M/s. JK Traders,, Srinagar v. The Assessing Officer,, Srinagar

ITA 474/ASR/2013 | 2007-2008
Pronouncement Date: 15-04-2014 | Result: Partly Allowed

Appeal Details

RSA Number 47420914 RSA 2013
Assessee PAN AADFJ2687D
Bench Amritsar
Appeal Number ITA 474/ASR/2013
Duration Of Justice 9 month(s) 14 day(s)
Appellant M/s. JK Traders,, Srinagar
Respondent The Assessing Officer,, Srinagar
Appeal Type Income Tax Appeal
Pronouncement Date 15-04-2014
Appeal Filed By Assessee
Order Result Partly Allowed
Bench Allotted DB
Tribunal Order Date 15-04-2014
Date Of Final Hearing 17-04-2014
Next Hearing Date 17-04-2014
Assessment Year 2007-2008
Appeal Filed On 01-07-2013
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH; AMRITSAR. BEFORE SH. H.S. SIDHU JUDICIAL MEMBER AND SH. B.P.JAIN ACCOUNTANT MEMBER I.T.A. NO.474(ASR)/2013 ASSESSMENT YEAR:2007-08 PAN :AADFJ2687D M/S. J.K.TRADERS VS. THE ASSESSING OFFICER NEELAM ROAD WARD-1 KARAN NAGAR SRINAGAR. SRINAGAR. (APPELLANT) (RESPONDENT) APPELLANT BY:MR. M.A. MIR COST ACCOUNTANT RESPONDENT BY:SH.TARSEM LAL DR DATE OF HEARING:09/04/2014 DATE OF PRONOUNCEMENT:15/04/2014 ORDER PER BENCH ; THIS APPEAL OF THE ASSESSEE ARISES FROM THE ORDER OF THE CIT(A) JAMMU DATED 15.03.2013 FOR THE ASSESSMENT YEAR 2007 -08.THE ASSESSEE HAS RAISED FOLLOWING GROUNDS OF APPEAL 1. THE LD. CIT(A) HAS ERRED IN LAW AND FACTS BY CO NFIRMING ADDITION OF RS.98 16 337/- ON ACCOUNT OF UNSECURED LOANS RAISED AND REPAID DURING THE SAME YEAR. THE ADDITION WAS M ADE U/S 68 OF THE ACT WHICH IS BAD IN LAW THUS LIABLE TO BE DE LETED. ITA NO.474(ASR)/2013 2 2. THE LD. CIT(A) HAS ERRED IN LAW AND FACTS BY CON FIRMING ADDITION OF RS.9 10 274/- ON ACCOUNT OF DIFFERENCE IN STOCK. THE ADDITION IS BAD IN LAW UNJUSTIFIED AND LIABLE TO B E DELETED. 3. THE APPELLANT RESERVES THE RIGHT TO AMEND ALTER A DD ANY GROUNDS OF APPEAL. 2. AS REGARDS GROUND NO.1 THE BRIEF FACTS OF THE C ASE AS PER THE ORDER OF THE AO ARE REPRODUCED FOR THE SAKE OF CONVENIENCE AS UNDER: DURING THE YEAR UNDER CONSIDERATION THE ASSESSEE HAS CREDITED RS.98 16 337/- IN THE BOOKS OF ACCOUNT ON DIFFERENT DATES UNDER THE HEAD TEMPORARY ADVANCE ASSESSEE HAS DEBITED THE SAME AMOUNT DURING THE YEAR ITSELF. THE ASSESSEE HAS TO GIVE DE TAIL OF THE NAME AND ADDRESS OF THE PERSONS FROM WHOM THESE ADVANCES TAK EN AND TO PROVE THE GENUINENESS AND CREDIT WORTHINESS OF THE TRANSA CTIONS HAVE BEEN RAISED AS PER THE FOLLOWING DETAIL: S.NO. NAME AND ADDRESS OF THE PERSONS AMOUNT 1. MRS. SHAMIMA RAFEEQI D/O GH. MOHI- UD-DIN R/O SOURA 20 33 000/- 2. M. AMIN SHAH R/O BUCHPORA (NRI) 36 50 000/- 3. MR. MOLVI MUNEER R/O ZAKOORA SRINAGAR 10 00 000/- 4. MRS. SHEEMA D/O AMANULLAH SHAH WAZA BAGH SRINAGAR 5 00 000/- 5. MRS. ZAITOONA D/O GH. MOHI-UD-DIN SOURA 3 60 000/- 6. SHAMIM AHMAD SHAWL D/O M. AMIN SHAWL R/O BACHPORA SRINAGAR 20 00 000/- 7. M.AFZAL LONE RAFIA ABAD BARAMULLA 47 000/- 8. NISAR ENTERPRISES R/O SONAWAR SRINAGAR 1 21 756 /- 9. MR. TARIQ AHMAD LONE R/O BARAMULLA 1 04 581/- TOTAL 98 16 337/- THE ASSESSEE WAS ASKED TO GIVE RELATIONSHIP WITH AL L THE PERSONS FROM WHOM TEMPORARY LOANS HAVE BEEN RECEIVED. THAT WHETH ER ALL THE ITA NO.474(ASR)/2013 3 PERSONS ASSESSED TO TAX AND IF YES PROOF OF THEIR H AVING FILE THE RETURN. THE ASSESSEE IN REPLY TO THE SAME DATED 24.11.2009 HAS GIVEN THE RELATIONSHIP WITH THE PARTNERS OF THE ASSESSEE FIRM WHICH IS AS UNDER: S.NO. NAME AND ADDRESS OF THE PERSONS RELATIONSHIP WITH PARTNERS 1. MRS. SHAMIMA RAFEEQI D/O GH. MOHI-UD-DIN R/O SOURA SISTER IN LAW OF ASHIQ HOSSAIN PARTNER 2. M. AMIN SHAH R/O BUCHPORA (NRI) IIND COUSIN OF ASHIQ HUSSAIN (PARTNER) 3. MR. MOLVI MUNEER R/O ZAKOORA SRINAGAR FRIEND OF ASHIQ HUSSAIN (PARTNER) 4. MRS. SHEEMA D/O AMANULLAH SHAH WAZA BAGH SRINAGAR MRS. OF MUBASHI ASLAM (PARTNER) 5. MRS. ZAITOONA D/O GH. MOHI-UD- DIN SOURA MRS. OF ASHIQ HUSSAIN (PARTNER) 6. SHAMIM AHMAD SHAWL D/O M. AMIN SHAWL R/O BACHPORA SRINAGAR BROTHER IN LAW OF MUBASHIR ASLAM (PARTNER) 7. M.AFZAL LONE RAFIA ABAD BARAMULLA FRIEND OF ASHIQ HUSSAIN (PARTNER) 8. NISAR ENTERPRISES R/O SONAWAR SRINAGAR FRIEND OF ASHIQ HUSSAIN (PARTNER) 9. MR. TARIQ AHMAD LONE R/O BARAMULLA FRIEND OF ASHIQ HUSSAIN (PARTNER) TOT AL : 98 16 337 THE ASSESSEE HAS ALSO DECLARED THAT NO INTEREST HAS BEEN PAID TO ANY OF THE PERSONS FROM WHOM TEMPORARY LOAN HAVE BEEN RECE IVED DURING THE YEAR. AS PER THE ASSESSEE ALL THESE PERSONS ARE NR IS THE ASSESSEE HAS ALSO SUBMITTED VIDE LETTER DATED 24.11.2009 THAT TH E ASSESSEE FIRM IS COLLECTING THE DOCUMENTS FROM WHICH IT CAN BE PROVE D THAT THE LOANEES ARE THE NRIS. THE ASSESSEE REQUESTED FOR SOME MORE TIME AND PROMISED THAT THE NECESSARY DETAILS WILL BE FURNISH ED WITHIN FEW DAYS. HOWEVER THE ASSESSEE HAS FAILED TO FURNISH ANY OF THE DETAILS NOR THE ASSESSEE WAS ALE TO PRODUCE ANY OF THE PERSONS FROM WHOM THE LOANS HAVE TAKEN BY THE ASSESSEE. THE ASSESSEE WAS ASKED TO EXPLAIN AS TO WHY THE CREDITS IN THE BOOKS OF ACCOUNTS VIDE ORDE R SHEET ENTRY DATED 16.12.2009. HOWEVER TILL DATE THE ASSESSEE HAS NOT FURNISHED ANY OF ITA NO.474(ASR)/2013 4 THE REQUISITE PROVES NOR HAS THE ASSESSEE PRODUCED ANY OF THE PERSONS FROM WHOM THE LOANS HAVE BEEN RAISED. SO MUCH SO TH AT THE ASSESSEE HAS NOT EVEN FURNISHED ANY CONFIRMATION LETTER FROM ANY OF THE PERSONS WHO AS PER THE ASSESSE ARE EITHER CLOSE RELATIVES O R THE FRIENDS OF THE PARTNERS. MOREOVER THE ASSESSEE HAS EARLIER STATED THAT THESE AMOUNTS HAVE BEEN RECEIVED FROM M/S. OASIS CHILD DEVELOPMEN T CENTRE KARAN NAGAR SRINAGAR. THE ASSESSEE CLAIMED IT TO B E ITS SISTER CONCERN. IT WAS WHEN THE ASSESSEE WAS CONFRONTED VI DE THIS OFFICE LETTER DATED 13.11.2009 ABOUT THE SOURCE OF THESE AMOUNTS AT THE END OF M/S. OASIS CHILD DEVELOPMENT CENTRE KARAN NAGAR SRINAGAR AND TO EXPLAIN HOW SUCH HUGE AMOUNTS HAVE BEEN GIVEN TO M/S. OASIS CHILD DEVELOPMENT CENTRE WHICH IS NOT EVEN ASSESSE D TO TAX THEN THE ASSESSEE CHANGED ITS EARLIER STAND AND STATED THAT THESE CREDITS ARE LOANS FROM RELATIVES AND FRIENDS. THUS IT IS QUITE CLEAR THAT THE ASSESSEE HAS NO PROPER EXPLANATION TO OFFER. IN VIE W OF THE ABOVE I AM LEFT WITH OTHER OPTION BUT TO TREAT THE AMOUNT OF R S.98 16 337/- AS UNEXPLAINED CREDITS U/S 68 OF THE ACT AND TO ADD TH E SAME TO THE TOTAL INCOME OF THE ASSESSEE SUBJECT TO PENALTY PROCEEDI NGS U/S 271(1)(C) OF THE ACT FOR FURNISHING INACCURATE PARTICULARS OF IN COME. 3. THE LD. CIT(A) CONFIRMED THE ACTION OF THE ASSES SING OFFICER AND THE RELEVANT FINDINGS OF THE LD. CIT(A) ARE REPRODUCED HEREUNDER: I HAVE CONSIDERED THE FINDINGS OF THE AO IN THE AS SESSMENT ORDER AND SUBMISSIONS OF THE ASSESSEE. THERE ARE TWO ADDITION S MADE FOR RS.98 16 337/- AND RS.6 97 181/-. REGARDING THE ADD ITION OF RS.98 16 337/- THE AO IN PARA 4 OF THE ASSESSMENT ORDER HAS MENTIONED THAT THESE CREDITS IN THE BOOKS OF ACCOUN T ON DIFFERENT DATES ARE TEMPORARY ADVANCES RECEIVED FROM VARIOUS PERSO NS MENTIONED IN THE ASSESSMENT ORDER FROM S.NO.1 TO 9. THE AGGREGAT E OF SUCH ADVANCES IS RS.96 16 337/-. DESPITE OPPORTUNITIES GIVEN TO THE APPELLANT BY THE AO. THE APPELLANT COULD NOT FURN ISH THE CONFIRMATIONS AND CAPACITY OF THE LENDERS. THE PREV IOUS COUNSEL OF THE APPELLANT HAS STATED THAT THE LOANS WERE TAKEN FRO M THE VARIOUS PERSONS FROM WHOM AFFIDAVITS WERE FILED. FROM THE PERUSAL OF THE AFFIDAVITS IT IS FOUND THAT PROPER ADDRESSES HAVE NOT BEEN MENTIONED IN THE AFFIDAVITS AND THE MODE OF PAYMENT IS ALSO N OT DISCLOSED AS TO FROM WHICH ACCOUNT THE SAID MONEY WAS ADVANCED. THE PRESENT ITA NO.474(ASR)/2013 5 COUNSEL OF THE APPELLANT VIDE ITS SUBMISSION DATED 13.03.2013 HAS STATED THAT THESE CREDITS ARE NOT LIABLE TO BE ADDE D U/S 68 BECAUSE THE AMOUNT HAVE BEEN DEBITED AND PAID IN THE SAME YEAR AND MORE OVER THE AO HAS REJECTED BOOKS OF ACCOUNT (ANY CREDIT EN TRY IN THE BOOKS HAS NOT RELEVANCE). THUS ADDITION U/S 68 CANNOT B E MADE. THIS IS AN ABSURD EXPLANATION. NEITHER THE PREVIOUS COUNSEL NO R THE PRESENT HAS EXPLAINED AS TO WHY THE CONFIRMATIONS FROM THE LEND ERS WERE NOT FURNISHED BEFORE THE A.O. IN FACT DURING THE COUR SE OF ASSESSMENT PROCEEDINGS THE ASSESSEE HAS CHANGED ITS STAND THA T THE MONEY WAS RECEIVED AS LOAN FROM VARIOUS PERSONS. EARLIER IT WAS SAID THAT IT HAS BEEN RECEIVED FROM M/S. OASIS CHILD DEVELOPMENT CEN TRE KARAN NAGAR SRINAGAR BUT LATER ON STATED TO HAVE BEEN RE CEIVED FROM RELATIVES AND FRIENDS. THE ONUS WAS ON THE APPELLAN T TO PROVE BEYOND DOUBT THE IDENTITY THE CREDITWORTHINESS AND GENUI NENESS OF THE TRANSACTION WHICH WAS NOT PLACING THESE CONFIRMATIO N BEFORE THE AO IN TIME. THEREFORE THE AFFIDAVITS FILED NOW CANNOT BE ACCEPTED UNLESS REASONABLE REASONS PLACED FOR NON-FURNISHING THE SAME BEFORE THE AO IN VIEW OF THE ABOVE DISCUSSION I UPHOLD THAT A DDITION OF RS.98 16 337/- HAS VALIDLY BEEN MADE AND THE GROUND OF THE APPELLANT IS REJECTED. 4. THE LD. COUNSEL FOR THE ASSESSEE MR. M.A.MIR C OST ACCOUNTANT ARGUED THAT THERE IS NO DISPUTE TO THE FACT THAT TH E ASSESSEE HAD RECEIVED THE TEMPORARY LOANS FROM THE RELATIVES AND FRIENDS WHIC H HAVE BEEN PAID DURING THE IMPUGNED YEAR ITSELF. ALL THE PERSONS ARE OF R EPUTE I.E. NRIS AND THIS FACT IS BORNE OUT FROM THE ORDER OF THE AO ITSELF. AS REGARDS THE CONFIRMATION FROM THE SAID PERSONS THE SAME COULD NOT BE FURNI SHED BEFORE THE AO AND SOME MORE TIME WAS REQUIRED FROM THE AO FOR FURNISH ING SUCH CONFIRMATIONS. BEFORE THE LD. CIT(A) THE AFFIDAVIT S WERE SUBMITTED FROM ALL THE PERSONS WHO HAD ADVANCED THE LOANS AND NO DEF ECT IN THE SAME HAS BEEN POINTED OUT BY THE LD. CIT(A). AS REGARDS THE ADDRE SSES OF THE PERSONS WHO ITA NO.474(ASR)/2013 6 ADVANCED THE LOANS ARE AVAILABLE IN THE ORDER OF T HE AO AT PAGE 2 & 3 ITSELF AND THEREFORE THE ALLEGATION THAT PROPER ADDRESSE S ARE NOT AVAILABLE IS AGAINST THE FACTS OF THE PRESENT CASE. THE LOANS HA VING BEEN RECEIVED DURING THE YEAR HAVE BEEN PAID BACK DURING THE IMPUGNED YE AR ITSELF AND THEREFORE NO CASE CAN BE MADE OUT U/S 68 OF THE ACT. THE LD. COUNSEL RELIED UPON THE DECISIONS OF VARIOUS COURTS OF LAW AS UNDER: I) SAROGI CREDIT CORPORATION VS. CIT 103 ITR 344 P ATNA II) TOLA RAM DAGA VS. CIT 59 ITR 632 (ASSAM) III) CIT VS. DAULAT RAM RAWATMULL 87 ITR 349 (SC) IV) CIT VS. SURESH KUMAR 324 ITR 231 (DEL) V) ADDL. CIT VS. HANUMAN AGGARWAL 151 ITR 150 (PATNA) VI) ADDL. CIT VS. BAHRI BROS (P) LTD. 154 ITR 244 (PATN A) THE LD. COUNSEL FURTHER PRAYED TO DELETE THE ADDITI ON SO MADE. 5. THE LD. DR ON THE OTHER HAND RELIED UPON THE O RDERS OF BOTH THE AUTHORITIES BELOW. 6. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. THERE IS NO DISPUTE TO THE FACT THAT THE AMOUNT REC EIVED DURING THE YEAR HAS BEEN REPAID DURING THE YEAR ITSELF. THE SAID AMOUNT WAS RECEIVED FROM NINE PERSONS WHO ARE STATED TO HAVE BEEN NRIS AND HAVE B EEN PAID BACK DURING THE YEAR UNDER CONSIDERATION. THE ASSESSEE COULD NO T FURNISH CONFIRMATIONS ITA NO.474(ASR)/2013 7 AND REQUIRED MORE TIME TO FURNISH SUCH DETAILS. THE REPRESENTATION MADE BY THE LD. COUNSEL FOR THE ASSESSEE THAT THE AMOUNT HA S BEEN RECEIVED FROM M/S. OASIS CHILD DEVELOPMENT CENTRE SRINAGAR WAS GIV EN AS ARGUED BY THE LD. COUNSEL WAS UNDER WRONG BELIEF WHICH WAS RECTIFIE D AND ACCORDINGLY NAMES AND ADDRESSES OF EACH AND EVERY PERSON ALONGWITH RE LATIONS WITH THE ASSESSEE AND THE AMOUNT SO RAISED AS ADVANCED AND REFUNDED B ACK IS ON RECORD AND IS PART OF THE ORDER OF THE A.O. THE ASSESSEE HAVING S UBMITTED AFFIDAVITS FROM EACH PERSON IS ALSO NOT IN DISPUTE. NO DEFECT ON TH E ACCOUNT HAS BEEN POINTED OUT BY THE LD. CIT(A). ACCORDINGLY IN THE FACTS AN D CIRCUMSTANCES OF THE CASE AND DECISIONS OF VARIOUS COURTS OF LAW RELIED UPON BY THE LD. COUNSEL FOR THE ASSESSEE MR. M.A. MIR THE LD. CIT(A) IS N OT JUSTIFIED IN CONFIRMING THE ACTION OF THE A.O. ACCORDINGLY THE ORDER OF TH E LD. CIT(A) IS REVERSED AND THE A.O. IS DIRECTED TO DELETE THE ADDITION SO MADE. THUS GROUND NO.1 OF THE ASSESSEE IS ALLOWED. 7. AS REGARDS GROUND NO.2 THE BRIEF FACTS OF THE C ASE AS PER AOS ORDER ARE REPRODUCED FOR THE SAKE OF CONVENIENCE AS UNDE R: DURING THE COURSE OF ASSESSMENT PROCEEDINGS IT WAS FOUND THAT THE ASSESSEE HAS REFLECTED AN OPENING STOCK OF RS.9 10 274/-. THE PURCHASES DURING THE YEAR ARE OF RS.1 67 776/- AND SALES ARE RS.2 23 722/-. HOWEVER THE CLOSING STOCK REFLECTED IS AT RS.1 95 266/-. THE CLOSING APPEAR TO BE QUITE LOW CONSIDERING THE VOLUME OF THE SALES OF THE ASSESSEE THE CLOSING STOCK IS AS PER THE ST OCK VALUED IN THE SALE TAX ASSESSMENT AND THE ASSESSEE HAS PRODUCED THE T RADING ACCOUNT AS PER THE VAT FOR THE FINANCIAL YEAR 2006-07. IN THAT TRADING ACCOUNT ITA NO.474(ASR)/2013 8 THE CLOSING STOCK IS ON 31.03.2007 IS RS.1 95 000/- AND OPENING STOCK IS RS.2 13 093/-. FROM THE ABOVE DISCUSSION IT IS CLEAR THAT THE ASSESSEE TAKEN THE OPENING STOCK AS PER THE INCOME TAX RETURN FOR THE ASSESSMENT YEAR WHICH IS RS.9 10 274/- (AS PER THE RETURN OF ASSESSMENT YEAR 2006-07) BUT THE CLOSING STOCK AS P ER THE CLOSING STOCK OF VAT RETURN. THE ASSESSEE WAS TO FURNISH TH E EXACT DETAIL OF CLOSING AS ON 31.03.2007 THE ASSESSEE WAS FURTHER ISSUED SHOW CAUSE THAT THE OPENING STOCK MAY NOT BE TAKEN AT RS.2 13 093/- AS PER THE INFORMATION FURNISHED WITH THE VAT RETURN FOR THE F INANCIAL YEAR 2006- 07 AS AN ALTERNATIVE. 3. THE ASSESSEE VIDE LETTER RECEIVED IN THE OFFICE ON 20.11.2009 AS MENTIONED AS UNDER: WE HAVE ALREADY SUBMITTED THE DETAILS OF CLOSING STOCK AS ON 31.03.2007. NOW YOUR GOODSELF ASKS THAT WHY THE OPE NING STOCK MAY NOT BE TAKEN AT RS.2 13 023/- AS THE TRADING AC COUNT FURNISHED WITH VAT RETURNS FOR THE FINANCIAL YEAR 2 006-07. NOW IT IS KINDLY REQUESTED THAT DO WHATEVER GOODSE LF THINKS FIT. IN VIEW OF THE ABOVE REPLY OF THE ASSESSEE IT IS C LEAR THAT THE ASSESSEE NO EXPLANATION TO OFFER. THEREFORE THE BO OKS OF ACCOUNT OF THE ASSESSEE ARE BEING REJECTED AND AN INCOME OF R S.6 97 181/- IS ADDED TO THE TOTAL INCOME OF THE ASSESSEE IS THE DI FFERENCE BETWEEN THE OPENING STOCK AS ON 31.03.2006. THIS INCOME IS ADD ED TO UNDISCLOSED SALES SUBJECT TO PENALTY PROCEEDINGS U/S 271(1)(C) OF THE ACT FOR FURNISHING CONCEALMENT OF INCOME. 8. THE LD. CIT(A) CONFIRMED THE ACTION OF THE ASSES SING OFFICER. 9. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. THE ADDITION MADE IS MAINLY BEING A DIFFERENCE OF T HE OPENING STOCK AS PER INCOME TAX RETURN AND CLOSING STOCK AS PER VAT RETU RN. IT WAS EXPLAINED BEFORE THE LD. CIT(A) AS WELL AS BEFORE US THAT THE LOSS IS DUE TO MOISTURE ITA NO.474(ASR)/2013 9 CONTENTS INVOLVED WITH THE COAL. THE STOCK WAS MAIN LY OF COAL DUST ACCUMULATED FOR OVER MANY YEARS WHICH HAS NO SALE VALUE THAT IS THE REASON THAT SALE HAS BEEN REDUCED TO RS.2 23 272/-. THE AO AS WELL THE LD. CIT(A) HAS REJECTED THE EXPLANATION OF THE ASSESSEE AND HA S REJECTED THE BOOKS OF ACCOUNT. THOUGH THE EXPLANATION SUBMITTED BY THE AS SESSEE HAS A FORCE BUT IN THE ABSENCE OF ANY DOCUMENTARY EVIDENCE AND HAVING REJECTED THE BOOKS OF ACCOUNT ONLY PROFIT ELEMENT CAN BE ADDED ON THE DI FFERENCE OF RS.6 97 181 /- I.E. RS.69 718/- TO THE INCOME INSTEAD OF RS.6 97 1 81/-. THUS GROUND NO.2 OF THE ASSESSEE IS PARTLY ALLOWED. 10. IN THE RESULT THE APPEAL OF THE ASSESSEE IN IT A NO.474(ASR)/2013 IS PARTLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 15TH APRIL 2014. SD/- SD/- (H.S. SIDHU) (B.P. JAIN) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 15TH APRIL 2014 /SKR/ COPY OF THE ORDER FORWARDED TO: 1. THE ASSESSEE:M/S. J.K. TRADERS SRINAGAR. 2. THE A.O. WARD -1 SRINAGAR. 3. THE CIT(A) JAMMU 4. THE CIT JAMMU 5. THE SR DR ITAT AMRITSAR. TRUE COPY BY ORDER (ASSISTANT REGISTRAR) INCOME TAX APPELLATE TRIBUNAL