RAJENDRA SINGH BHAMBOO, JHUNJHUNU v. DCIT, Jaipur

ITA 136/JPR/2016 | 2010-2011
Pronouncement Date: 10-11-2017 | Result: Partly Allowed

Appeal Details

RSA Number 13623114 RSA 2016
Assessee PAN AACFR3438H
Bench Jaipur
Appeal Number ITA 136/JPR/2016
Duration Of Justice 1 year(s) 8 month(s) 28 day(s)
Appellant RAJENDRA SINGH BHAMBOO, JHUNJHUNU
Respondent DCIT, Jaipur
Appeal Type Income Tax Appeal
Pronouncement Date 10-11-2017
Appeal Filed By Assessee
Tags M/s Rajendra Singh Bhamboo.
Order Result Partly Allowed
Bench Allotted Not Allotted
Tribunal Order Date 10-11-2017
Assessment Year 2010-2011
Appeal Filed On 12-02-2016
Judgment Text
VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCHE S JAIPUR JH DQY HKKJR] U;KF;D LNL; OA JH FOE FLAG ;KNO] YS [KK LNL; DS LE{K BEFORE: SHRI KUL BHARAT JM & SHRI VIKRAM SINGH YAD AV AM VK;DJ VIHY LA-@ ITA NO. 136/JP/2016 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2010-11. M/S RAJENDRA SINGH BHAMBOO D-30 INDRA SINGH JHUNJHUNU. CUKE VS. DCIT CENTRAL CIRCLE-2 JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. AACFR 3438 H VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI K.L. MOOLCHANDANI (ADVOCATE) JKTLO DH VKSJ LS@ REVENUE BY : SMT. ROLLY AGARWAL. (CIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 24.10.2017. ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 10/11/2017. VKNS'K@ ORDER PER SHRI KUL BHARAT JM. THIS APPEAL BY THE ASSESSEE PERTAINING TO ASSESSMEN T YEAR 2010-11 IS DIRECTED AGAINST THE ORDER OF LD. CIT(A)-4 KOTA DA TED 22.12.2015. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS OF AP PEAL:- 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CA SE THE LEARNED AUTHORITIES BELOW HAVE LEGALLY AND FACTUALLY ERRED IN MAKING AND CONFIRMING THE 'TRADING ADDITION' BY APPLYING NP RATE IN THE ASSESSMENT PROCEEDINGS COMPLETED U/S 153A READ WITH SECTION 143(3) OF THE ACT. LEGALLY NO VALID ADDITION OF REGULAR A SSESSMENT CAN BE MADE WITHIN THE MEANING OF SECTION 153A OF THE A CT AS ENVISAGED AND INTERPRETED BY NUMBER OF JUDICIAL AUTHORITIES O N THE POINT; PARTICULARLY IN ABSENCE OF ANY INCRIMINATING MATERI AL DETECTED DURING THE COURSE OF SEARCH OPERATIONS. IN THE CIRCUMSTANC ES NO ADDITION IS CALLED FOR U/S 153A OF THE ACT AND ENTIRE ADDITION DESERVES TO BE DELETED SOLELY ON THIS GROUND ALONE. 2 ITA NO. 136/JP/2016. M/S RAJENDRA SINGH BHAMBOO JHUNJHUNU. 2 WITHOUT PREJUDICE TO THE ABOVE OBJECTION ON MERI TS ALSO NO ADDITION IS CALLED FOR IN THE CASE AND IS OBJECTED TO ON THE FO LLOWING GROUNDS: (A) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE LEARNED CIT(A) HAS LEGALLY AND FACTUALLY ERRED IN C ONFIRMING THE AO'S ACTION OF INVOKING PROVISIONS OF SECTION 1 45 OF THE I.T. ACT 1961 WITHOUT POINTING OUT ANY SPECIFIC DE FECT IN THE MAINTENANCE OF BOOKS OF ACCOUNT PARTICULARLY WHEN NO INCRIMINATING MATERIAL INDICATING UNDER-STATEMENT O F INCOME WHAT-SO-EVER COULD BE FOUND DURING THE COURSE OF SE ARCH OPERATIONS. IN ABSENCE OF ANY SPECIFIC DEFECT OR DI SCREPANCY THE PROVISIONS OF SECTION 145 OF THE ACT CANNOT BE INVOKED. THUS THE ADDITION SO MADE BY INVOKING SUCH SECTION AND CONFIRMED BY THE LD. CIT (A) IS BAD IN LAW AND DESE RVES TO BE DELETED. (B) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE LEARNED CIT(A) HAS LEGALLY AND FACTUALLY ERRED IN C ONFIRMING AO'S WORKING OF THE ADDITION BY APPLYING NET PROFIT RATE OF 8.5% IGNORING THE FACT THAT THE ACTUAL INTEREST PA YMENTS OF RS. 1 46 22 346/- AS SHOWN AND CLAIMED BY THE APPELLANT WERE INCORRECTLY TAKEN AT RS. 72 08 314/- WITHOUT ASSIGNING ANY REASON. IN THE CIRCUMSTANCES THE INCOME OF THE APPELLANT HAS BEEN OVER-COMPUTED BY RS. 74 14 034/-. IN THE APPEAL ORDER THE LD. CIT (APPEAL) HAS CONFIRME D THE WORKING OF THE AO WITHOUT ADDRESSING THIS FACT. IN THE CIRCUMSTANCES THE WORKING AS CONFIRMED BY THE LD. CIT (A) IS FACTUALLY INCORRECT AND DESERVED TO BE MODIFIED BY ALLOWING THE CORRECT INTEREST PAYMENTS OF RS. 1 46 22 346/-. 3. THE APPELLANT CRAVES THE RIGHT TO ADD AMEND AND ALTER THE GROUNDS ON OR BEFORE THE HEARING. 2. BRIEFLY STATED THE FACTS ARE THAT A SEARCH & SE IZURE ACTION U/S 132 OF THE ACT 1961(HEREINAFTER REFERRED TO AS THE ACT) WAS CARRIE D OUT ON THE MEMBERS OF BHAMBOO GROUP ON 15.03.2012 OF WHICH THE ASSESSEE I S ONE OF THE MEMBERS. IT IS OBSERVED BY THE ASSESSING OFFICER THAT DURING THE C OURSE OF SEARCH ACTION THE CASH JEWELLERY VALUABLES STOCK-IN-TRADE DOCUMENTS BO OKS OF ACCOUNT AND/OR LOOSE PAPERS WERE FOUND AND SEIZED FROM THE PREMISES OF T HE MEMBERS OF THE BHAMBOO 3 ITA NO. 136/JP/2016. M/S RAJENDRA SINGH BHAMBOO JHUNJHUNU. GROUP. SUBSEQUENTLY A NOTICE U/S 153(A) WAS ISSUE D AND SERVED UPON THE ASSESSEE IN RESPONSE THERETO THE ASSESSEE FILED A RETURN DECLARING AN INCOME OF RS. 5 19 62 170/-. THE ASSESSING OFFICER FRAMED ASSESS MENT U/S 143(3) R.W.S. 153A OF THE ACT. THEREBY THE ASSESSING OFFICER MADE ADDIT ION BY REJECTING THE BOOKS OF ACCOUNTS AND ADOPTING NET PROFIT RATE OF 8.50% ON G ROSS OF RS. 987819443/-. AGGRIEVED BY THIS THE ASSESSEE PREFERRED AN APPEAL BEFORE LD. CIT(A) WHO AFTER CONSIDERING THE SUBMISSIONS DISMISSED THE APPEAL. NOW THE ASSESSEE IS IN FURTHER APPEAL BEFORE THIS TRIBUNAL. 3. GROUND NO. 1 IS AGAINST MAKING CONFIRMATION OF ADOPTING NP RATE WITHOUT APPRECIATING THE FACT THAT NO INCRIMINATING MATERIA L WAS DETECTED DURING THE COURSE OF SEARCH OPERATION. 3.1 LD. COUNSEL FOR THE ASSESSEE VEHEMENTLY ARGUED THAT THE AUTHORITIES BELOW WERE NOT JUSTIFIED IN FRAMING THE ASSESSMENT AS THE RE WAS NO MATERIAL. LD. COUNSEL REITERATED THE SUBMISSIONS AS MADE IN THE WRITTEN S UBMISSIONS. THE SUBMISSIONS OF THE LD. COUNSEL ARE REPRODUCED AS UNDER:- IT IS A SEARCH CASE. IN THIS CASE SEARCH OPERATION S WERE CARRIED OUT ON 15.3.2012. CONSEQUENT UPON THE SEARCH OPERATIONS T HE ASSESSMENT PROCEEDINGS U/S 153A OF THE ACT FOR THE BLOCK PERIO D INCLUDING THIS YEAR WERE INITIATED AS MENTIONED IN THE BODY OF THE ASSESSMEN T ORDER ITSELF. IN COMPLIANCE TO SUCH NOTICE U/S 153A OF THE ACT RETU RN OF INCOME WAS FILED SHOWING THEREIN THE SAME INCOME OF RS.5 19 62 170/- AS DECLARED IN THE ORIGINAL RETURN FILED ON 11.10.2010. AS NO INCRIMINATING MATERIAL PERTAINING TO THIS YEAR WAS FOUND AND SEIZED IN THE SEARCH OPE RATIONS SO NO UNDISCLOSED INCOME PERTAINING TO THIS YEAR WAS DECL ARED BY THE ASSESSEE AS MENTIONED IN PARA 5 OF THE ASSESSMENT O RDER ITSELF. 4 ITA NO. 136/JP/2016. M/S RAJENDRA SINGH BHAMBOO JHUNJHUNU. 2. DURING THE COURSE OF ASSESSMENT PROCEEDINGS THE LEARNED AO HAD OBSERVED THAT THE NP RESULTS SHOWN FOR THE YEAR WER E SLIGHTLY LOW. ACCORDINGLY IT WAS PROPOSED TO MAKE TRADING ADDITIONS ON ESTIMA TE BASIS AFTER REJECTING THE BOOK RESULTS U/S 145(3) OF THE ACT FOR CERTAIN 'ROUTINE AND GENERAL DEFICIENCIES LIKE: (I) NON-MAINTENANCE OF THE STOCK REGISTER (II) NO RECORD OF THE CONSUMPTION OF MATERIAL ON DAY TO DAY BASIS (II I) NON-MAINTENANCE OF SITE WISE ACCOUNTS AND (IV) UNVOUCHED AND UNVERIFIABLE P URCHASES OF SOME ITEMS LIKE SAND STONES GREET EARTH WORK ETC. (KINDLY R EFER TO PARA 8 OF THE ASSESSMENT ORDER). THE PROPOSED ADDITION WAS VEHEME NTLY OBJECTED ON LEGAL GROUNDS DETAILED AS UNDER: 'FROM THE SEARCH PROCEEDINGS IT WOULD BE NOTED THA T NO INCRIMINATING MATERIAL WHAT-SO-EVER PERTAINING TO THE A.Y. 2010-13 WAS FOUND AND SEIZED. IN THE CIRCUMSTANCES NO VALID ADDITION CAN BE MADE WITHIN THE MEANING OF SECTION 153C READ WITH SECTIO N 153A OF THE ACT AS INTERPRETED IN THE FOLLOWING JUDICIAL JUDGM ENTS: (I) SUNCITY ALLOYS (P) LTD. VS. ACIT (2009) 124 TTJ (JD ) 674 - SCOPE OF SECTION 153A (II) ANIL KUNDILIIIHATIA & ORS VS. ACIT (2010) 1 ITR (T RIB) 484 (DEL.) - SCOPE OF SECTION 153A (III) H.C. CHANDNA (P) LTD. VS. DCIT (2004) 91 TTJ (DEL. ) 243 - SCOPE OF SECTION 153A (IV) CIT VS. CHANDRA CHEMOUX (2008) 215 CTR (RAJ.) 43 - SCOPE OF SECTION 153A (V) CIT VS. HARISH BOOB (2008) 215 .CTR (RAJ.) 30 -SCOP E OF SECTION 153A (VI) VINOD KUMAR JAIN VS. ACTT (2004) 91 TTJ (DEL.) 134 SCOPE OF SECTION 153A (VII) ACIT VS. SRJ PEETY STEELS (P) LTD. 53 DTR 347 (PUNE B ) SCOPE OF SECTION 153A (VIII) LMJ INTERNATIONAL LTD. VS. DCIT 22 SOT 315 (CAL.) - SCOPE OF SECTION 15A- HELD THAT 'ITEMS OF REGULAR ASSESSMENT CANNOT BE ADDED BACK IN THE 5 ITA NO. 136/JP/2016. M/S RAJENDRA SINGH BHAMBOO JHUNJHUNU. PROCEEDINGS U/S.153C WHEN NO INCRIMINATING DOCUMENT S WERE FOUND IN RESPECT OF THE DISALLOWED AMOUNTS IN THE SEARCH PRO CEEDING. THUS THE ADDITIONS MADE BY THE AO BEING ALL RELATING TO REG ULAR ASSESSMENT WERE DELETED.' (IX) ANIL P. KHIMANI VS. DCIT 2010-TIOL-177-ITAT-MUM - SCOPE OF SECTION 153A- HELD THAT ASSESSEE ARGUED BEFORE HE TRIBUNAL THAT SINCE NO MATERIAL IS FOUND AS A RESULT OF SEARCH NO ADDITION COULD BE MADE. IT WAS HELD THAT THE POWER GIVEN BY THE PROVISO TO 'ASSESS ' INCOME FOR SIX ASSESSMENT YEARS HAS TO BE CONFINED TO THE UNDISCLO SED INCOME UNEARTHED DURING SEARCH AND CANNOT INCLUDE ITEMS WH ICH ARE DISCLOSED IN THE ORIGINAL PROCEEDINGS. SINCE THE ADDITIONS MADE BY THE AO WAS NOT BASED ON THE MATERIAL FOUND AS A RESULT OF SEARCH THE SAME WAS DELETED. (X) ACIT VS. KAMAL KUMAR S. 'AGRAWAL (INDL.) .& ORS. 4 1 DTR 105(NAG)(TRIB) - SCOPE OF SECTION 153A- HELD THAT 'FOLLOWING SOME ENQUIRIES IN PROCEEDINGS U/S.153A THE A.O. FORMED AN OPINION TH AT THE TRANSACTIONS WERE NOT GENUINE AND TAXED THE SALE PROCEEDS OF SHA RES AS INCOME FROM UNDISCLOSED SOURCES U/S.68. NOT JUSTIFIED. (XI) JAGDISH DUGGAL VS. ACIT 24 DTR 174 (CHD.)(TRIB) - SCOPE OF SECTION 153A- HELD THAT 'NOT JUSTIFIED. REASONS ADVANCED BY THE AO ARE QUITE GENERAL IN NATURE AS SUCH ARTICLES ARE A NORMAL OCC URRENCE IN URBAN HOUSEHOLDS. IN THE ABSENCE OF ANY ADVERSE MATERIAL FOUND DURING SEARCH NO ADDITION COULD BE MADE ON ESTIMATE BASIS. (X) ACIT VS. M/S. ROCHEM SEPARATION SYSTEMS (I) PV T. LTD. 2011-TIOL-334- ITAT-MUM - SCOPE OF SECTION 153A- IT WAS HELD THAT WHEN NO INCRIMINATING DOCUMENTS ARE FOUND IN A SEARCH NEITH ER PROCEEDING NOR SUMMONS ARE ISSUED BY THE AO FOR ANY SPECIFIC DOCUM ENT COMMISSION EXPENSES INCURRED FOR BUSINESS PURPOSE CANNOT BE DI SALLOWED ONLY ON THE BASIS OF ASSUMPTIONS AND PRESUMPTIONS. 6 ITA NO. 136/JP/2016. M/S RAJENDRA SINGH BHAMBOO JHUNJHUNU. 2. BESIDES THE ABOVE LEGAL OBJECTION THE PROPOSAL OF THE LD. AO TO REJECT THE BOOK RESULTS U/S 145 OF THE ACT AND MAKING TRAD ING ADDITION ON ESTIMATE BASIS WAS ALSO OBJECTED ON VARIOUS COUNTS FROM TIME TO TIME AS NO SPECIFIC DISCREPANCY OR ANY MISTAKE WAS POINTED OUT SO THE B OOK RESULTS COULD NOT BE REJECTED ON THE BASIS OF GENERAL OBSER VATIONS OF NON- MAINTENANCE OF THE STOCKS AND DAY TO DAY CONSUMPTIO N OF THE MATERIAL ETC. THE LD. AO HAD HOWEVER COMPLETED THE ASSESSMENT WI THOUT ADDRESSING THE LEGAL OBJECTIONS AND ALSO WITHOUT CO NSIDERING THE OBJECTIONS MADE REGARDING INVOKING OF THE PROVISIONS OF SECTIO N 145(3) OF THE ACT AND TO ESTIMATE THE INCOME ETC. AGAIN WHILE MAKING TRADING ADDITION OF RS.44 93 431/- THE LD. AO HAD PROCEEDED TO COMPAR E THE 'TRADING 'RESULTS ' ON THE BASIS OF PAST HISTORY OF THE APPELLANT BY RE FERRING IRRELEVANT FIGURES OF THE NP RESULTS TO ARRIVE AT THE FINDINGS THAT DURIN G THE YEAR NP RESULTS WERE 'LOW' . ACCORDINGLY HE HAD PROCEEDED TO WORK OUT THE TRA DING ADDITION OF RS.44 93 431/- BY APPLYING NP RATE OF 8.5% SUBJECT TO INTEREST DEPRECIATION AND REMUNERATIONS TO THE PARTNERS. WHILE COMPUTING THE INCOME IN THIS MANNER THE LD. AO HAD INCORRECTLY TAKEN THE FIGURE S OF INTEREST PAYMENTS AT RS.72 08 314/- AS AGAINST ACTUAL INTEREST PAYMENTS OF RS. 1 46 22 346/- AND MADE TRADING ADDITION OF RS.44 93 431/- . AGAIN IN SUCH WORKING HE HAD OMITTED THE INTEREST OF RS.74 14 038/- EARNED ON TH E FDRS PLEDGED WITH THE DEPARTMENTS; DULY ACCOUNTED FOR IN THE P&L A/C. FOR THE REASONS KNOWN TO HIM. SUCH FAULTY WORKING RESULTED IN OVER-ASSESSMEN T OF INCOME BY RS.44 93 431/-. IN FACT DURING THIS YEAR THE NP D ECLARED BY THE APPELLANT WAS 9.25% (INCLUDING INTEREST INCOME EARNED ON THE FDRS PLEDGED WITH THE GOVT. DEPARTMENTS). DUE TO EXCLUSION OF SUCH INTERE ST INCOME WHILE COMPUTING THE INCOME BY THE LD. AO THE NP 7 ITA NO. 136/JP/2016. M/S RAJENDRA SINGH BHAMBOO JHUNJHUNU. 3.2 ON THE CONTRARY LD. CIT(DR) OPPOSED THE SUBMIS SIONS AND STATED THAT DURING THE COURSE OF SEARCH PROCEEDING A PAPER WAS RECOVER ED. LD. CIT(DR) ALSO SUPPORTED THE ORDER OF THE AUTHORITIES BELOW. 3.3 WE HAVE HEARD THE RIVAL CONTENTIONS PERUSED TH E MATERIAL AVAILABLE ON RECORD. DURING THE COURSE OF HEARING LD. D/R HAS PLACED ON RECORD A PHOTOCOPY OF PAPER WHERE CERTAIN FIGURES WERE WRITTEN. LD. AR C OULD NOT CONTROVERT THAT PAPER. THEREFORE WE ARE OF THE CONSIDERED VIEW THAT AUTHO RITIES BELOW WERE JUSTIFIED IN INVOKING THE PROVISIONS OF SECTION 153A OF THE ACT. THEREFORE GROUND NO. 1 IS DISMISSED. 4. GROUND NO. 2 IS AGAINST REJECTION OF BOOKS OF ACCOUNT AND ADOPT ING THE NET PROFIT. 4.1 LD. COUNSEL FOR THE ASSESSEE REITERATED THE SUB MISSIONS AS MADE IN THE WRITTEN SUBMISSIONS AND CONTENDED THAT THE REJECTIO NS OF BOOKS OF ACCOUNTS WERE NOT JUSTIFIED IN RESPECT OF GROUND NO. 2(B). HE SUBMIT TED THAT THE NP WORKS OUT AT 9.25%. HE SUBMITTED THAT ADDITION WHATSOEVER IS CAL LED FOR ON THE BASIS OF NP OF 8.5% AS APPLIED BY THE AO. HE SUBMITTED THAT THE A SSESSING OFFICER HAS INCORRECTLY TAKEN THE FIGURES OF RS. 72 08 314/- AS AGAINST AC TUAL FIGURE OF RS. 1 46 22 346/-. HE FURTHER CONTENDED THAT THE ASSESSING OFFICER HAS EXCLUDED THE INTEREST RECEIPTS ON FDRS PLEDGED WITH THE GOVERNMENT DEPARTMENT TO S ECURE THE CONTRACTS. 4.2 ON THE CONTRARY LD. D/R OPPOSED THE SUBMISSION S AND SUBMITTED THAT THE AUTHORITIES BELOW HAVE RIGHTLY EXCLUDED THE INTERES T RECEIPTS ON FDRS AS THE ISSUE HAS BEEN DECIDED AGAINST THE ASSESSEE BY THE HONBL E JURISDICTIONAL HIGH COURT IN 8 ITA NO. 136/JP/2016. M/S RAJENDRA SINGH BHAMBOO JHUNJHUNU. THE CASE OF COMMISSIONER OF INCOME TAX VS. BHAWAL S YNTHETICS (INDIA) UDAIPUR [2017] 81 TAXMANN.COM 478 (RAJASTHAN). 4.3 WE HAVE HEARD THE RIVAL CONTENTIONS. IT IS CONT ENDED BY THE LD. COUNSEL FOR THE ASSESSEE THAT THE ASSESSING OFFICER HAS NOT TAK EN THE CORRECT FIGURE OF THE INTEREST PAID DESPITE THE FACTS THAT PROFIT AND LOS S ACCOUNT WAS BEFORE THE ASSESSING OFFICER. HE SUBMITTED THAT AS PER THE PROFIT AND L OSS ACCOUNT BANK INTEREST AND OTHER CHARGES WAS RS. 1 46 22 348/- HOWEVER THE A SSESSING OFFICER HAS TAKEN RS. 74 14 038/-. HE FURTHER SUBMITTED THAT NO SPECIFIC DEFECTS HAVE BEEN POINTED OUT BY THE ASSESSING OFFICER. HE DREW OUR ATTENTION TO TH E PAPER BOOK PAGE NO. 2 I.E PROFIT AND LOSS ACCOUNTS AS PER THE PROFIT AND LOSS ACCOU NT FURNISHED BY THE ASSESSEE THE BANK INTEREST AND OTHER CHARGES ARE REFLECTED AS RS . 1 46 22 348.16/-. THEREFORE AFTER CONSIDERING THE TOTALITY OF THE FACT WE DEEM IT PROPER THAT THIS ISSUE REQUIRES FRESH DECISION BY THE AO. ACCORDINGLY WE SET ASID E THIS ISSUE OF ESTIMATION OF PROFIT TO THE FILE OF THE AO TO BE DECIDED AFRESH. NEEDLE SS TO SAY THAT AO WOULD PROVIDE SUFFICIENT OPPORTUNITY TO THE ASSESSEE AND MAKE FRE SH ASSESSMENT EXPEDITIOUSLY. 5. IN THE RESULT APPEAL OF THE ASSESSEE IS PARTLY ALLOWED FOR STATISTICAL PURPOSE. ORDER PRONOUNCED IN THE OPEN COURT ON FRIDAY THE 10 TH DAY OF NOVEMBER 2017. SD/- SD/- FOE FLAG ;KNO ( DQY HKKJR ) (VIKRAM SINGH YADAV) ( KUL BHARAT ) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER JAIPUR DATED:- 10 /11/2017. POOJA/ VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 9 ITA NO. 136/JP/2016. M/S RAJENDRA SINGH BHAMBOO JHUNJHUNU. 1. THE APPELLANT- M/S RAJENDRA SINGH BHAMBOO JHUNJ HUNU. 2. THE RESPONDENT- DCIT CENTRAL CIRCLE-2 JAIPUR. 3. THE CIT 4. THE CIT (A) 5. THE DR ITAT JAIPUR 6. GUARD FILE (ITA NO. 136/JP/2016) VKNS'KKUQLKJ@ BY ORDER LGK;D IATHDKJ@ ASSISTANT. REGISTRAR