Agrasen Engineering Industries Ltd., ... vs Department Of Income Tax

Jh vkj-ih-rksykuh] U;kf;d lnL; ,oa Jh Vh-vkj-ehuk] ys[kk lnL; ds le{k BEFORE: SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM

vk;dj vihy la-@ITA No. 758/JP/2012 fu/kZkj.k o"kZ@Assessment Year : 2009-10

The ACIT cuke M/s. Agrasen Engineering Circle- 4 Vs. Industries Ltd. Jaipur G-515-518, Road No. 9A, VKI Area , Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCA 3401 D vihykFkhZ@Appellant izR;FkhZ@Respondent

jktLo dh vksj ls@ Revenue by : Shri D.C. Sharma, Addl. CIT -DR fu/kZkfjrh dh vksj ls@ Assessee by : Shri Vijay Goyal, CA

lquokbZ dh rkjh[k@ Date of Hearing : 01/06/2015 ?kks"k.kk dh rkjh[k@ Date of Pronouncement : 26 /06/2015

vkns'k@ ORDER

PER R.P. TOLANI, JM

This is an appeal filed by the Revenue against the order of the ld.

ld. CIT(A)-II, Jaipur dated 04-06-2012 for the assessment year 2009-10

wherein following grounds are raised.

''On the facts and in the circumstances of the case and in law the ld. CIT(A) has erred in:-

2 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

(i) deleting trading addition of Rs. 93,94,856/-

made by the AO after rejection of books of account u/s 145(3) without appreciating the facts of the case.

(ii) deleting the addition of Rs. 12,77,984/- made by the AO on account of undisclosed sale despite the fact that assessee could not prove that the scrap was retained by the job workers..''

2.1 Brief facts of the case are that the assessee is a public limited

company engaged in the business of manufacturing and job work of

bearing races and bush. The books of account are regularly maintained

and audited as per Companies Act and Income-tax Act which was

claimed to be supported by bills and vouchers. The assessee's industrial

activity of manufacturing of ball bearings is liable for levy under Central

Excise Act. During the course of assessment proceedings, the AO was of

the view that assessee's record contained some discrepancies as assessee

was not maintaining quality was stock register of raw material; oil and

lubricants and stock consumption; separate trading of manufacturing and

job work charges was not maintained; job work payment to sister

concerns were not be cross-verifiable and the reasonableness of the

payments was not justified. Excise Register (ER-1), trading account,

scrap generation and yield % were not verifiable. Repairs and machinery

expenses were based on self made vouchers also were not verifiable.

3 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

Assessee filed detailed reply contending that the assessee's method of

accounting, record keeping and excise compliance was same as in earlier

years. Similarly the issues about stock register of consumables and stores;

separate trading and manufacturing recorded and job charges were same

as in earlier years. Ld. AO however rejected the books of account and

above additions was made. It may be mentioned that the addition of Rs.

12,87,984/- was telescoped in the total addition of Rs. 93,94,856/-.

Consequently ground no. 2 as raised by the Revenue is included in

Ground No. 1.

2.2 Aggrieved, the assessee preferred first appeal where it was

contended that books of account were duly audited and supported by

records, no specific discrepancies were pointed in the books. Oil and

lubricants and consumable stores were otherwise allowable as revenue

expenditure in the year of purchase. In any case if any stock in this behalf

is found to be undervalued it will only result into increase in closing stock

and corresponding increase in the opening stock of next year. This

exercise will be revenue neutral or merely notional postponement of stock

valuation. The assessee maintains regular ER-1 register under Excise

Rules. The rate of job work paid to associated and non associated

concerns were fully comparable with, earlier years, other job workers and 4 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

comparable cases. As a market practice scrap generated by the job

workers is not returned to the principal. The rate of job charges is fixed

keeping in view the scrap earning of jobbers. As per Excise Rules,

notional Excise Duty is payable by the assessee on such generation of

scrap which is not returned to it. The scrap having not been returned by

the associated concerns as well as non-associated concerns resulted in

difference of quantity and sale value of scrape as per excise and

accounted record, which was properly reconciled. No case of applicability

of Section 40A(2)(b) of the Act has been made out as neither comparable

cases have been cited by ld. AO nor any comparison with earlier years

have been made.

2.3 Apropos allegations about day to day consumption and production

record not maintained, assessee contended that:

The assessee is properly maintaining the consumption and production records and the same were produced before AO during the course of assessment proceedings which emerge from the following facts:-

(i) Tax Audit report where complete quantitative details of raw material and Finished goods are provided.

(ii) Monthwise quantitative details of purchase of raw material consumption of raw material, production of finished goods and scrap, and burning loss filed before the ld AO.

(iii) Monthwise details of Production of scrap vis a vis sales and remained with Job workers filed before the ld AO.

5 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

(iv) Outward/Inward Challan in support of goods issued/received from Job workers were produced before the AO.

(v) The statutory auditors, without any qualification have certified in their reports that the assessee is maintaining proper records of inventory.

Consequently ld. AO erred in rejecting the books of accounts and resorting to estimation of GP and sales.

2.4 The detailed submissions and paper book was supported before the

ld. CIT(A), based thereon ld. CIT(A) and in consideration of various case

laws and the submissions, observed that :-

(i) The assessee having books of account cannot be rejected on the basis of the issues like stock of oil and lubricants and consumables stores etc.

(ii) Similarly, maintaining the consolidated account also cannot be a reason to reject the books of account inasmuch as the assessee has been able to segregate the figures and give break thereof.

(iii) The books of account are maintained on a consistent accounting practice in earlier years and no such rejection has been made. The books of account were upheld.

(iv) AO rejected the books of account in AY 2006-2007 also. But the Hon'ble ITAT found that these are not major defect;

hence the books of account of the assessee cannot be rejected.

6 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

2.5 Apropos, alleged discrepancies in respect of scrap generation, the

ld. CIT(A) held that :-

''3.3 (Page 7) ..... In the present case, there is no evidence that vendors or sub-vendors had returned the scrap to the appellant and same was sold by the appellant outside the books of account. In the case of State Bank of Travancore vs. CIT (158 ITR 102), it was held by the Hon'ble Supreme Court that the concept of reality of the income and the actuality of the situation were relevant factors which went to the making up of the accrual of income. It was also held that what had really accrued to the assessee, had to be found out first and what had accrued must be considered from the point of view of real income taking the probability or improbability of realization in a realistic manner and dovetailing of these factors together. In the present case, no real income accrued to the appellant or was received by it during the year under reference simply because it did not recover or realize the same. As evident, the job workers had not returned the scrap to the appellant. On the contract undertaken by it, M/s. Alankar Automobiles (P) Ltd. had shown the sale of scrap of Rs. 3,30,000/- in its books of account. There was no evidence on the record to suggest that these sub-vendors had ever returned the scrap to the alleged vendor or the appellant itself. The appellant had provided complete names and addresses of these sub-

vendors alongwith other relevant details to the AO. Accordingly, no adverse inference could have drawn against the appellant merely on surmise and conjectures. There was no real income which could be brought to tax in the hands of the appellant on accrual basis on receipt basis. In view of above facts, I direct the AO to delete the addition of Rs. 12,77,984/- made by him. This ground of appeal is allowed.''

2.6 Apropos trading addition, the ld. CIT(A) observed that:

7 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

(i) During the course of assessment proceedings, the assessee had furnished quantitative details of raw materials consumed, finished goods produced, scrap generated and burning loss. Consequently there was no justification in the rejection of books of the assessee.

(ii) The AO's allegation that the job charges paid to sister concerns were in violation of Section 40A(2)(b) was not established by the AO by citing any unreasonableness or comparative cases. Similarly, non-returned of scrap was supported by customary practice.

(iii) Relevant TDS was deducted from the job workers which were duly paid in the Govt. treasury and no discrepancy whatsoever was indicated in this behalf.

(iv) Since the books of account were upheld, there was no question of applying the estimation of gross profit. Besides, assessee's gross profit was better than assessment year 2006-07 and 2007-08. In assessment year 2006-07, ITAT dismissing revenue appeal, in assessee's own case upheld the gross profit rate at declared GP of 14.54%. Thus the assessee gross profit is as long as 14.54%. Therefore, the current year gross profit rate at 26.07% cannot be held to be low.

2.7 Aggrieved, Revenue is before us. Ld. DR supported the order of

ld. AO on the issues of discrepancies in books of accounts, scrape

generation and sale figures and GP addition.

8 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

2.8 Ld. Counsel for the assessee contends that:

(i) Stock details of oils & lubricants and consumables stores cannot be maintained as desired by ld. AO as practically it is not possible to maintain them. These are purchased in limited quantity which is required on daily basis as there storage is risky, their closing stock is minor. These expenses are duly supported by bills and payment made through a/c payee cheques and in any case is revenue in nature. Assessee company has proper internal control system to protect the revenue leakage. This has also been certified by the statutory auditors in their audit report. Without prejudice to above this is to submit that even if stock register is not maintained the books of accounts cannot be rejected on this ground. Reliance is place on following decisions: -

• Ashok Refractories Pvt Ltd Vs CIT (2005) 279 ITR 475 (cal) • Avdesh Pratap Singh v CIT 210 ITR406 (All) • CIT Vs Jas Jack Elegance Exports 324 ITR 95 (Delhi High Court) • CIT Vs Om Overseas 315 ITR 185 (Punjab & Haryana High Court) • Haridas Parikh Vs ITO 113 TTJ 274 (ITAT Jodhpur Bench) • Vishal Infrastructure Ltd Vs ACIT 104 ITD 537 ITAT Hyderabad Bench.

• CIT Vs Smt Poonam Rani 326 ITR 223 Delhi High Court • Ashok Kumar & Co, Vs ITO 2 SOT 518 ITAT Amritsar Bench • Malani Ramjivan Jagannath 316 ITR 120 9 ITA No. 758/JP/2012

ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

(ii) Understatement of Sales by Rs. 12,77,984/-

Ld. AO has not relied on any material indicating any sale outside books, its only based on presumption based on ER-1, which is not a return of sales but only return of computation of excise duty. The sales of MS scrap as per books of account of assessee was Rs. 65,07,100/- while as per ER-1 the "quantity cleared" is of Rs. 77,85,084/-. The reason of difference of Rs. 12,77,984/- is that the assessee was sending goods for Job work also and the scrap generated during production by job worker remains with job worker and the job worker were the beneficial owner of that scrap and it is a part of job cost to the assessee. Since assessee is liable for notional ad volarem excise duty thereon, it has to show the value of scrap remained with Job worker also in ER-1. This is the reason there is mismatch in these two different statutory parameters. Therefore the ld AO has no material to presume that the assessee has made sales outside the books.

iii) Separate trading a/c of job work and manufacturing not maintained

This is not a defect in maintenance in books for which books of accounts can be rejected. The assessee gets the job work done from outside parties, it common manufacturing facility for goods manufactured for trading purpose and goods received for job work. Since books of accounts are and expenditure are inseparable and common, it is not practically possible to prepare the separate 10 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

trading and profit & loss a/c of job work and manufacturing goods cannot be prepared. This is a regularly and consistently accounting practice by the assessee. Assessee maintains regular register with relevant entries of goods for job work and return after job work, supported by challans; no adverse finding whatsoever in this behalf.

iv) Issue about sister concerns job work

The payments of job charges made to sister concerns are supported by their bills made through account payee cheques at the same rates payable to unrelated jobbers, after deducting applicable TDS. The goods are issued for job work through challans and received back also through challans. Ld. AO has not pointed out even single instance where the payment to sister concern is found to be comparably unreasonable.

v) Apropos scrap remaining with the Job workers, this trade practice is accepted by the department in previous assessments (Scrutiny assessment for AY 2005-06 and AY 2006- 07 & AY 2012-13. Therefore there is no justification in AO allegation that sister concerns have been benefited in terms of sec. 40A 2(b). The assessee has neither received scarp from the sister concern nor from the other parties. During the course of assessment proceedings assessee submitted bills of Job charges paid to sister concerns as well as outside parties to justify that rate of job charges paid to sister concern and other parties. They remain 11 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

uncontrovered, therefore, ld. AO is not justified in holding that payments to sister concern are not reasonable, the burden to furnish comparative cases is on AO which has been wrongly attributed to assessee.

vi) Raw material and finished goods dispatch record

Assessee maintains proper stock records showing the day to day qty detail of goods purchases, issued for production and finished goods & scrap produced. The qty. detail of raw material, finished goods and scrap were submitted before AO similarly it maintains proper records for goods issued for job work and received from job work which is also mandatory in Central Excise rules. Despite copious evidence and compliance ld. AO erred in holding that the assessee is not maintaining challans. The photocopy of the inward and outward challans are placed on paper book.

vii) Scrap generation and yield issue:

During the course of assessment proceeding, assessee submitted month-wise detail of consumption of raw material, finished goods produced and scrap generated. All these details are verifiable from books, therefore, this is not a case to hold that yield and scrap are not verifiable. The complete stock records showing day to day details of input and outputs along with supporting bills, vouchers and challans were produced before AO for verification, which has not been controverted in any objective manner. Ld. AO 12 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

thus erred in holding that yield rate and scrap generation not verifiable from books of accounts.

viii) Alleged concealment of sales

The assessee books of accounts including stock records, sales bills, challans and sales have not been found defective based any instance of unrecorded/concealed sales. Therefore, the finding of concealed sales is grossly wrong and based on assumption and presumption. The difference in amount of MS scrap in ER-1 shown as qty. cleared and sales of MS scrap as per books of accounts has been fully reconciled.

ix) Low GP cannot be ground for rejection of books

The low GP cannot be a ground for rejection of the books of account. Further, the GP of current year was better than AY 2006-

207 and AY 2007-2008. The case of assessee for AY 2006-2007 was finalized in scrutiny and the ld AO estimated GP at 20% as against declared GP rate of assessee 14.54%. The CIT(A) held the GP rate @18% and Hon'ble ITAT upheld the GP declared by the assessee in books of account. Therefore, the assessee's GP is not lower to the past history of the assessee. The past history does not mean immediate preceding year only but the AO should look into the history of the assessee in past few years. Reliance is placed on:

Hon'ble Rajasthan High Court in the case of Malani Ramjivan Jagannath Vs. Assistant Commissioner Of Income Tax (2009) 316 ITR 120 has held as under:-

"10. In the face of these undisputed facts and circumstances, the Tribunal in our opinion could not have interfered with 13 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

the order of CIT(A). In doing so, it had ignored all admitted facts noticed by us above, in the face of which there was no occasion for the AO to have resorted to estimate method. The GP is primarily result of excess of sales over purchases, opening stock, closing stock, the unsold stock at two terminals is only balancing factor. Admittedly out of this four components of trading result, there could not have been any ground for the Revenue to arrive at different result. So far as closing stock is concerned, inventories of existing stock were not found to be incorrect by the AO i.e. that position of stock as shown in the account books was not incorrect. There being no dispute about the sales and purchases, non- maintenance of stock register lost its significance so far as arriving at GP is concerned. Therefore, the CIT(A) was right in his reasoning about admitted state of affairs. Resorting to estimate of GP rate was founded on no material. It was merely a case of making certain additions on the basis of certain defects pointed out by the AO and which he has shown in different account by giving margin of unvouched expenses. He has disallowed certain expenses .

11. The Tribunal committed basic error in not appreciating the reasoning given by the CIT(A). It is trite to say that in the facts and circumstances of present case, account books are maintained as they were ordinarily maintained years after years and which were found to yield a fair result. Mere deviation in GP rate cannot be a ground for rejecting books of account and entering realm of estimate and guesswork. Lower GP rate shown in the books of account during current year and fall in GP rate was justified and also admitted by the AO as well as CIT(A) as well as the Tribunal. Therefore, fall in GP rate lost its significance. Having accepted the reason for fall in GP rate, namely, stiff competition in market and also that huge loss caused in particular transaction, neither the rejection of books of account was 14 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

justified nor resort to substitution of estimated GP by rule of thumb merely for making certain additions. We are, therefore, of the opinion that the findings arrived at by the Tribunal suffers from basic defect of not applying its mind to the existing material which were relevant and went to the root of the matter. When all the data and entries made in the trading account were not found to be incorrect in any manner, there could not have been any other result except what has been shown by the assessee in the books of account. We are, therefore, unable to sustain the order of the Tribunal."

It is submitted that assessee's books of accounts and trading results being

completely verifiable, ld. AO wrongly rejected the books of accounts, ld

CIT(A) after appreciation of all the relevant facts, record, submissions

and law, has rightly upheld the books deleted the additions, his order is

relied on.

2.9 We have heard the rival contentions and perused the material

available on the record. Ld. CIT (A) by elaborate findings held that:-

(i) The assessee's regular books of account cannot be rejected on the basis of the issues like stock of oil and lubricants and consumables stores which constitutes day to day purchases and the stock is comparatively small. Besides such items being inflammable on preponderance of probabilities also can't be stored in huge quantity.

(ii) Similarly, maintaining the consolidated trading account of manufacturing and job work also cannot be a reason to 15 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

reject the books of account inasmuch as they are interconnected.

Assessee deals in manufacturing and job working for self and others.

(iii) The books of account are maintained on consistent accounting practices in earlier years and no such rejection has been made. The books of account were upheld in earlier years.

(iv) AO rejected the books of account in AY 2006-2007 ITAT found that these defects are not major and the books of account of the assessee cannot be rejected on ipse dixit.

(v) Apropos scrap generation, there is no evidence at all to show that vendors or sub-vendors returned the scrap which was sold by the appellant outside the books of account. As evident, the job workers had not returned the scrap to the appellant, sub vendors including M/s. Alankar Automobiles (P) Ltd. had shown income from sale of scrap of Rs. 3,30,000/- in its books of account. There being no evidence on the record to suggest that these sub-vendors had ever returned the scrap to assessee, no adverse inference can be drawn against the appellant merely on surmise and conjectures.

(vi) Apropos trading additions, assessee had furnished quantitative details of raw materials consumed, finished goods produced, scrap generated and burning loss. Consequently there was no justification in the rejection of books of the assessee, therefore no estimation of GP can be resorted to in the given facts and circumstances.

16 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

(vii) The AO's allegation that the job charges paid to sister concerns is in violation of Section 40A(2)(b) was not established by citing any projection of unreasonableness or comparative cases. Similarly, non-returned of scrap by sister concerns is comparable with unrelated concerns and held to be a customary practice in this trade.

(viii) Relevant TDS was deducted from the job workers which were duly paid in the Govt. treasury and no discrepancy whatsoever was indicated in this behalf.

(ix) Since the books of account are upheld, there is no question of applying the estimation of gross profit. Besides, assessee's GP is better than assessment year 2006-07 and 2007-08. In assessment year 2006-07, ITAT dismissing revenue appeal, in assessee's own case upheld the gross profit rate at declared GP of 14.54%. Thus the assessee gross profit is as long as 14.54%. Therefore, the current year gross profit rate cannot be held to be low.

2.10 In similar type of case, ITAT on same facts and circumstances in

the revenue appeal of ACIT vs. M/s. Pushp Enterprises (ITA No.

659/JP/2012 for the assessment year 2009-10) vide its order dated 13-02-

2015, upheld the order of the ld. CIT(A) deleting the additions observing

as under:-

''8. We have heard the rival contentions of both the parties and perused the material available on the record. Apropos the first 17 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

ground i.e. the addition on account of alleged sale of scrap, we find no infirmity in the order of the learned CIT(A) inasmuch as nothing has been brought on record by learned Assessing Officer that the assessee's job workers returned any scrap to assessee. Nothinghas also been brought on record to demonstrate in any way that assessee indulged in any sale of scrap outside the books of account. This is further indicated by new Cenvat Credit Rules, which holds that the scrap was not required to be returned to the assessee. The same is referred to by the judgment in the case of M/s Rocket Engineering Corporation Vs. CCE (supra). The assessee further provided evidence from M/s Noble Industries, which has done a job work of 3.56 crores and has shown the income attributable to sales of scrape of Rs. 747109/-, in its books.

These facts and observations demonstrate that the assessee did not receive any scrap back from job workers. There being no evidence whatsoever suggesting any unaccounted sales by the assessee, the order of learned CIT(A) on these issues is upheld. This ground of revenue's appeal is dismissed.

8.1 Apropos the second ground, which includes the addition amount of Rs. 1,35,56,787/- relating to concealed sale of scrap, the balance amount to difference shown by the assessee as receivable from SKF and the payable amount in the books of SKF, the assessee has demonstrated that the difference was due to the disputes pertaining to defective and inferior quality of goods. The assessee used to account for the actual invoice value whereas the purchases were accounted by SKF not on the basis of the sales bills but on the basis of settled amounts qua these invoices. All these issues have been discussed in details by the learned CIT(A) as mentioned above. In view thereof, we see no infirmity in the order of the learned CIT(A) on this issue also, which is upheld. The second ground of revenue appeal is dismissed.

8.2 Apropos the third ground the assessee demonstrated that as per Rule 4(6) of the Central Excise Rules, the assessee was liable for excise duty on the notional value of nonreturnable scrap. Thus, the assessee has to face the situation where the scrape was not returnable to it and on top of that the excise duty on such scrape was also payable by the assessee as per excise rules. In view thereof, the excise duty in respect of unreturned scrap becomes a statutory/legal liability of the assessee, which is allowable business expenditure. The learned CIT(A) has considered the issue in right perspective and we see no infirmity in its order on this ground, the same is upheld.'' 18 ITA No. 758/JP/2012 ACIT- Circle- 4, Jaipur vs. M/s. Agrasen Engineering Industries Ltd. , Jaipur

2.11 In consideration of all the above facts, circumstances, submissions

and case laws, we see no infirmity in the order of ld. CIT(A) which is

upheld.

3.0 In the result, the appeal of the Revenue is dismissed

Order pronounced in the open court on 26/06/2015.

Sd/- Sd/- ¼Vh-vkj-ehuk½ ¼vkj-ih-rksykuh½ (T.R. Meena) (R.P.Tolani) ys[kk lnL;@ Accountant Member U;kf;d lnL;@Judicial Member

Tk;iqj@Jaipur fnukad@Dated:- 26/06/ 2015

*Mishra

vkns'k dh izfrfyfi vxzfs 'kr@Copy of the order forwarded to:

1. vihykFkhZ@The Appellant- The ACIT, Circle- 4, Jaipur

2. izR;FkhZ@ The Respondent- M/s. Agrasen Engineering Industries Ltd. , Jaipur

3. vk;dj vk;qDr¼vihy½@ CIT(A).

4. vk;dj vk;qDr@ CIT

5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur

6. xkMZ QkbZy@ Guard File (ITA No.758/JP/2012)

vkns'kkuqlkj@ By order,

lgk;d iathdkj@ Assistant. Registrar