 148, by passing an order, with the prior approval of specified authority, within one month from the end of the month in which the reply referred to in clause (c) is received by him, or where no such reply is furnished, within one month from the end of the month in which time or extended time allowed to furnish a reply as per clause (b) expires: Provided that the provisions of this section shall not apply in a case where,- a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A in the case of the assessee on or after the 1st day of April, 2021, or the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner that any money, bullion, jewellery or other valuable article or thing, seized in a search under section 132 or requisitioned under section 132A, in the case of any other person on or after the 1st day of April, 2021, belongs to the assessee; or the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner that any books of account or documents. seized in a search under section 132 or requisitioned under section 132A, in case of any other person on or after the 1st day of April, 2021, pertains or pertain to, or any information contained therein, relate to, the assessee. CBDT issued Instruction No. 01 of 2022 on May 11, 2022, instructing the Assessing Officers as under. 1. To provide the information and material relied upon for issuance of extended reassessment notices within 30 days of the judgement of the Hon'ble Supreme Court Le. June 02, 2022. 2. The assessee had two weeks to reply as to why a notice under section 148 of the Act should not be issued to him on the basis of information which suggests that income chargeable to tax has escaped assessment in his case for the said assessment year. Printed from counselvise.com 5 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. 3. After receiving the reply, the assessing officer shall decide on the basis of the material available on record including the reply of the assessee, whether or not it is a fit case to issue a notice under section 148 of the Act. The assessing officer is required to pass an order under section 148A (d) with the prior approval of specified authority under the new law within one month from the end of the month in which the reply is received. 4. If it is a fit case to issue a notice under section 148 of the Act, the assessing officer shall serve on the assesse notice under section 148 after obtaining the approval of the specified authority under section 151 of the Act, along with a copy of the order under section 148A(d) of the Act. In the second round of litigations, writ petitions/appeals were filed and various High Courts quashed the notices on the ground that benefit of TOLA was not applicable to the new regime of reassessment. It is found that the AO has followed the instructions of CBDT and various courts during re-assessment proceedings. The AO has issued notices, provided the information and material relied upon by the AO to the appellant. issued order u/s 148A (d) of the Income tax Act, 1961 by following the provisions of the Act. All the objections raised by the appellant were duly considered by the AO and a speaking order u/s 148A (d) of the Income tax Act, 1961 was passed on 27/07/2022. I do not find any merit in the grounds of appeal adduced by the appellant. It is pertinent to mention here that the appellant had also raised objections against re-assessment proceedings before the AO also. All the objections raised by the appellant were duly considered by the AO and a speaking Order u/s 148A (d) of the Income tax Act, 1961 was passed. The appellant has not provided any documentary evidences related to unexplained cash credits. The appellant has failed to explain the cash credits. Hence I do not find any merit in the grounds of appeal adduced by the appellant due in the absence of of supporting evidences. In view of the factual matrix of the case at hand and the discussion above, these grounds of appeal are, accordingly, dismissed and the addition made by the AO on this account is, hereby, confirmed. 6. In the result, the appeal is dismissed. In the result, the appeal is decided as above.” 8. Ld. DR for the department has opposed the contention raised by Ld. AR for the appellant and submitted following written submissions:- Printed from counselvise.com 6 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. “2. Legal Framework - Rajeev Bansal Judgment (SC) In Union of India v. Rajeev Bansal [(2024) 167 Taxman 70 (SC)], the Hon'ble Supreme Court in Paras 110 to 112 laid down the principle that: The limitation period under the Income Tax Act, as extended by TOLA, is not lost merely because notices were issued under the old regime. This surviving period is preserved in full, and becomes available after the assessee submits reply to the deemed show-cause notice under Section 148A(b). Para 110: Clarifies that the limitation period is suspended from the date of the old notice until the assessee is served with material and has replied. Para 111: States that the clock of limitation begins only after the assessee has filed the reply under Section 148A(b). The AO is then required to complete all procedural steps-including passing of the order under Section 148A(d) and issuance of notice under Section 148- within the preserved surviving period. Para 112: Gives a working illustration: Where a notice was issued on 01.05.2021 (within the old regime), the period till 30.06.2021 is 61 days. These 61 days survive and are available in full to the AO after receiving the reply from the assessee. This is a universal principle applicable to all reassessment notices issued between 01.04.2021 and 30.06.2021, and is not confined to the example given. 3. Application to the Present Case - No Delay  Original notice u/s 148: 23.06.2021 (under old regime, deemed valid SCN under Section 148A(b) as per Ashish Agarwal)  Material provided: As per CBDT Instruction No. 1/2022  Assessee filed reply: 19.06.2022  Surviving period under TOLA: 61 days (from date of original notice up to 30.06.2021, as per Para 112 of SC judgment)  Notice u/s 148 issued: 27.07.2022  Time elapsed from date of reply: 38 days.” 9. Ld. DR for the department has also pointed out that Writ Petition –DB Civil Writ Petition No.14988/2022 filed by the appellant herein and others challenging the notice under section 148 stands dismissed by our own Hon’ble High Court. She has further submitted that factum of dismissal of Printed from counselvise.com 7 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. the writ petition filed by our own Hon’ble High Court, challenging notice u/s 148 of the Act, has been concealed on behalf of the assessee even in the course of arguments. 10. We have specifically enquired from Ld. AR for the appellant as to why the factum of dismissal of the Writ Petition, filed by the appellant, challenging notice u/s 148 of the Act, has not been brought to our notice, Ld. AR has submitted that he himself is not within the know of the dismissal of the writ petition filed by the assessee. 11. Be that as it may, as pointed out by Ld. DR for the department, the above writ petition filed by the assessee and others has been recently dismissed on 21.08.2025. 12. In para 5 ,6 and 8 to 10 of the order passed by our own Hon’ble High Court, it has been observed as under:- “5. We accordingly direct the revenue to examine each and every case relating to the deemed notices issued under Section 148 of the Act, in light of the observations made by the Supreme Court in Rajeev Bansal's case (supra) and reach to a conclusion, as to whether the proceedings would fall within the limitation or have become time barred in terms of sub-para F, G & H of paragraph No.114 (supra). 6. While examining the cases, the example as mentioned by the Apex Court in its judgment in Rajeev Bansal's case (supra) in paragraph No.112 and observations made in paragraph Nos. 110 and 111, shall also be taken into consideration. Cases, which fall less than the value of Rs.50,00,000/- would have to be dropped keeping in view the stand taken by the revenue before the Apex Court, as observed in paragraph No.53. ………….. Printed from counselvise.com 8 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. 8. In view of the above, the contentions raised before us are rejected. Further, it has also been brought to notice that in the recent judgments passed in the cases of Assistant Commissioner of Income Tax Vs. Vikram Kapahi, reported in 2025] 170 taxmann.com 593 (SC), decided on 06.01.2025, Income Tax Officer Vs. Ashish Acharatlal Varaiya, reported in [2024] 168 taxmann.com 588 (SC) and Income Tax Officer Vs. Pradeep Himatlal Shah, reported in [2025] 170 taxmann.com 472 (SC), decided on 20.12.2024, the Hon'ble Supreme Court has also disposed of the Special Leave Petitions in terms of the judgment passed in Rajeev Bansal (supra) with the observation that the Assessing Officer shall dispose of the petitions in terms of the law laid down therein. 9. We order accordingly. All the petitions stand disposed of. Pending application, if any, also stands disposed of. 10. If any of the petitioner/assessee is still aggrieved of the order passed, remedy in terms of the provision of the Act can be availed by him.” 13. At this stage, on the issue involved herein, relevant paragraphs of decision in Rajeev Bansal’s case (supra), cited by Learned AR for the appellant and learned DR for the appellant, need to be reproduced for ready reference. Same read as under:- “108. The Income Tax Act read with TOLA extended the time limit for issuing reassessment notices under Section 148, which fell for completion from 20 March 2020 to 31 March 2021, till 30 June 2021. All the reassessment notices under challenge in the present appeals were issued from 1 April 2021 to 30 June 2021 under the old regime. Ashish Agarwal (supra) deemed these reassessment notices under the old regime as show cause notices under the new regime with effect from the date of issuance of the reassessment notices. The effect of creating the legal fiction is that this Court has to imagine as real all the consequences and incidents that will inevitably flow from the fiction. 163 Therefore, the logical effect of the creation of the legal fiction by Ashish Agarwal (supra) is that the time surviving under the Income Tax Act read with TOLA will be available to the Revenue to complete the remaining proceedings in furtherance of the deemed notices, including issuance of reassessment notices under Section 148 of the new regime. The surviving or balance time limit can be Printed from counselvise.com 9 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. calculated by computing the number of days between the date of issuance of the deemed notice and 30 June 2021. 109. If this Court had not created the legal fiction and the original reassessment notices were validly issued according to the provisions of the new regime, the notices under Section 148 of the new regime would have to be issued within the time limits extended by TOLA. As a corollary, the reassessment notices to be issued in pursuance of the deemed notices must also be within the time limit surviving under the Income Tax Act read with TOLA. This construction gives full effect to the legal fiction created in Ashish Agarwal (supra) and enables both the assesses and the Revenue to obtain the benefit of all consequences flowing from the fiction, 110. The effect of the creation of the legal fiction in Ashish Agarwal (supra) was that it stopped the clock of limitation with effect from the date of issuance of Section 148 notices under the old regime [which is also the date of issuance of the deemed notices] As discussed in the preceding segments of this judgment, the period from the date of the issuance of the deemed notices till the supply of relevant information and material by the assessing officers to the assesses in terms of the directions issued by this Court in Ashish Agarwal (supra) has to be excluded from the computation of the period of limitation. Moreover, the period of two weeks granted to the assesses to reply to the show cause notices must also be excluded in terms of the third proviso to Section 149. 111. The clock started ticking for the Revenue only after it received the response of the assesses to the show causes notices. After the receipt of the reply, the assessing officer had to perform the following responsibilities: (i) consider the reply of the assessee under Section 149A(c); (ii) take a decision under Section 149A(d) based on the available material and the reply of the assessee; and (iii) issue a notice under Section 148 if it was a fit case for reassessment. Once the clock started ticking, the assessing officer was required to complete these procedures within the surviving time limit. The surviving time limit, as prescribed under the Income Tax Act read with TOLA, was available to the assessing officers to issue the reassessment notices under Section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under the old regime for a relevant assessment year. Because of the legal fiction, the deemed show cause notices will also come into effect from 1 May 2021. After accounting for all the exclusions, the assessing officer will have sixty-one days [days between 1 May 2021 and 30 June 2021] to issue a notice under Section 148 of the new regime. This time starts ticking for the assessing officer after receiving the response of the assessee. In this instance, if the assessee submits the response on 18 June 2022, the assessing officer will nerfs Section 148 of the Printed from counselvise.com 10 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. new regime: Thus, in this illustration, the time limit for issuance of a notice under Section 148 of the new regime will end on 18 August 2022. 113. In Ashish Agarwal (supra), this Court allowed the assesses to avail all the defences, including the defence of expiry of the time limit specified under Section 149(1). In the instant appeals, the reassessment notices pertain to the assessment years 2013-2014, 2014-2015, 2015-2016, 2016-2017, and 2017- 2018. To assume jurisdiction to issue notices under Section 148 with respect to the relevant assessment years, an assessing officer has to: (i) issue the notices within the period prescribed under Section 149(1) of the new regime read with TOLA, and (ii) obtain the previous approval of the authority specified under Section 151. A notice issued without complying with the preconditions is invalid as it affects the jurisdiction of the assessing officer. Therefore, the reassessment notices issued under Section 148 of the new regime, which are in pursuance of the deemed notices, ought to be issued within the time limit surviving under the Income Tax Act read with TOLA. A reassessment notice issued beyond the surviving time limit will be time-barred. G. Conclusions 114. In view of the above discussion, we conclude that: a. After 1 April 2021, the Income Tax Act has to be read along with the substituted provisions; b. TOLA will continue to apply to the Income Tax Act after 1 April 2021 if any action or proceeding specified under the substituted provisions of the Income Tax Act falls for completion between 20 March 2020 and 31 March 2021; c. Section 3(1) of TOLA overrides Section 149 of the Income Tax Act only to the extent of relaxing the time limit for issuance of a reassessment notice under Section 148, d. TOLA will extend the time limit for the grant of sanction by the authority specified under Section 151. The test to determine whether TOLA will apply to Section 151 of the new regime is this if the time limit of three years from the end of an assessment year falls between 20 March 2020 and 31 March 2021, then the specified authority under Section 151(i) has extended time till 30 June 2021 to grant approval; e. In the case of Section 151 of the old regime, the test is: if the time limit of four years from the end of an assessment year falls between 20 March 2020 and 31 March 2021, then the specified authority under Section 151(2) has extended time till 31 March 2021 to grant approval; Printed from counselvise.com 11 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. f. The directions in Ashish Agarwal (supra) will extend to all the ninety thousand reassessment notices issued under the old regime during the period 1 April 2021 and 30 June 2021; g. The time during which the show cause notices were deemed to be stayed is from the date of issuance of the deemed notice between 1 April 2021 and 30 June 2021 till the supply of relevant information and material by the assessing officers to the assesses in terms of the directions issued by this Court in Ashish Agarwal (supra), and the period of two weeks allowed to the assesses to respond to the show cause notices; and h. The assessing officers were required to issue the reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside; 115. The judgments of the High Courts rendered in Union of India v. Rajeev Bansal, 105 Keenara Industries Pvt. Ltd. v. ITO, Surat, JM Financial and Investment Consultancy Services Pvt. Ltd. v. ACIT, Siemens Financial Services Pvt. Ltd. v. DCIT, 168 Geeta Agarwal v. ITO, 169 Ambika Iron and Steel Pvt Ltd v. PCIT, 170 Twylight Infrastructure Pvt Ltd v. ITO, 171 Ganesh Dass Khanna v. ITO, 172 and other judgments of the High Courts which relied on these judgments, are set aside to the extent of the observations made in this judgment. 116. The appeals filed by the Revenue are accordingly allowed. The appeals filed by the assesses will be governed by reasons discussed in this judgment.” 14. Herein, notice under section 148 of the Act was issued on 23.6.2021. It is clear from the copy of the notice itself available on record. In the written submission, however, Learned DR has mentioned the date of issuance of notice as 1.5.2021. But, the record speaks otherwise. 15. Admittedly, as regards assessment year 2014-15, the period of six years was to be over between 20.3.2020 and 30.6.2021. Therefore, the Printed from counselvise.com 12 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. notice issued under section 148 of the Act under old regime as per TOLA , on 23.6.2021 was a valid notice. 16. Proceeding further, admittedly, information was supplied to the assessee under section 148A(b) on 13.6.2022. Assessee filed reply thereto on 19.6.2022. 17. In this manner, counting the period as per decision by Hon’ble Apex Court, right from 23.6.2021, last date for issuance of notice under section 148 A(d) i.e. after considering the reply of the assessee, was 26.6.2022. But, herein, admittedly, the notice under section 148A(d) was issued to the assessee on 27.7.2022, after considering reply of the assessee under section 148A(c). In other words, the proceedings were not concluded by the Assessing Officer within the stipulated/surviving period i.e. upto 26.6.2022. When so calculated, we find merit in the contention raised on behalf of the appellant that the notice under section 148A(d) issued on 27.7.2022 was beyond the surviving period. Since the period of limitation, as provided under Section 149(1) of the Act, had expired prior to issuance of the impugned notice, same is held to be invalid being beyond the period of limitation. Printed from counselvise.com 13 ITA No. 417/JPR/2025 Sanskriti Build-Dev Pvt. Ltd, Jaipur. Result 18. In view of the above findings, this appeal filed by the assessee deserves to be allowed. Same is hereby allowed on the sole legal ground, and the impugned orders are set aside. File be consigned to the record room after the needful is done by the office. Order pronounced in the open court on 10/09/2025. Sd/- Sd/- ¼xxu xks;y½ ¼ujsUnz dqekj½ (GAGAN GOYAL) (NARINDER KUMAR) ys[kk lnL; @Accountant Member U;kf;d lnL;@Judicial Member Tk;iqj@Jaipur fnukad@Dated:- 10/09/2025 *Santosh vkns'k dh izfrfyfivxzsf’kr@Copy of the order forwarded to: 1. The Appellant- Sanskriti Build-Dev Pvt. Ltd., Jaipur. 2. izR;FkhZ@ The Respondent- ITO, Ward-6(2), Jaipur. 3. vk;djvk;qDr@ The ld CIT 4. foHkkxh; izfrfuf/k] vk;djvihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur 5. xkMZQkbZy@ Guard File ITA No. 417/JPR/2025) vkns'kkuqlkj@ By order, lgk;d iathdkj@Asstt. Registrar Printed from counselvise.com "