SHILPA JAIN,JAIPUR vs. ITO WARD 6(A), JPR, JAIPUR

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “B” BENCH, JAIPUR BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI T. R. SENTHIL KUMAR, JUDICIAL MEMBER ITA No.1226/JPR/2025 (Assessment Year:2016-17)

Shilpa Jain Vs. ITO G-20, Jaipur Electronic Ward 6(A), Market, Gopalpura By Jaipur Pass, Jaipur �थायीलेखासं./जीआइआरसं./PAN/GIR No:AKUPJ 4243N Appellant .. Respondent Assessee by : Sh. Ashok Gupta, Adv. & Sh. Puneet Pareek, Adv. Departmentby : Ms. Namita Patel, JCIT Date of Hearing 28.07.2026 Date of Pronouncement 27.10.2026 O R D E R Per Annapurna Gupta, AM:- The present appeal has been filed by the assessee against the order passed by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “Ld. CIT(A)”), dated 04.07.2025 under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

P a g e | 2 ITA No.1226/JPR/2025 Shilpa Jain 2. The grounds raised by the assessee read as under:-

P a g e | 3 ITA No.1226/JPR/2025 Shilpa Jain assessee before us was that the jurisdiction assumed by the AO was invalid, since the reasons recorded for reopening the case of the assessee by the AO reflected complete non-application of mind by the AO to the facts and materials before him. He drew our attention to the copy of the reasons recorded reproduced before us at paper book page No.22-23 referring to the details of information received reproduced at point No.2 as under:- ….. 2. Brief details of information received collected: - As per record Assessee Smt. Shilpa Jain has filed her audit report on 17.10.2016 but has not filed her return of income for A.Y. 2016-17 showing gross income from business/profession Rs.24,65,870/-. Thus, income of Rs. 24,65,870/- is treated as undisclosed income of the assessee for the year under consideration. Therefore, the total become of Rs.24,65,870/- is being treated as escaped income of the assessee for A.Y. 2016-17. ……. 5. He contended that the AO noted from the tax audit report filed by the assessee that the assessee had reflected gross income of Rs.24,65,870/- and since no return of income had been filed, the AO held that income to this extent of Rs.24,65,870/- had escaped assessment. 6. Thereafter Ld Counsel for the assessee drew our attention to the conclusion of the AO at point No.7 referring to the escaped income of Rs.24,65,870/- and noting as under:- ….. 7. Escapement of income chargeable to tax Rs.24,65,870/- In view of the above facts and circumstances, such income i.e. Rs.24,65,870/-, to the extent of such sums, has escaped assessment should be chargeable to tax under section 147 of the Income-Tax Act, 1961. 1, therefore, have reason to believe that the assessee has concealed the particulars of her income for the year under consideration. Therefore, Notice under section 148 of the Income-Tax Act, 1961 is to be issued for initiating the escaped assessment proceedings under section 147 of the Income-Tax Act, 1961.

P a g e | 4 ITA No.1226/JPR/2025 Shilpa Jain 7. Ld. Counsel for the assessee contended that the reasons recorded by the AO of escapement of income of the assessee, for assuming jurisdiction to frame assessment u/s 147 of the Act, revealed that the AO believed escapement of income to the tune of Rs.24,65,870/- which was allegedlythe profit earned by the assessee and which figure was revealed from the tax audit report filed by the assessee, the assessee having not filed any return of income in the impugned year. 8. Taking us now to the copy of the tax audit report furnished before us at paper book page No.9 where the details of turnover, gross profit for the previous year and preceding years were reflected as under:-

P a g e | 5 ITA No.1226/JPR/2025 Shilpa Jain was clear non-application of mind by the AO while recording reasons for escapement of income of the assessee and therefore the jurisdiction assumed by the AO was bad in law to frame assessment u/s 147 of the Act. 10. Ld. DR though was unable to controvert the factual contentions made by the Ld. Counsel for the assessee as above, however he contended that the fact remained as noted by the AO in his reasons also that no return of income filed by the assessee and therefore the belief of escapement of income of the assessee for reopening the case of the assessee was correct, though the quantum noted by the AO was incorrect. He therefore contended that the jurisdiction assumed by the AO was correct to reopen the case of the assessee. 11. We have heard the rival contentions and have perused the documents referring to us. It has been sufficiently established before us from the reasons recorded for reopening the case of the assessee, the AO had incorrectly recorded the gross profit of the assessee to have escaped assessment when undoubtedly the figure of net profit also was available with the AO, since the gross profit figure had been extracted by the AO from the tax audit report furnished by the assessee and the same tax audit report reflected the net profit also of the assessee. The escapement of income therefore of Rs.24,65,870/- recorded by the AO was not correct and as rightly pointed out by the ld. Counsel for the assessee the AO had not applied his mind to the information before him. His belief of escapement of income to the extent of gross profits earned by assessee is

P a g e | 6 ITA No.1226/JPR/2025 Shilpa Jain accordingly found to be without application of mind to the information before him. 12. We accordingly agree with the ld. Counsel for the assessee that the jurisdiction assumed by the AO to reopen the case of the assessee was deficient, without application of mind and accordingly was invalid. The assessment order passed as a consequence therefore we hold does not survive and is directed to be quashed. 13. The ground of appeal No.3 raised by the assessee is therefore allowed. 14. Ground of appeal No.2 and 4 is in relation to the addition made in the hands of the assessee. 15. Though we have quashed the assessment order passed and these grounds raised are therefore mere academic in nature however we shall deal with the same also for completeness purposes. 16. In the assessment framed u/s 147 of the Act, the AO noted that the assessee did not produce any books of accounts or vouchers and accordingly therefore he estimated the profits earned by the assessee by applying the provisions of Section 44AD of the Act estimating the profits at the rate of 8% of the total turnover of the assessee of Rs.8,78,78,428/-. Thus, he estimated the profits earned by the assessee at Rs.70,60,274/-. 17. Further he made addition on account of following to the income of the assessee in the absence of any explanation furnished by the assessee.  Unexplained source of proprietors found Rs.15,56,116/-  Unexplained unsecured loans Rs.19,47,000/-

P a g e | 7 ITA No.1226/JPR/2025 Shilpa Jain  Unexplained loans and advances of Rs.2,18,500/-  Unexplained sundry creditors Rs.8,27,462/- 18. The order of the Ld. CIT(A) reveals that the assessee explained to him that with respect to all the additions made on account of proprietors capitals, sundry creditors, loans and advances all evidences and confirmations have been furnished by the assessee but the AO had failed to take note of the same. With respect to the estimation of profits by applying Section 44AD of the Act, the assessee had contended that Section 44AD of the Act was not applicable in its present case, since the turnover of the assessee far exceeded the limit specified u/s 44AD of the Act for its applicability. 19. Further the assessee had pointed out that the tax audit report itself reflected that the profits returned by the assessee for the impugned year were in consonance with the profits reflected in the preceding year also and therefore also, there was no reason to resort to any estimation of profits. 20. The Ld. CIT(A) however rejected all the contentions of the assessee and confirmed the addition made in the hands of the assessee. 21. We have noted that with respect to each addition made in the hands of the assessee and also with respect to the estimation of profits detailed submissions were filed by the assessee. But the Ld. CIT(A) has summarily rejected the explanation of the assessee without dealing with the specific contentions of the assessee at all.

P a g e | 8 ITA No.1226/JPR/2025 Shilpa Jain 22. With respect to the estimation of profits u/s 44AD of the Act, the submissions of the assessee before the Ld. CIT(A) reproduced in the order of the Ld. CIT(A) at page 3 to 5 of his order as under:- …… Invalid Invocation of Section 44AD in Presence of or with knowledge of Audited Books of Accounts

The Assessing Officer (AO), while passing the assessment order, erroneously invoked the provisions of Section 44AD of the Income Tax Act, 1961. The AO assumed that the applicant had not maintained books of accounts, despite all required documents being available on record. The AO further estimated the applicant's income at 8% of the total turnover (Rs. 70,30,274/-), invoking Section 44AD arbitrarily

It is submitted that Section 44AD is applicable only to eligible businesses with a turnover not exceeding 2 crore in a financial year. In the present case, the applicant's turnover was Rs. 8,78,78,428/-, far exceeding the prescribed threshold under Section 44AD. Hence, the invocation of presumptive taxation is not legally tenable. Moreover, the applicant is an individual engaged in the business of wholesale providing service of Mobile and DTH recharges to retail customers and earns commission on the samewhich is quite meager as compared to the turnover.

The applicant duly complied with the provisions of the Income Tax Act by maintaining proper books of accounts, which were also audited by a chartered accountant as specified in section 44AB. The Tax Audit Report was filed in Form 3CB and 3CD, and the financial statements including the Profit and Loss Account, Balance Sheet, ITR V and Computation of Income were duly submitted during the course of assessment proceedings. The applicant declared a gross turnover of Rs.8,78,78,428/- with a Gross Profit of Rs. 24.65.870/- and Net profit of Rs. 6,76,534/- Copies of the Income Tax Return, Computation of Income, and Statement of Profit and Loss Account are attached as Annexure A for reference.

The AO's reliance on Section 44AD despite the applicant's compliance with Sections 44AB is contrary to the provisions of the Act and judicial precedents. It is respectfully submitted that the addition made under Section 44AD is unsustainable and deserves to be set aside.

For your reference screen short from the Income Tax Website which clearly shows that during filing the Income Tax Audit Report in Form 3CBand 3CD on 30.09.2016 on time balance sheet and profit and loss account for the AY 2016-17 dated 30.09.2016 had been attached.

P a g e | 9 ITA No.1226/JPR/2025 Shilpa Jain

For the above arguments Applicant have placed reliance on following case law:

a. CIT v. Surinder Pal Anand [2010] 192 Taxman 264 (P&H HC):

In this case, the Punjab and Haryana High Court held that where an assessee maintains and submits audited books of accounts, the AO cannot invoke the presumptive provisions of Section 44AD arbitrarily. The court observed that the presumptive scheme is only applicable to businesses with a turnover not exceeding the prescribed threshold ft. 2 crore for the relevant year). It emphasized that auditedaccounts are sufficient compliance and must be relied upon unless proven otherwise. a. CIT v. BanwarilalBanshidhar [1998] 229ITR 229 (All HC)

The Allahabad High Court ruled that when an assessee's books of accounts are audited and submitted, the AO cannot ignore them without proper grounds or verification. The court noted that the rejection of books based on presumptions or arbitrary estimates, without specific defects being pointed out, is unsustainable. It further held that once proper compliance is demonstrated, income should be computed based on the accounts, not under presumptive taxation provisions

b. Aspinwall& Co. Ltd. v. CIT[2001] 251 ITR 323 (SC)

The Supreme Court held that audited accounts submitted under statutory obligations are presumed to reflect the true and correct state of affairs unless the AO identifies specific discrepancies or defects. The court also emphasized that income tax assessments must be based on facts and proper records, and arbitrary estimations are not permissible in the presence of audited financials

In light of the above submissions, it is respectfully requested that the addition of Rs. 70,30,274/- under the head "Presumptive Taxation" be deleted, as it is contrary to the facts of the case. As the applicant had declared the actual profit earned and already paid taxes on the same. The applicant is engaged in the business of wholesale providing service of Mobile and DTH recharges to retail customers wherein profit margin is very low. ……

P a g e | 10 ITA No.1226/JPR/2025 Shilpa Jain 23. With respect to the addition made on account of unexplained proprietors capital, the submission of the assessee reproduced at page 6 and 7 of his order as under:- …… A. Unjustified addition of Rs. 15,56, 116/- as unexplained proprietor'sfund

The AO has made an arbitrary addition of Rs.15,56,116/- under the head "Unexplained Proprietor's Fund" without properly considering the explanation and evidence provided by the applicant during the assessment proceedings.

At the outset, it is submitted that the proprietor's capital account reflects the accumulation of funds introduced into the business over the years, sourced from personal savings, past business earnings, and lawful contributions. The proprietor's fund is an internal account of the business reflecting the owner's contributions. It is a well-settled principle of law that the Cash Credit under Section 68 applies primarily to third-party credits, such as unsecured loans or deposits Additions cannot be made merely on the ground that detailed supporting documents are not available unless the AO identifies specific discrepancies. The arbitrary treatment of the proprietor's capital introduction as unexplained is against the principles of natural justice and lacks merit

Section 68 pertains to unexplained credits and is applicable primarily to third-party transactions. It cannot be invoked without disproving the explanation provided by the applicant for funds introduced into their own business. The reliance on Section 68 in this case is misplaced, as the funds are clearly traceable to the proprietor's own sources, supported by documentation for your reference copy of capital account for the AY 2016-17 alongwith bank statement showing the receipts have been attached herewith as Annexure B Further for your reference the abstract of capital account had already been submitted in the cover letter submitted on 19.02.2024 to your goodself's office.

P a g e | 11 ITA No.1226/JPR/2025 Shilpa Jain

For the above arguments Applicant have placed reliance on following case law

1 CIT v. Metachem Industries [2000] 245 ITR 160 (MP HC)

The Madhya Pradesh High Court held that the proprietor's own funds introduced into the business cannot be treated as unexplained under Section 68 unless the AO conclusively establishes the absence of genuine sources.

1 CIT v. Taj Borewells [2007] 291 ITR 232 (Mad HC):

The Madras High Court ruled that when the capital introduced by the proprietor is supported by plausible explanations and evidence, no addition can be made without disproving the credibility of the sources

In light of the above submissions, it is respectfully requested that the addition of Rs. 15,56,116/- under the head "Unexplained Proprietor's Fund" be deleted, as it is contrary to the facts of the case and very well explained through the bank receipts as well as capital account and audited books of accounts. …… 24. With respect to the addition made of Rs.19,47,000/- on account of unexplained unsecured loan, the submission of the assessee reproduced in the order of the ld. CIT(A) at page 7 and 8 of his order as under:- …… 1. Unjustified addition of Rs. 19,47,000/- as unexplained unsecured loans

P a g e | 12 ITA No.1226/JPR/2025 Shilpa Jain The AO has made an addition of Rs. 19,47,000/- under the head "Unexplained Unsecured Loans" by invoking Section 68 of the Income Tax Act, 1961, treating the loans as unexplained credits. The addition is arbitrary and unwarranted as the applicant had submitted sufficient evidence to substantiate the genuineness of the loans and during the assessment proceedings. Further for your reference a copy ofunsecured loan confirmation from the parties along with their PAN card, ITR V for the AY 2016-17 and relevant bank statements are attached herewith as Annexure C

During the year under assessment assessee has taken unsecured loan from various persons for business needs, the details of the unsecured loan outstanding as on 31.03.2016 are as follows.-

The addition of Rs. 19,47,000/- under the head "Unexplained Unsecured Loans" is arbitrary and contrary to the facts and law. The applicant has discharged the burden of proof by providing all necessary evidence to substantiate the loans. The AO has not provided any material to dispute the genuineness of the loans or the creditworthiness of the lenders By just making addition that the details have not been provided, it is purely unjust and unfair.

For the above arguments Applicant have placed reliance on following case law

The Supreme Court ruled that where the assessee provides all details of lenders and the AO fails to investigate further or disprove the evidence, the addition under Section 68 cannot be sustained

The Gujarat High Court held that an AO cannot make an addition merely due to doubts or suspicions, especially when the loans are routed through banking channels and duly confirmed

P a g e | 13 ITA No.1226/JPR/2025 Shilpa Jain In light of the above submissions, it is respectfully requested that the addition ofRs. 19,47,000 under the head "Unexplained Unsecured Loan" be deleted, as it is contrary to the facts of the case. ……

The AO has made an addition of Rs. 8,27,462/- under the head "Unexplained Sundry Creditors" by invoking Section 68 of the Income Tax Act, 1961, treating the loans as unexplained credits. The addition is arbitrary and unwarranted as the applicant had submitted sufficient evidence to substantiate the genuineness of the loans and during the assessment proceedings. Further for your reference copy of ledger accounts of the sundry creditors and details of payments made to the sundry creditors outstanding as on 31st march to the amount of Rs. 8,27,462/-along with the relevant pages of bank statements showing the payments made to the sundry creditors had been attached herewith as Annexure D.

Details of the sundry creditors outstanding as on 31.03.2016 are as follows:-

P a g e | 14 ITA No.1226/JPR/2025 Shilpa Jain

The addition of Rs. 8,27,462/- under the head "Unexplained Sundry Creditors" is arbitrary and contrary to the facts and law. The applicant has discharged the burden of proof by providing all necessary evidence to substantiate the creditors The AO has not provided any material to dispute the genuineness of the creditors

For the above arguments Applicant have placed reliance on following case law:

1 CIT v. Orissa Corporation Pvt. Ltd. [1986] 159 ITR 78 (SC):

The Supreme Court held that once the assessee provides basic details about the creditors, including their identity and the genuineness of transactions, the burden shifts to the AO to disprove the claim. Additions cannot be made merely based on doubts and assumptions.

1 CIT v. Vishal Exports Overseas Ltd [2012] 252 CTR 10 (Guj HC):

The Gujarat High Court ruled that when creditors are recorded in the books of accounts and the transactions are substantiated with evidence, additions under Section 68 are not justified unless the AO proves that the creditors are fictitious.

In light of the above submissions and supporting judicial precedents, it is respectfully requested that the addition of Rs. 8,27,462/- made under Section 68 of the Income Tax Act be deleted. ….. 26. With respect to the addition of Rs.2,18,500/- as unexplained loans and advances the submission of the assessee reproduced in the order of the ld. CIT(A) at page 10-12 of his order as under:- ….. Unjustified addition of Rs.2, 18,500/- as unexplained loans and advances

The learned Assessing Officer (AO) has made an addition of Rs.2,18,500/- under the head "Unexplained Loans and Advances", treating the amount as unexplained under Section 69 of the Income Tax Act, 1961. The addition is arbitrary and unjustified, as the applicant had duly submitted explanations and supporting documents during the assessment proceedings to establish the nature and source of these advances

Section 69: Unexplained Investment

P a g e | 15 ITA No.1226/JPR/2025 Shilpa Jain "Where in the financial year immediately preceding the assessment year the assessee has made investments which are not recorded in the books of account, if any, maintained by him for any source of income, and the assessee offers no explanation about the nature and source of the investments or the explanation offered by him is not, in the opinion of the Assessing Officer, satisfactory, the value of the investments may be deemed to be the income of the assessee of such financial year."

From above it can be clearly interrupted that investment which are not recorded in Books of Accounts OR No Explanation is offered about the transaction can only be treated as unexplained investment despite recording the transaction in books of accounts and submitting sufficient explanation to the AO had still arbitrarily added the Rs. 2,18,500/- under section 69 of the act as Unexplained Investment.

Details of the Deposits and advance of Rs 2,18,500/- shown in audited balance sheet are as follows:-

For your reference copy of ledger confirmation to the persons to whom advances had been given during the previous year along with the relevant pages of bank statements had been attached here with as

Annexure E

For the above arguments Applicant have placed reliance on following case law:

1 CIT v. Daulat Ram Rawatmull [1973] 87 ITR 349 (SC)

The Supreme Court held that if an assessee provides a reasonable explanationwith supporting documents, the burden shifts to the AO to bring contrary evidence proving that the transactions are non-genuine. Mere suspicion cannot justify an addition

The Rajasthan High Court ruled that advances made in the normal course of business, supported by books of accounts and bank transactions, cannot be treated as unexplained

P a g e | 16 ITA No.1226/JPR/2025 Shilpa Jain under Section 69 unless the AO establishes that the advances were fictitious or unaccounted for In light of the above submissions, it is respectfully requested that the addition of Rs.2,18,500 under the head "Unexplained Loans & Advances" be deleted, as it is contrary to the facts of the case and unsupported by law. ….. 27. The findings of the Ld. CIT(A) rejecting the assessee’s explanation is contained at para 6.2 and 6.2.1 of his order as under:- ….. 6.2 Ground No.2 & 3: In these grounds the appellant has challenged the addition worth Rs. 4330578/- u/s 68 of the Income Tax Act. The AO made the addition as the documentary evidence in support of propritors fund worth Rs 1556116/-, the unsecured loans worth Rs. 1947000/-, loans and advances worth Rs. 218500/-, the sundry creditors worth Rs. 827462/- were not filed by the appellant. The PAN, addresses, the nature of business, the mode of payment, the details of loans and advances, the interest paid, the rate of interest, the mode of payment, the addresses of the sundry creditors, the nature of transactions and the dates of payments to the creditors were not filed by the appellant. Hence the genuineness of the transaction, the creditworthiness were not proved by the appellant, hence AO made the addition 6.2.1 Now before me in the appellate proceedings, the appellant has filed written submission. The appellant has mentioned that it has filed Return of Income u/s 44AD of the Income Tax Act. Hence these issues cannot be examined. The AO has made the addition on the basis of the fact that the nature of transactions and the dates of payments to the creditors were not filed by the appellant. Even on the issues of loans and advances, the appellant made no efforts to prove the genuineness of the transaction, the creditworthiness. Hence the contention of the appellant cannot be accepted because onus was on the appellant to prove the genuineness of the transaction, the creditworthiness. Hence the order of the AO on this ground is confirmed and appeal of the appellant is dismissed. …… 28. A bare perusal of the above would reveal that with respect to each addition made to the income to the assessee, the assessee had filed detailed submissions. With respect to the estimation of profits by invoking Section 44AD of the Act, the assessee had contended that Section 44AD of the Act was applicable only if the turnover did not exceed Rs.2 crore in a financial year and in the case of the assessee,

P a g e | 17 ITA No.1226/JPR/2025 Shilpa Jain admittedly it was Rs.8.78 crores which far exceeded the prescribed threshold u/s 44AD of the Act. The assessee also contended that the tax audit report furnished by the assessee itself reflected net profit which was in consonance with that returned in the preceding year. 29. With respect to the addition made on account of unexplained proprietors fund of Rs.19,47,000/- the assessee had stated that all explanations had been furnished to the AO demonstrating that only an addition of Rs.3 lakhs was made by the assessee to the proprietors capital that too through banking channels from the savings bank account of the assessee and the remaining addition to the proprietors capital was of the profits earned during the year. 30. Similarly with respect to the addition of Rs.19,47,000/- made on account of unexplained sundry creditors, the assessee had submitted that during the assessment proceedings itself, the assessee had submitted the confirmation of all the sundry creditors and had also submitted that all the loans were taken through banking channels. 31. Similarly with respect to the sundry creditors outstanding of Rs.8,27,462/- which were added to the income of the assessee as unexplained, the assessee similarly submitted that during the assessment proceedings itself all confirmations of the respective parties were submitted to the AO. 32. With respect to the addition of unexplained loans and advances, the assessee had submitted that the entire loans and advances had been given through banking channels and all details of the persons to whom it was given including their PAN number was also furnished.

P a g e | 18 ITA No.1226/JPR/2025 Shilpa Jain 33. Despite this detailed submissions made by the assessee to the Ld. CIT(A) demonstrating clearly that it had discharged his onus of proving the genuineness of all the unsecured loans and the sundry creditors proprietors capital and loans and advances and also demonstrating that there was no case for estimation of its profits u/s 44AD of the Act even as per law, the Ld. CIT(A) we have noted has not dealt with any of the specific factual or legal submissions made by the assessee at all while dismissing the assessee’s appeal. 34. Before us, Ld. DR was unable to controvert the factual contentions made by the ld. Counsel for the assessee before us of having sufficiently discharged his onus of proving the genuineness of all balances outstanding in its books of accounts by furnishing confirmations, details, PAN Numbers and showing that all the transactions took place through banking channels. She was unable to controvert the legal contention of the ld. Counsel for the assessee that Section 44AD of the Act could not be invoked for estimating the profits in the facts of the present case since the turnover of the assessee far exceeded the limits specified under the said Section. 35. In view of the above, we hold that all the addition made to the income of the assessee are grossly unjustified and against law and it is only net profit earned by the assessee which is liable to tax. The AO is accordingly directed to assess the income of the assessee only to the extent of net profits reflected in the profits and loss account of the assessee and all other additions and estimations made are directed to be deleted.

P a g e | 19 ITA No.1226/JPR/2025 Shilpa Jain 36. In effect, the appeal of the assessee is accordingly allowed in above terms. Order pronounced in the Open Court on 27.10.2026

Sd/- Sd/- (T.R. Senthil Kumar) (Annapurna Gupta) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated 27.10.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order, Mittali Digitally signed by: Mittali Asst. Registrar DN: CN = Mittali email = ITAT, Jaipur mittaligupta34671@gmail.com C = IN O = Personal Date: 2026.10.30 12:39:23 +05'30'