Lakhi Gems, Jaipur 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. 637/JP/2012 fu/kZkj.k o"kZ@Assessment Year : 2004-05

I.T.O. cuke M/s Lakhi Gems, Ward 1(1), Jaipur Vs. 395, II Floor, Hanuman Ji Ka Rasta, Johari Bazar, Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAAFL 5913 D vihykFkhZ@Appellant izR;FkhZ@Respondent

izR;k{ksi.k@C.O. No. 39/JP/2013 (Arising out of vk;dj vihy la-@ITA No. 637/JP/2012) fu/kZkj.k o"kZ@Assessment Year : 2004-05

M/s Lakhi Gems, cuke I.T.O. 395, II Floor, Hanuman Ji Ka Rasta, Vs. Ward 1(1), Jaipur Johari Bazar, Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAAFL 5913 D izR;k{ksid@Objector izR;FkhZ@Respondent

jktLo dh vksj ls@ Revenue by : Mrs. Neena Jeph (JCIT) fu/kZkfjrh dh vksj ls@ Assessee by : Shri P.C. Parwal (C.A.)

lquokbZ dh rkjh[k@ Date of Hearing : 17/06/2015 mn?kks"k.kk dh rkjh[k@ Date of Pronouncement : 17/07/2015 2 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

vkns'k@ ORDER

PER: T.R. MEENA, A.M.

The appeal by revenue and cross objection by assessee arise

from the order dated 26/04/2012 passed by the learned CIT (A)-I,

Jaipur for A.Y. 2004-05. The ground of revenue's appeal and grounds of

the assessee's C.O. are as under:-

Ground in Revenue's Appeal.

"On the facts and in the circumstances of the case, especially in view of the fact that purchases are not verifiable and hence sale price is not capable of being linked to the purchase price, whether the ld. CIT(A) was justified in ordering to apply g.p. rate of 17% as against the disallowance of 45,03,020/- representing 25% of unverifiable purchase made by the A.O."

Grounds in Assessee's C.O. "1. The learned Commissioner of Income Tax (Appeals) has erred on facts and in law in upholding the validity of assessment framed u/s 147.

2. The learned Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the action of A.O. in rejecting books of accounts u/s 145(3).

2.1 The learned Commissioner of Income Tax (Appeals) has further erred on facts and in law in confirming trading addition of Rs. 10,61,214/- by applying G.P. rate of 17% as against G.P. rate of 12.61% declared by the assessee."

2. Firstly we take C.O. of the assessee. The assessee filed the

present C.O. belated by 293 days, for which he also filed a condonation 3 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

petition to condone the delay alongwith affidavit of Shri Neeraj Lakhi, a

partner of M/s Lakhi Gems and Shri Gopal Das Ganglani, employee of

M/s Bihari Lal Hola Ram (sister concern) of Lakhi Gems.

3. The ld AR of the assessee argued that this was the mistake of the

employee who got received form NO. 36 served on him on 14/07/2012,

which was misplaced by Shri Gopal Das Ganglani. Therefore, the

assessee has reasonable cause to file the C.O. delayed by 293 days.

4. At the outset, the ld DR opposed the condonation of delay

application as claimed by the assessee that this was the mistake of Shri

Gopal Das Ganglani. She further argued that even form No. 36 was

misplaced in July, 2005 whereas the assessee has asked to supply the

copy of form No. 36 from Hon'ble ITAT on 15/5/2013. There was a

lapse of more than 10 months. If the assertion made by the assessee

was correct, he might have asked to supply the copy of form No. 36

within 1 or 2 months after the misplacement of form No. 36 as claimed

by the assessee. Therefore, there is no reason to condone the delay in

filing the C.O. 4 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

5. We have heard the rival contentions of both the parties and

perused the material available on the record. The assessee filed the

present C.O. on 03/6/2013. Copy of form No. 36 was served on the

employee of sister concern admittedly on 14/7/2012. The AR of the

assessee has not explained day to day delay with reasons in filing of the

C.O. We find merit in the contentions of learned DR. The assessee has

only filed a vague and general affidavit from a partner of the assessee

and employee of the sister concern of the assessee, which utterly lacks

any specific contentions and fails to explain day to day delay in

reasonable manner. It does not conform to general human conduct in

such circumstances, preponderance of probabilities and surrounding

circumstances which form sine qua non in the matters of condonation

of delay. The burden is on the assessee to reasonably explain day to

day delay and establish that there existed reasonable and sufficient

cause in delaying the filing of appeals for about 10 months. If the

proper dates or occasions are not mentioned with proper facts then the

delay cannot be condoned. In this behalf, we rely on the decision of the

Hon'ble Madras High Court in the case of Madhu Dadha Vs. ACIT (2009)

317 ITR 458 (Mad). The Hon'ble High Court has held as under:-

5 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

"Held, dismissing the appeal, that it was clear that the assessee had not explained the cause of delay in filing the appeal, especially when the authorized representative who was given charge to file the appeal had died exactly one year after the last date for filing of the appeal. Even after the death of the authorized representative the assessee had taken more than six months to file the appeal. The assessee had neither given any particular or details in the affidavit as to the date on which the papers were handed over to the counsel for preparing the appeal and on what occasion the assessee enquired about the progress in preparing the appeal and filing it. The assessee had not taken a proper plea to show sufficient cause giving evidence and proof beyond reasonable doubt for the delay. There was no need to interfere with the order of the Tribunal."

In this judgment, the Hon'ble Supreme Court citation i.e. Collector,

Land Acquisition Vs. Mst. Katiji (1987) 167 ITR 471 (SC) has also been

considered. We find merit in the contentions of ld. DR that law helps

diligent and not the indolent as well as the axiomatic delay defeats

equity.

In our considered view that the condonation petition filed by the

assessee and material available on the record, fail to invoke any

confidence, fail to explain reasonable and sufficient cause for 6 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

condonation of long delay of 293 days in filing this C.O. The assessee

has to come clean with all the relevant facts, which happened in the

period of one year. The assessee has to explain all the events and be

specific in the dates. In the entirety of facts and circumstances of the

case, we decline to condone the delay of 293 days in filing this C.O.

6. Now we are deciding the C.O. on merit. Ground No. 1 of the C.O.,

the assessee challenged the reopening the case U/s 147 of the Income

Tax Act, 1961 (in short the Act). The ld AR of the assessee has drawn

our attention on reasons recorded by the Assessing Officer for

reopening as under:-

(i) On the basis of annexure 25 to 28 proceedings u/s 147 for A.Y. 2003-04 was initiated. Annexure 25 pertains to A.Y. 2004-05. As per information gathered in survey and finding given in A.Y. 2006-07 and 2003-04, income chargeable to tax for the year under consideration has escaped assessment.

(ii) The purchases are unverifiable, since its nature is same as in A.Y. 2003-04, where addition was made. This aspect needs verification and the exact quantum can be ascertained only after verification.

7 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

(iii) There are other issues arising from survey for which return filed for A.Y. 2004-05 required verification for quantification of escaped income.

As per A.R. none of the reasons indicated above has reason to believe

that any income has escaped assessment.. The reopening was on the

basis of annexure-25 to 28, which was impounded during the course of

survey in the case and carried out on 18/5/2003 in group cases of the

firm. Consequently, assessment for the A.Y. 2006-07 was also framed

by the ACIT, Circle-1, Jaipur where these annexures were considered by

the Assessing Officer. On the basis of similar information pertained to

A.Y. 2003-04 and 2004-05, the reopening was made by the Assessing

Officer but the Assessing Officer himself verified these annexures and

found that these are the regular books. Therefore, the ld Assessing

Officer did not have reason to believe that income has been escaped to

assessment. He relied on the decision in the cases of M/s Gupta

Abhushan P. Ltd. Vs ITO (2008) TIOL 96, ITAt Delhi, Bakulbhai

Ramanlal Patel Vs. ITO (2011) 56 DTR 212 (Guj) (HC) and CIT Vs.

Mahesh Gum and Industries (2007) 292 ITR 397 (Raj.) and argued that

reopening U/s 147 is illegal, bad in law and same is required to be

quashed.

8 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

7. At the outset, the ld DR supported the order of the CIT(A) as

there was no scrutiny U/s 143(3) of the Act in A.Y. 2004-05 and Hon'ble

Supreme Court decision in the case of ACIT Vs. Rajesh Jhaweri Stock

Brokers (P) Ltd. (2007) 291 ITR 500 (SC) and held that order U/s 143 is

not an order and no opinion has been form by the Assessing Officer

U/s 143(1) of the Act. There was a survey in the case of group concern

of the assessee where the information was collected by the department

that the assessee has taken bogus bills to inflate the purchases.

Therefore, the assessee's ground may please be dismissed.

8. We have heard the rival contentions of both the parties and

perused the material available on the record. In this case, the order U/s

143(1) was passed. There was a reason to believe that the assessee

has inflated the purchases by accepting bogus bills from the market on

which this case was reopened and quantified additions were made by

the Assessing Officer after verification as the Hon'ble Supreme Court in

various cases has held that reason to believe does not have certainty

that Assessing Officer in each and every case should have made

addition but there should be prima facie believe of escapement of

income. The finding given by the ld CIT(A) had not controverted by the 9 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

AR. The subsequent year finding as held in (2012) 343 ITR 188 (Bom)

can be reason in reopening wherein ld Assessing Officer had made the

addition on account of bogus purchases by rejecting the books of

account U/s 145(3) of the Act, which has been confirmed by the ld

CIT(A), therefore, we dismiss this ground of appeal.

9. The 2nd ground of C.O. is against challenging the rejection of

book U/s 145(3) of the Act. It is submitted by the AR that the assessee

had maintained complete day to day books of account, which are

subject to audit. All the transactions of purchases and sales are fully

verifiable from the supporting bills, vouchers and documents maintained

by the assessee. The assessee made purchases with full vouchers. The

supplier was registered in the sales tax department. The payments were

made through account payee cheque. The addresses of the supplier is

on the bill. The assessee had filed the confirmation of the purchases.

The assessee has discharged his burden of proof, therefore, books of

account rejected U/s 145(3) of the Act is not justifiable.

10. At the outset, the ld DR has supported the order of the ld CIT(A)

and she further argued that as per form No. 35, the assessee has not

taken specific ground before the ld CIT(A) even she has confirmed the 10 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

rejection of books of account U/s 145(3), therefore, assessee's ground

is not maintainable under the law.

11. We have heard the rival contentions of both the parties and

perused the material available on the record. The assessee raised this

ground before us. On verification of form No. 35, there was no specific

ground on rejection of books U/s 145(3) of the Act. Further the Hon'ble

Rajasthan High Court as well as the Coordinate Bench of the ITAT,

Jaipur in various cases of gems and jewellery business has held that

the book result is not reliable and accordingly Assessing Officer's action

U/s 145(3) is justified. The detailed findings on this issue has been

given by this Bench in the case of Shri Anuj Kumar Varshney Vs. ITO in

ITA No. 187/JP/2012 order dated 22/10/2014.

12. Ground No. 3 of the C.O. and sole ground of the revenue's appeal

are against confirming the trading addition of Rs. 10,61,214/- by

applying G.P. rate of 17% as against the G.P. rate of 12.61% declared

by the assessee and deleting the addition by applying the G.P. @ 17%

as against the disallowance of Rs. 45,03,020/- @ 25% on unverifiable

purchases made by the Assessing Officer. The ld Assessing Officer

observed that the original return declaring total income at Rs.

11 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

2,93,130/- was filed on 1/11/2001. The assessee deals in the business

of precious and semi precious stones. This case was not scrutinized U/s

143(3) of the Act. In group cases of M/s Bihari Ram Hola Ram, Lakhi

Gems and Khushboo Jewellers, survey operations U/s 133A were carried

out on 18/08/2005. From the various annexures impounded during the

course of survey, it is revealed that the firm and its partners were

booking bogus purchases from various bill providers. Subsequent to the

survey, scrutiny assessments in the case of assessee for the A.Y. 2003-

04, 2005-06 and 2006-07 had been framed by the Assessing Officer

wherein finding was given that the assessee has also procured bogus

bills. The ld CIT(A) also confirmed the findings. The ld Assessing Officer

recorded the reasons U/s 147 of the Act and issued notice U/s 148,

which was responded by the assessee. A detailed questionnaire dated

24/10/2011 was issued by the Assessing Officer to the assessee on

decline in G.P. as well as bogus purchases made by the assessee. The

G.P. rate during the year had come done from 14.75% in preceding

year to 12.61% in year under consideration. There was a bogus

purchases to the tune of Rs. 1,80,12,079/- from the following parties:

12 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

S.No. Name of Address of PAN SCT/RST/TIN Amount Rs.

supplier supplier No. 1. A R Exports 227, Sumer 1423/05398 2,149,076 Karn Ji Ka Rasta, Ramganj, Jaipur 2. Adinath 3613, MSB Ka AAMPJ204A 8632250994 1,726,704 Gems Rasta, Johari Bazar, Jaipur 3. Ambika B-20, Ratna AHHPS3389N 1451/01301 370,521 Impex Sagar, MSB Ka Rasta, Johari Bazar, Jaipur 4. Creative B-12, Ratna 413,427 Gems Sagar, MSB Ka Rasta, Johari Bazar, Jaipur 5. Creative 1145, Barkat AAHPV1885S 8092105791 244,470 International Nagar, Tonk Road, Jaipur 6. DJ Impex 1447, Jadiyon ABEPV9059R 8702252275 1,859,732 Ka Rasta, Chaura Rasta, Jaipur 7. Esdire 2305, ACPPV5572R 8252253531 `269,346 International Chandrawat House, Johari Bazar, Jaipur 8. GV Gems 470, Barkat ABOPH3714H 8762108187 528,403 International Nagar, Tonk Road, Jaipur 9. Govindam 1307, Kedia ACGPV1316E 8842251994 1,392,102 Jewellers Building, Johari Bazar, Jaipur 10. MD Exports B-20, Ratna AAEFM9181C 1451/10306 480,383 Sagar, MSB Ka Rasta, Johari Bazar, Jaipur 11. MV Gems 1206, Khejron 8471705845 1,189,702 International Ka Rasta, Chandpole Bazar, Jaipur 12. Manviya C-55, Ambabari, ABQPV5586M 1424/05399 782,908 Exports Jaipur 13 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

13. Nidhi Gems 8, Keshav Vihar, AAQPV3502L 8691605717 470,295 Sitabari, Tonk Road, Jaipur 14. Nikki 3328, Jailal ACAPB0937B 8851705442 1,079,501 Enterprises Munshi Ka Rasta, Chandpole Bazar, Jaipur 15. Puja Exports 93, Mahesh 8182105790 211,041 Nagar, Shiva Colony, Tonk Road, Jaipur 16. Rahul Exports 2253, AHAPR6059E 8642251425 1,411,504 Gheewalon Ka rasta, Johari Baaar, Jaipur 17. Riddhi Siddhi 62/415, Shipra 8441758775 1,650,153 Gems Path, Mansarovar, Jaipur 18. Sahil 115, Vardhman 8912251519 344,385 Diamonds P Chamber, Ltd. Johari Bazar, Jaipur 19. Sapna gems 1/665, Malviya AAUPJ6771H 8581604856 1,133,389 Nagar, Jaipur 20. Triveni Gems 1538, Nagawala 8641600652 305,037 House, Sonthliwalon Ka Rasta Total Unverifiable Purchases 1,80,12,079

The ld AR submitted before the Assessing Officer that the assessee

made these purchases and paid these parties through account payee

cheques. The assessee furnished confirmation and claimed that the

payments were made through account payee cheques. The purchases

made from the relative under the provisions U/s 40A(2)(b) of the Act,

the price was reasonable. The assessee also furnished addresses in all 14 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

the parties and PAN in some of the cases. After considering the

assessee's reply, the ld Assessing Officer observed as under:-

i) Though the assessee has quoted the PAN No. of the suppliers, yet the fact of transfer of goods mentioned in the bills to the assessee is not subject to verification;

ii) The business does not exist at the notified address. No new address has been provided by the assessee for further verification. The summons issued has been returned unserved.

iii) From the Dak returned by the postal authorities it is evidenced that the assessees do not exist at the given address. It is evident that these suppliers are mere fake bill providers.

iv) The assessee has not maintained any stock register on day to day basis so as to verify the day to day movement of the stock.

v) The entire exercise is made with a view to verify the correctness of each of the entries made in the trading account which culminates in the determination of the gross profit. If the correctness of any one entry of the trading account is found to be incorrect, then it will have a bearing

15 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

on the gross profit declared because it is arrived at by arithmetical calculations.

vi) The observations of formalities on paper, like TIN, RCST/CST No./PAN, Bank account are part of the modus operandi to run the racket of issuing bogus bills. All the documents bear an address, but the supplier is not found at the given address. Moreover, payment by cheque is neither sacrosanct nor can it make a non-genuine transaction as genuine for which reliance is placed on the judgment of CIT vs. Precision Finance (P) Ltd. [208 ITR 465 (Cal)].

vii) Reliance is also placed on the judgment of M/s Kachwala Gems Vs. JCIT[ITD No. 134, ITAT, Jaipur Bench (Dec. 2003)] wherein it was held that the A.O. is entitled to act on material which may not even be accepted as an evidence as the A.O. is not bound by the technical rules of Evidence and Pleadings. The Hon'ble ITAT has also held that the declaration of sales under Sales Tax Act and non-production of books of accounts by the seller will not lead the conclusion that the sales are genuine in a case wherein A.O. comes to the conclusion that the relevant purchases are non-genuine in the case of the assessee. The Hon'ble ITAT has also held that the payment by account payee cheque is not sufficient to establish the genuineness of the purchaser.

16 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

viii) Under section 101, 102 and 106 of the Evidence Act, onus lies upon the assessee to prove all the expenses including purchases to the satisfaction of the Assessing Officer, which was not discharged by the assessee as it failed to produce the suppliers from whom purchases have been claimed. The onus lies upon the assessee to prove the genuineness of the transaction when such purchases are claimed to the genuine by it. Reliance is placed in the case of Indian Woolen Carpet Factory Vs. ITAT 178 CTR 420 (Raj).

ix) The assessee has argued that if any discrepancy in the purchases is noticed, then it should be treated to have been merged with the assessment for the survey year where surrender/addition on account of unexplained stock. This argument has no force. Assessee himself has admitted that he is not maintaining any quantitative details. Therefore, it is not ascertainable that the goods purchased before 31/3/2004 is available with the assessee in subsequent years. Assessee's argument is baseless.

Thereafter he rejected the book result U/s 145(3) of the Act and applied

25% on bogus purchases of Rs. 1,80,12,079/- and Rs. 45,03,020/- was

added to the total income of the assessee.

13. Being aggrieved by the order of the Assessing Officer, the

assessee carried the matter before the ld CIT(A), who had confirmed 17 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

the addition @ 17% on total sale turnover and net addition of Rs.

10,61,214/- was confirmed. The finding of the ld CIT(A) is reproduced

as under:-

"5.3 I have carefully perused the order of the A.O. and the submissions of the AR. It is a fact that the appellant was not able to verify the purchases made from 20 parties against whom department had gathered information of being entry providers. Thus these purchases could not be verified and the Hon'ble ITAT, Jaipur Bench has consistently held in the case of gems and jewellery trader/manufacturers that unverifiable purchases are sufficient grounds for invoking provisions of section 145(3). Therefore, the rejection of the books of the account of the appellant as unreliable u/s 145(3) is upheld.

5.4 Regarding the estimation of G.P. the Hon'ble ITAT, Jaipur Bench has consistently held that the past history of the assessee is the most reliable guide. In the case of the assessee it is seen in the A.Y. 2003-04, the assessee had shown a G.P. rate of 14.75% on total turnover of Rs. 1,53,91,516/-. In A.Y. 2005-06, the Hon'ble ITAT upheld the G.P. of 16.16% on total turnover of Rs. 2,55,00,660/-. During this assessment year, it is seen that the turnover at Rs. 2,41,67,327/- is comparable to that in A.Y. 2005-06 in fact it is marginally less. Therefore, given the finding of the

18 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

Hon'ble ITAT for A.Y. 2005-06 it is held to be reasonable to apply a G.P. rate of 17% during this assessment year as the sales turnover has declined and the G.P. generally improves with the decline in turnover. This results in gross profit of Rs. 41,08,446/-. As the assessee has already declared a G.P. of Rs. 30,47,232/- the balance amount of Rs. 10,61,214/- is confirmed as trading addition."

14. Now the revenue in appeal and assessee in C.O. before us. The ld

AR for the assessee reiterated the arguments made before the lower

authorities as confirmation submitted, PAN and addresses given,

payments were made through account payee cheque and assessee

discharged his burden of proof. Therefore, the addition confirmed by

the ld CIT(A) may please be deleted.

15. At the outset, the ld DR drawn our attention that the Hon'ble

ITAT, Jaipur has decided the issue of bogus purchases in gems and

jewellery in the case of Shri Anuj Kumar Varshney Vs. ITO & others

gems and jewellery cases in I.T.A. No. 187/JP/2012 & other ITAs order

dated 22/10/2014 wherein net profit @ 15% as bogus purchases has

been confirmed by the Hon'ble Bench, but the ld Assessing Officer had

applied NP rate @ 25% by considering the decision of Hon'ble 19 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

Ahmadabad Tribunal in the case of Vegetable Products Ltd., therefore,

she requested to confirm the additions made by the Assessing Officer.

16. We have heard the rival contentions of both the parties and

perused the material available on the record. Similar line of cases, this

Bench has decided in the case of Shri Anuj Kumar Varshney Vs. I.T.O.

and other cases in ITA No. 187/JP/2012 order dated 22/10/2014 where

on unverifiable/bogus purchases 15% disallowances has been decided.

Accordingly, we also apply 15% disallowances on unverifiable purchases

in this case also. The Assessing Officer is directed to recalculate the

income as per above direction.

17. In the result, C.O. of the assessee is dismissed the appeal of the

revenue is partly allowed.

Order pronounced in the open court on 17/07/2015.

Sd/- Sd/- ¼vkj-ih-rksykuh½ ¼Vh-vkj-ehuk½ (R.P.Tolani) (T.R. Meena) U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member Tk;iqj@Jaipur fnukad@Dated:- 17th July, 2015 *Ranjan

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

1. vihykFkhZ@The Appellant- The ITO, Ward 1(1), Jaipur.

20 ITA 637/JP/2012 & CO 39/JP/2013_ ITO Vs. Lakhi Gems

2. izR;FkhZ@ The Respondent- M/s Lakhi Gems, Jaipur.

3. vk;dj vk;qDr@ CIT

4. vk;dj vk;qDr¼vihy½@The CIT(A)

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

6. xkMZ QkbZy@ Guard File (ITA No. 637/JP/2012 & C.O. 39/JP/2013) vkns'kkuqlkj@ By order,

lgk;d iathdkj@Asst. Registrar