GALAXY IMPEX,JAIPUR vs. DCIT, JAIPUR

per the quantities, the Authorized Representative had expressed his

inability for the same. Thus, considering the defects pointed out by the

7 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

Assessing Officer, the rejection of books of accounts is upheld. Now

coming to the percentage to be adopted, in the previous year the gross

profit was 49.74% while in the current assessment year it is only

44.71%. The decrease is explained through increase in raw material cost

and decrease in total turnover. It is true that the turnover has decreased

by about 24% and there was increase in the price of raw material and

hence it will be reasonable to adopt the gross profit at 46% of the total

turnover. This ground is partly allowed.

4.1 It was submitted that the assessee has admittedly maintained

complete books of accounts consisting of Cash Book, Ledger, Journal

and Stock Register of Raw Material & Production, Stock Register of

Finished Goods. All the purchases and sales are fully vouched. All the

expenses were fully supported by vouchers. The financial accounts and

the other subsidiary & Quantitative records were duly maintained.

Further the accounts were subjected to Tax Audit u/s 44AB(PB 1-9). The

same were produced before the AO also alongwith other details from

time to time. The AO has not at all judiciously considered submissions

made before the AO.

8 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

4.2 The contention that the assessee has maintained complete day to

day quantitative details, is duly supported by the examination done by

the learned tax auditor wherein through Annexure G (PB 18) with

reference to clause no.28 of TAR (PB 8), the quantitative details have

been furnished of raw materials and finished goods both. The relevant

extract from TAR, are as under:

9(b) Books of accounts maintained. Purchases Book, Sales Book, (In case books of account are Cash Book, Bank Book, maintained in a computer Journal, Ledger (Books of system, mention the books of account generated by account generated by such computer system and Stock computer system). Register.

9(c) List of Books of account Same as mentioned in 9(b) examined. above.

4.3 The objection of the learned AO that the assessee had maintained

the quantitative details as indicated and annexure attached with the

Form No.3CD in terms of square meter and pieces only of all quantity of

goods. However, such inventory and details attached with Form 3CD are

giving the extracts of raw material and of finished goods but does not

provide the details of manufactured goods and of the yield.

9 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

In fact, it appears a gross misconception of fact on the part of the AO on

the face of the record itself in as much as a perusal of PB 18 to 19 being

Annexure G to TAR, clearly shows and also admitted by the AO as well

that the assessee has maintained the details of raw material and finished

goods both still however, his grievance was that the assessee has not

provided the details of manufactured goods and of the yield.

A bare perusal of this annexure shall reveal that for Jaipur Unit, the

assessee has shown the yield of finished goods in absolute term i.e.

136506.46 sq. mtr. And the percentage of yield being 89.34%, as also

the absolute figure of wastage/rejection being 16,287.52 sq. mtr.,

meaning thereby the wastage percentage was 10.66%. similarly for

Chennai Unit also which was engaged in trading and manufacturing

both, similar figures of raw material consumption, production and yield

have been given. After obtaining finished goods, there could not have

been any wastage or rejection thereafter. Therefore, the allegation of

the AO is grossly incorrect on the face of it. Further separate chart of

wastage given to AO (PB 78).

4.4 The allegation of the AO that the assessee did not furnish the details

of item-wise inventories of various purchased goods, is something

impossible and impracticable for any trader/businessman in this line,

10 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

which otherwise is not a prevailing trade practice for the reason that

there are several types of stones running into hundreds and the price

variation is very nominal. The assessee has been following the same

method of maintenance of stock register and valuing the stock at

average cost price since inception, which otherwise is in accordance with

the prevailing trade practice. The AO when confronted on this aspect the

assessee, he duly replied the above facts however, thereafter the AO did

not raise any query meaning thereby he felt satisfied.

4.5 As regards the AO’s allegation that the assessee made purchases at

higher prices as compared to the preceding year, it is submitted that the

fact is admitted that the assessee made purchases from the outside

parties only and no one was in relation of the partners of the assessee

firm. That being the position, S. 40A(2) does not apply and the

genuineness of the expenditure and the fact of making payment not

having being under doubt, it has to be accepted that the assessee made

purchases at the prevalent prices in the best business interest. The AO

could and should have made inquiries directly from those suppliers to

bring the truth on record, had he got some doubt. Further as regards

the expectation of the AO that the sale price should have also been

increased by the assessee similarly to that extent, firstly, suffice to say

11 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

that it was a businessman decision taking into the prevailing trade

conditions, facts and circumstances, in the best business interest and

secondly, the purchase had to be made at higher prices however, the

supplies were to be made to the importers/buyers, with whom, the

assessee had already entered into agreement. Therefore the assessee

was contractually obliged to honour the commitment already made. In

other words, the assessee had already committed the sales prices

however, in the meanwhile the raw material prices went up and hence

the assessee was not in a position to recoup the increase in the prices

more particularly, in the absence of an escalation clause. Ref. Pr. 2.6

also.

4.6 The AO also alleged that the assessee failed to produce item-wise

quantitative sock register maintained at Jaipur and Chennai and had also

failed to provide item-wise details of such inventory month wise as well

as copies of stock statements filed with the bank from whom the limits

have been taken.

It is submitted that the assessee did maintain all the possible

quantitative details meticulously on day to day basis and the same is

evident from the various copies of chart showing Stock Register of Raw

Material & Production, Stock Register of Finished Goods. However, the

12 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

same were even duly produced before the AO time to time for his

verification. Hence this allegation is factually incorrect. However the AO

never asked of furnishing copies of stock statement filed with the bank,

as evident from the query letter dated 05.11.2014 (PB 79-82)

4.7 The AO alleged that the freight inward expenses of Rs.117.83 lacs

and expenses of packing material of Rs.157.91 lacs were very high.

However, such allegation is without making any comparison or giving

other details which made him to allege like this. Thus, his objection

appears to be vague and baseless. No payment to related parties have

been made and paid to third parties as per prevailing rates.

4.8 The allegation of the AO that the assessee had not given any reason

for the increase in the cost at pg 4 pr 1, is completely baseless and

contrary to the facts in as much as he himself has admitted in the earlier

part of the order at pgs 2-3 that the assessee submitted the reason

behind fall in G.P. rate being increase in the purchase price of raw

material ranging between 10% to 160% (which is correctly 4.3% to

37.2% and from Rs.10 per sq. mtr. to Rs.160 per sq. mtr). The

purchases were made from unrelated outside various parties at the

prevailing market prices, as evident from the copies of invoices (PB 84-

98). The AO could have made inquiries from those parties directly.

13 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

4.9 The AO appears to have wrongly mentioned the figure of wastage

and appears to have proceeded on misconception of facts by saying that

the assessee declared wastage of 15.80% this year as against 8.93% in

the preceding assessment year and alleged that there was no reason for

such a sharp increase in the wastage. However, the correct facts are

otherwise. The assessee, in fact, declared much lesser wastage of

8.93% this year as against 15.80% in AY 2010-11. In AY 2011-12 the

assessee declared 13.82%. Thus, the percentage of wastage is

constantly coming down and has sharply decreased. Kindly refer the

comparative chart (PB 78). The very basis of S. 145 remains no more.

4.10 The AO alleged that the details of sold inventory does not indicate

how the same can be bifurcated and differentiated with each items of

inventory for the purpose of examination. It was stated by the assessee

that it is not possible to maintain such inventory in a large

manufacturing unit item-wise. It is submitted that firstly there appears

no specific query raised by the AO as stated nor the assessee ever gave

any submission as mentioned.

Thus, none of the objections raised could be made a basis of invoking

Sec. 145.

14 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

4.11 The ld. CIT(A), as evidently clear from her order has summarily

confirmed the application of Sec. 145 without appreciating the various

factual submissions and the case laws cited and even without

appreciating the practical difficulties in the maintenance of the

quantitative records, the way the revenue wants more particularly, when

there is no prescription u/s44AA r/w Rule 6F. In fact, the AO wanted the

assessee to do something humanely impossible. It has been held in

various cases that maintenance of the accounts & records in a particular

manner, the accounts cannot be rejected. Further, rejection of accounts

is a serious matter and unless specific defects are pointed out and it is

shown that due to such defect, the profits are not reasonably

ascertainable, the accounts cannot be rejected in a casual or routine

manner.

4.12. During the course of hearing before the ld CIT(A), when the

assessee was asked to clarify how the yield and wastage was arrived at

and whether after doing some work, the stone and the ultimate product

has changed the shape, a chart showing the mathematical working of

wastage of 8.93% was submitted, as under:

Assessment Year 2012-13

Goods Issued for Production (Sq. Mtr)

15 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

Jaipur 152793.98 Chennai 67450.00 220243.98 Finished Goods Production Jaipur 136506.46 Chennai 64077.50 200583.96 Wastage Jaipur 16287.52 Chennai 3372.50 19660.02 % of Wastage on Goods issued for Production Wastage(19660.52) X 100 Goods Issued for Production (220243.98) 8.93%

It was submitted that the raw/rough/crude stone as available in the

mother earth or in rocks is unearth/quarried/excavated by the mine

owners and is of different shape and size. It is purchased as a raw

material. Sizing is done. Edge cutting is done by machines as well as by

tools manually. Various natural flaws such as color variation, joints,

fissures moles, patches, hairline, cracks etc. are removed by

16 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

hand/machine process and by use of various tools, chemicals, polish,

resin, vex etc. Dressing & Cutting, Washing, Lavigation, Calibration,

tumbling, molding and other upgrading techniques are applied. As per

requirement Slabs and Tiles are produced. The Slabs and Tiles exported

by the assessee firm are different than raw materials purchased by the

assessee firm. In the export business the quality of product is of utmost

importance. Even a single defect in quality of goods, the entire shipment

is rejected by the buyer.

However, in the order, there appears no adverse remark of the claim of

wastage made by the assessee this year at 8.93% and thus, the

contentions of the AO have been impliedly rejected. It is submitted that

when the ld. CIT(A) has neither found any fault in the submissions

explaining the reason of fall in the GP/NP rate as also has justified the

wastage claimed this year, there was no reason yet to upheld the part

addition by applying GP rate of 46%. Hence, the impugned addition

kindly be deleted in full.

4.13. Minor irregularities, even assuming were there, cannot be made a

basis of the rejection of the books of accounts or of trading addition.

Kindly refer Padampath Ramgopal (1970) 76 ITR 719 (SC).

17 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

4.14. It was further submitted that the assessee has been carrying on

the same business in the same set up and under the same facts and

circumstances. Even the manner and method of recording the

transactions has also been the same since AY 2003-04. All along in the

past, the cases of the assessee are being selected for scrutiny in almost

every year except in A.Y. 2010-11. The same books of accounts and the

other ancillary record showing financial and quantitative details,

maintained in a similar manner in the past also, were duly produced

before the earlier assessing officers yet however, in none of these years,

the AO has ever invoked S.145 and rejected the accounts either directly

or indirectly or even remotely. Therefore, there appears no special

reason as to why the AO should have departed from the settled position

on facts and on law between the parties and to unsettled the same.

Kindly refer copies of assessment order for AY 2011-12 (PB 109-112), AY

2009-10 (PB 113-120), AY 2008-09 (PB 121-126), AY 2007-08 (PB 127-

132). Similarly even in later years A.Y. 2013-14, 2014-15 assessment

completed u/s 143(3), yet S.145 was not invoked (copies submitted).

4.15 In the impugned assessment order, the AO has not whispered a

single word as to why he is breaking the rule of consistency, which

otherwise is binding upon him. In these circumstances therefore the

18 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

doctrine of res judicata certainly applies on the facts of the present case,

so far as this aspect is concerned.

It has been held that though the doctrine of res judicata do not apply to

Income Tax proceeding yet however, unless there is a change in the

facts and circumstances, the view taken earlier should normally be taken

consistently. For this kindly refer Sardar Kehar Singh v/s CIT (1991) 92

CTR 88(1992) 195 ITR 769 (Raj.), and a recent decision in CIT v/s Excel

Industries Ltd. (2013) 358 ITR 295 (SC).

It is a judicially accepted principle that when the facts are same, a

uniform view should be adopted for the subsequent years in the income

tax proceedings unless there is a material change in the facts, which has

not be established by the AO. Kindly refer Radhasoami Satsang v/s

CIT(1992) 193 ITR 321 (SC), on the theory of consistency, has held as

under:

“Strictly speaking, res judicata does not apply to the income tax

proceedings. Though, each assessment year being a unit, what was

decided in one year might not apply in the following year, where a

fundamental aspect permeating through different assessment years has

been found as a fact one way or the other and parties have allowed that

position to ne sustained by not challenging the order, it would not be at

19 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

all appropriate to allow the position to be changed in a subsequent

year”.

4.16. Alternatively and without prejudice to above submissions on merits

also, it is submitted that no trading addition at all was called for in view

of the following facts and submissions:

4.17 Addition need not be made, even if Sec. 145 Invoked: It is

submitted that even invoking of Sec. 145 does not confer blind powers

upon the AO and he is not at liberty to assess the income at whatever

figure he wants. He is bound to make an honest estimation of income.

In the case of CIT vs. Gotan Lime Khaniz Udyog (2002) 256 ITR 243

(Raj), it has been held that mere rejection of books of accounts need not

necessarily lead to additions to the returned income.

However, it will appear that in the present case, the ld. AO has not made

a fair estimation in conformity of the above settled judicial guideline. It is

not denied that the assessee was engaged in the business of

manufacturing, trading and export of stones in the past as also in the

later years. Therefore, there is no reason still not to consider the past

history which is the best material to be used for fair estimation as per

the binding decisions. The ld. AO is totally silent on this aspect.

20 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

4.18 As regards the following G.P./N.P. rate this year, the assessee

made categorical submissions before the AO vide letter dated

12.01.2015 (PB 73-74) reading as under:

“In respect of query No.15 of your query letter, we enclose

herewith comparative GP and NP chart for last three years

alongwith turnover details. The assessee firm has declared a GP

rate of 44.71% on Total Turnover of Rs.16,59,84,045/- for the

year under reference as against GP rate of 49.74% declared on

Total Turnover of Rs.21,85,71,128/- for the immediately preceding

year. The NP rate declared for the year under reference was

7.75% as against NP rate of 10.53% declared for the immediately

preceding previous year.

The main reason for fall in the GP rate for the year under

reference was due to increase in cost of Raw Materials in the year

under reference. We enclose herewith a statement showing break

up of Trading Account for the year ended 31.03.2012 and

31.03.2011. It is evident from the enclosed statement that the

cost of purchases in the year under reference was 41.15% of total

turnover whereas in the immediately preceding year i.e. financial

year 2010-11 it was 36.70% of total turnover of that year. There

21 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

was about 5.03% increase in the cost of purchases made during

the year under reference. We produce herewith the details of

purchases made during the year under reference with purchase

bills of Raw Materials cost comparison for the financial year 2010-

11 and 2011-12 (PB 84-98) alongwith copies of purchase bills of

raw materials in support of increase in cost of Raw Materials in the

year under reference. The perusal of enclosed statement (PB 83)

shows that increase in Raw Materials cost in the year under

reference was about 4% to 37% as compared to cost of

immediately preceding year. The purchases and sales are fully

vouched and transactions of purchases and sale are through

banking channels. Further the books of accounts are duly audited

and backed by stock records and quantitative tally.(PB 100).

The other main reason for fall in the GP rate for the year under

reference was due to decrease in turnover for the year under

reference. The turnover of the assessee firm decreased from

Rs.21,85,71,128/- to Rs.16,59,84,045/- in the over under

reference. There was a fall of about 24% in turnover in the year

under reference. The fall in the turnover resulted in fall in the GP

rate due to increase in percentage of cost of fixed nature of

22 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

expenditure and other direct expenditure. Int. & dep. increase this

year by 32 lacs i.e. 1.93% more w.r.t. turnover (PB 70).

The main reason for fall in the NP rate for the year under

reference was due to decrease in GP rate for the year under

reference by about 5% which resulted fall in NP rate for the year

under reference.”

However, it appears that the AO & ld. CIT (A) have not appreciated

these submissions judiciously. These submissions having been made and

duly supported with the evidences, remaining un-rebutted, there is no

reason that why the AO should have made the addition.

4.19 Otherwise A.Y. 2011-12 distinguishable: Since the assessee had

already successfully distinguished the facts of the preceding year A.Y.

2011-12 from the peculiar facts available in this year, which fact is not

disputed by the AO & ld. CIT (A), hence there was no justification even

of computing an average of the two years of the GP rate at 47.23% and

to apply the same. The past history though is treated to be a good guide

in the matters of estimations however, for fair estimation unless the

facts are not found exactly identical, blind application of the past history

is also equally not permissible.

23 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

4.20 Pertinently the ld. CIT(A) has very clearly accepted the factual

contentions raised explaining the reasons behind the fall of GP/NP rate

yet however, instead of deleting the complete addition, reduced the GP

rate from 47.23% applied by the AO to 46% only but absolutely without

furnishing any reason as to why she did not accept declared GP rate of

44.71%. There is absolutely no basis/reasoning behind adopting 46%.

Once the ld. CIT(A) has accepted the contentions, she was bound to

have allowed the relief more particularly, when the revenue is not in

appeal challenging the findings recorded and the relief granted by her.

authorities.

available on record. The principal contention raised by the Assessing

Officer while rejecting the books of accounts has been substantial

increase in the amount of wastage as compared to previous year where

the production has also increased substantially during the year. On

perusal of documents available on record, it is noted that the percentage

of wastage during the year is 8.93% as against 15.8% in A.Y. 2010-11.

The detailed working thereof has been reproduced above. Further, the

turnover has, in fact, decreased from Rs.21.85 crore to Rs.16.59 crore

24 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

during the year. Therefore, on both account, there is clearly an actual

inaccuracy which has crept in or wrongly appreciated by the Assessing

Officer which has resulted in rejection of books of accounts. The other

reason mentioned by the Assessing Officer while rejecting the books of

accounts has been the decrease in the GP rate vis-à-vis last year and

non-maintenance of quantitative details in terms of raw material and

finished goods account. On perusal of the record, it is noted that the fall

in GP rate has been reasonably explained by the assessee through facts

and figures and as far as the quantitative details of raw material and

finished goods are concerned, the same have been appropriately

disclosed in the Tax Audit Report and therefore, details have been

submitted during the course of assessment and the appellate

proceedings. In the light of above, we do not see any justifiable reason

for rejection of books of accounts in the instant case. Further, no

reasonable basis has been given for estimating the GP rate by the lower

authorities. In the overall facts and circumstances of the case and also

taking into consideration the fact that in the previous years as well as in

the subsequent years, the books of accounts have been accepted by the

Revenue, we do not see any justifiable basis for rejection of books of

accounts in the instant year. In the result, we are of the view that A.O

was not justified in rejecting the books of accounts and making the GP

25 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

above. Pursuant thereto the ground taken by the assessee is therefore

allowed.

Assessing Officer has made an addition on account of expenses under

the head conveyance of Rs.9,73,835/-, Office expense Rs.1,75,818/-,

Staff welfare expenses with staff-mess expenses Rs.4,79,463/-,

Telephone expenses Rs.2,42,816/-, Vehicle repairing expenses

Rs.3,53,127/-, Foreign travelling expenses Rs.36,51,757/-, and Sales

promotion expenses Rs.2,29,889/- which in total works out to

Rs.61,06,705/-. During the course of assessment proceeding, the

Assessing Officer has found that no call register, ledger, vouchers and

log book maintained by the assessee, hence the Assessing Officer made

20% of the above disallowance.

officer is on the higher side, hence the addition made by the Assessing

Officer is restricted to 10%.

submitted that a bare reading of the impugned order shall reveal that in

almost all the cases the disallowances have been made on ad hoc basis,

simply on mere suspicion, surmises and conjectures. No specific instance

26 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

of any nature whatsoever has been given by the AO in the impugned

order to support his contention with the documentary evidence that the

expenditures were incurred for non-business purposes, element of

personal use was there. An allegation remains a mere allegation unless

proved. Suspicion cannot take the place of reality, are the settled

principles kindly refer Dhakeshwari Cotton Mills V/S CIT (1954) 26 ITR

775 (SC).

9.1 It was submitted that a businessman is the best judge to take

care of its own interest & to take decisions and the AO is not supposed

to intervene therein nor he can replace the assessee. Here, whatever

decisions were taken by the assessee has to be understood as taken out

of commercial expediency. Kindly refer T.T (P) Ltd. v/s CIT (1980) 121

ITR 551 (Kar), CIT v/s Udhoji Shrikrishnadas (1983) 139 ITR 827 (MP),

JK Woolen Manufactures V/S CIT (1969) 72 ITR 612 (SC).

9.2 It was further submitted that neither the AO nor the ld. CIT(A) have

provided any reasonable basis whatsoever for making the estimated

disallowance. They also ignored the vital fact that in the past no such

disallowance was ever made. Kindly refer assessment order (PB 111)

where total Rs.7,84,388/- were claimed which came to 0.36% of the

turnover. It may be clarified that in the assessment order however, (PB

27 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur

101 & 111) the AO wrongly totaled the same at Rs.10,83,017/-. In that

year the AO disallowed Rs.2,16,803/- which comes to 0.10% of the

turnover. As against this the subjected expenditure were of

Rs.61,06,705/- as selected by the AO and came to 3.68% of the

turnover. Some of the expenses were incurred for the first time this year

only like Conveyance, Office, Staff Welfare, Foreign Travelling which is

3.18% of the turnover.

9.3 It was submitted that looking to a huge turnover of more than

Rs.16.59 crores (approx), claim of expenditure is otherwise very meager.

On the above expenses kindly refer a chart (PB 101) herein above. Thus

such a meager claim to achieve such a huge turnover is not at all

unjustified. All these expenses were incurred exclusively for businesses

purpose and are under the provisions of the Act.

available on record. No specific expenditure has been identified by the

Assessing officer which calls for disallowance either in terms of the said

expenditure being bogus in nature or not incurred for the purposes of

business carried on by the assessee. There is no basis for disallowance

on adhoc basis in the eyes of law. In the result, the disallowance made

28 ITA No.529/JP/2016 M/s Galaxy Impex Vs. C.I.T.(A), Jaipur by the Assessing officer and sustained by the ld CIT(A) is deleted. The

ground taken by the assessee is thus allowed.

Section 233B and 234D, since the same is consequential in nature, the same is dismissed.

In the result, appeal filed by the assessee is partly allowed.

Order pronounced in the open court on 28/02/2017.

Sd/- Sd/- ¼dqy Hkkjr ½ ¼foØe flag ;kno½ (Kul Bharat) (Vikram Singh Yadav) U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member Tk;iqj@Jaipur fnukad@Dated:-28/02/2017. *Sanjeev*. आदेश की प्रतिलिपि अग्रेf’ात@ब्वचल वf जीम वतकमत वितूंतकमक जवरू 1. vihykFkhZ@The Appellant- M/s Galaxy Implex, Jaipur. 2. izR;FkhZ@ The Respondent- The CIT, Circle-6, Jaipur. 3. vk;dj vk;qDr@ CIT 4. vk;dj vk;qDr@ CIT(A) 5. विभागीय प्रतिनिधि] आयकर अपीलीय अधिकरण] जयपुर@क्त्ए प्ज्Aज्ए Jंपचनत 6. xkMZ QkbZy@ Guard File {ITA No. 529/JP/2016}

vkns'kkuqlkj@ By order,

सहायक पंजीकार@Aेेज. त्महपेजतंत