RAM SWAROOP MEENA,JAIPUR vs. JCIT, JAIPUR

PER SHRI KUL BHARAT, JM.

This Bunch of 11 appeals of different assessees are directed against the

separate orders of the Commissioner of Income Tax (A) dated 10.09.2013,

19.09.2013, 14.05.2013, 27.04.2015, 05.03.2015, 01.11.2013 and 03.12.2015 by

the assessee and the revenue respectively. In all these appeals common issues are

involved, therefore, all the appeals were taken up together and are being disposed

of by way of consolidated order, for the sake of convenience and brevity.

assessment year 2004-05 which is against the order of ld. CIT (A) wherein the

asseessee has raised the following grounds of appeal.

1.1 That the Ld. CIT (A) has further erred in sustaining the disallowance of the following expenses claimed out of vehicle hiring income arbitrarily without considering the genuineness of the claim.

Particulars Amount Depreciation 2,01,000.00 Bank Charges 60.00 Interest on car loan 31,450.00 Repairing and maintenance 5,680.00 Salary 54,000.00 Total 2,92,190.00

1.2 That the Ld. CIT (A) as well as the Ld. AO has failed to appreciated the reply of the assessee in question no. 9 reproduced by the AO in his order wherein assessee has categorically mentioned about the loans taken on such vehicles. Hence the expenses so claimed deserves to be allowed and income be classified as earned from vehicle hiring business.

1.3 That the Ld. CIT(A) has erred in observing at page 6 of his order that the assessee has not declared income from hiring of vehicles in regular return filed u/s 139(1) by wrongly placing reliance on return of income filed by the father of assessee Shri Narayan Lal Meena, thus observation of Ld. CIT(A) deserves to be ignored and excluded.

1.4 That the Ld. CIT(A) has further erred in drawing adverse inference from reply to question No. 2 of the statement of the assessee stating that his traditional business is manufacturing of Gajak and no reference was made to the business of plying of taxi, while doing so Ld. CIT (A) has ignored the fact that assessee’s family is engaged in this business since long and vehicle hiring business is a secondry business and was not the main business activity of assessee and in said statement assessee has not categorically denied about taxi plying business, thus income earned from vehicle hiring business deserve to be accepted.

2.1 That the Ld. CIT(A) has erred in placing reliance on remand report of the AO stating that said gift was received by the

assessee from his father on 13.08.2003 and in cash book furnished by the assessee during the course of assessment proceedings for the year under consideration the assessee has surrendered the said amount on 30.05.2003 as cash received. While doing so the Ld. CIT(A) ignored the act that as per cash book the assessee has surrendered Rs. 9.00 lacs on 30.05.2003 on account of unaccounted income from sale of Gajak invested in purchase of shop and on 13.08.2003 the assessee has received cash of Rs. 3.00 lacs from his father, thus such there is no discrepancy in the date of receipt of cash in the books of accounts and date on which the gifts was made as per the affidavits filed by the appellant and his brothers, thus observation of Ld. CIT(A) deserves to be ignored and genuineness of gift received deserves to be accepted.

3.1 That the Ld. CIT(A) has further erred in ignoring the fact that the books of accounts were tendered for verification wherein all the payments made have been duly recorded and backed by necessary sources, hence the addition of Rs. 2 lacs so made deserves to be deleted.

3.2 That the Ld. CIT (A) has further erred in not accepting the opening cash in hand which was duly declared in the return of income filed or immediately preceding assessment years, thus the addition of Rs. 2 lacs made toward such opening cash balance deserves to be deleted. 4. That the appellant craves the right to add, delete, amend or abandon any of the grounds of appeal either before or at the time of hearing of appeal.”

case of M/s Narayanaji Gajakwale, Jaipur to which the assessee belongs.

Subsequently, the assessment was made under section 153A/143(3), 1961, vide order dated 23rd Dec. 2011. While framing the assessment, the assessing officer

made two addition of Rs. 2,92,190/- and 7,30,000/- treating the income from other

sources and on account of unexplained investment. Thus, computed income of Rs.

20,48,190/- against the income declared by the assessee of Rs. 10,26,000/-. The

assessing officer made addition of while rejecting the claim of expenditure of Rs.

2,92,190/- Further, the assessing officer made addition on account of unaccounted

investment in purchase of shop no. 344, Johri Bazar, Jaipur of Rs. 7,30,000/-.

Aggrieved by this, the assessee preferred an appeal before Ld. CIT(A) who after

considering the submission partly allowed the appeal. However, the Ld. CIT(A) out

of two additions namely Rs. 2,92,190/- and Rs. 7,30,00/- confirmed Rs. 2,92,190/-

and out of Rs. 7,30,000/- confirmed Rs. 5,00,000/-. Now, the assessee has filed

further appeals to this Tribunal.

Counsel for the assessee reiterated the submission as made in the written

submissions. The Ld. Counsel for the assessee submitted that the authorities below

failed to appreciate the facts in right perspective that the assessee had declared

gross receipt of Rs. 3,16,190/- against which expenses of Rs. 2,92,190/- were

claimed and net income of Rs. 24,000/- was declared on account of vehicles running

business. He submitted that on perusal of details expanses of Rs. 2,92,190/- it is

evident that expenses are in the nature of depreciation, salary and expenses of

running and maintenance of vehicles which are minimum expenses incurred for

running of the vehicles. He submitted that even if it is presumed that the allegation

of assessing officer is correct and source of income is denied these expanses of Rs.

2,92,190/- cannot be disallowed as ownership of the said vehicle has not been

doubted neither genuineness or reasonableness of expenditure under dispute. In

fact, the assessee had not offered any income against these expenses the same

would have been very well allowable as business expenses as vehicles have been

used for business. The AO had disallowed these expenditure, on the basis that the

source of income as claimed by the assessee was rejected.

4.1. On the contrary, the Ld. Departmental Representative for the assessee and

supported the order of the authorities below.

4.2. We have heard the rival contentions, perused the material available record

and gone through the order of the authorities below. The claim of the assessee is

that he was engaged in the business of plying vehicles on hiring. Admittedly, there

is no supporting evidence which suggest that the assessee had carried out this

activity. Another contention of Ld. Counsel for the assessee is that even if it is

assumed that the vehicles were not used for business of hiring of vehicles even then

the expenditure as claimed is allowable as the vehicles were used for business

purposes.

4.3. We find that no such claim was made before the authorities below. However,

it was incumbent upon the assessee to support this claim with some evidence.

Merely, stating that the vehicles were for business purposes, in our view, it would

not be sufficient to allow the claim of the assessee. Therefore, in the absence of

material evidences, the claim of the assessee can not be allowed. Thus these

grounds of assessee’s appeal are dismissed.

under section 68 of the Act. The Ld. Counsel for the assessee reiterated the

submission as made in the written submissions. The Ld. Counsel for the assessee

submitted that during the course of the assessment proceeding the assessee had

claimed gifts of Rs. 3 lakh from his father on 13/8/2003 which was paid to certain

agriculturists as advance. The assessing officer treated the payment as made from

undisclosed source and made addition. He submitted that during the appellate

proceedings the assessee duly submitted the supporting evidence which were

brushed aside by the Ld. CIT(A). Same could not be furnished during the course of

assessment proceedings. After obtaining the remand report the ld. CIT(A) did not

accept explanation provided by the assessee and confirmed the addition. He drew

our attention to paper book page nos. 49 to 53, he submitted that the assessee

received Rs. 3 lakhs from his father. He submitted that the gifts received was in the

knowledge of other family members, thus no formal gifts deed was executed at that

time. He submitted that as for cash on hand the assessee claimed Rs. 9 lakhs on

account of income from sale of Gajak, which was invested in purchase on

13/8/2003. The assessee had received cash of Rs. 3 lakhs from his father which

was given as advanced to various agriculturists he submitted that there is no

discrepancy in the date of receipt on cash in the books of accounts and the date on

which the gifts was made as per affidavit filed by the appellant and his brothers. He

submitted no new fact is stated in the remand report and the allegation as made in

the assessment order are merely produced.

5.1. On the contrary, Departmental Representative opposed the submission and

submitted that this story of gift is an after thought.

5.2. We have heard the rival contention perused the material available record and

gone through the order of the authorities below. We find that the assessee had

furnished affidavit from other family members particularly brothers in the form of

affidavits to state that father of the assessee had given a gift of cash on Rs. 3 lakhs on 13th Aug. 2003, the authority below have not believed this statement on oath. It

is also not the case of the assessing officer that shri Narayan lal Meena father of the

assessee was not in a position to give such gifts. The assessee has also placed on

record return of income filed by the father of the assessee which demonstrate that

father of the assessee was having sufficient source of income sufficient. Therefore,

the orders of the authorities below are set aside on this issue and the assessing

officer is directed to delete the addition of Rs. 3 lakhs.

ld. Counsel for the assessee reiterated his submission as made in the written

submissions. The Ld. Counsel submitted that during the course of assessment as

well as in the appellate proceedings it was claimed that the said payment was made

out of opening cash balance. The ld CIT(A) did not accept this claim on the ground

that the assessee was showing a meager income. He submitted that this

observations of Ld. CIT(A) is not justified. As the Ld. CIT(A) has admitted the act

that the assessee is engaged in the business of Gajak and it is carried out on cash

basis.

6.1. On the contrary, the Ld. Departmental Representative opposed the

submissions.

6.2. We have heard the rival contention, perused the material available record.

We find that the assessee has been declaring income as per evidence placed on

record. The assessee has been declaring income since the assessment year 1999-

2000. Therefore, in our view the Ld. CIT (A) was not justified in confirming the

addition and rejecting the claim of cash on hand.

6.3. In view of the aforesaid, we hereby direct the Assessing Officer to delete the

addition. This ground of the assessee’s appeal is allowed.

allowed.

ITA No. 890/JP/2013 & ITA No. 909/JP/2013:

909/JP/2013 by the revenue and assessee respectively. These appeals are against

the order of Commissioner of Income Tax (A), Central, Jaipur dated 19.9.2013. First

we take up assessee’s appeal in ITA No. 909/JP/2013. The assessee has raised

following grounds of appeals :-

1.1. That the Ld. CIT (A) has further erred in sustaining the disallowance of the following expenses claimed out of vehicle hiring income arbitrarily without considering the genuineness of the claim. Particulars Amount Depreciation 2,52,600.00 Bank Charges 70.00 Interest on car loan 58,430.00 Repairing and maintenance 4,950.00 Salary 60,000.00 Car Insurance 48,,922.00 Total : 4,24,972.00

1.2. That the Ld. CIT (A) as well as the Ld. AO has failed to appreciated the reply of the assessee in question no. 9 reproduced by the AO in his

order wherein assessee has categorically mentioned about the loans taken on such vehicles. Hence the expenses so claimed deserves to be allowed and income be classified as earned from vehicle hiring business. 1.3. That the ld. CIT (A) has further erred in drawing adverse inference from reply to question No. 2 of the statement of the assessee stating that his traditional business is manufacturing of Gajak and no reference was made to the business of plying of taxi, while doing so ld. CIT (A) has ignored the fact that assessee’s family is engaged in this business since long and vehicle hiring business is a secondary business and was not the main business activity of assessee and in said statements assessee has not categorically denied about taxi plying business, thus income earned from vehicle hiring business deserves to be accepted.

2.1. That the ld. CIT (A) has further erred in holding that M/s. Vastu Land and Buildline Developers had paid amount of Rs. 1.50 crores to the appellant for purchase of land when in fact from documents/evidences submitted by the ld. AO in the remand proceedings it is clearly established that the said firm has never purchased land from the appellant nor had made any payment to him and the firm has made the payment of Rs. 1.50 crores to the Khatedars towards the purchase of land, thus addition of Rs. 71,94,000/- uphold on account o profit on sale of land in the hands of appellant deserves to be deleted.

2.2. That the ld. CIT (A) has further erred in observing that the assessee has received the payment from M/s. Vastu Land and Buildline Developers by placing reliance on notarized document signed by the partner of M/s. Vastu Land and Buildline Developers accepting that the payment of Rs. 1.50 crores was made to the brother of appellant for the same land, while observing so the ld. CIT (A) has ignored the fact that as per said documents, payment of land was made to the Khatedars and brother of the assessee acted as power of attorney holder of the Khatedars and from this document it does not established that the appellant was the owner of the said land and has received payment on the sale of such land, thus observation of the ld. CIT (A) deserves to be ignored and excluded and the resultant addition deserves to be deleted.

2.3. That the ld. CIT (A) has erred in ignoring the fact that the appellant in order to buy peace and to avoid prolonged litigation declared additional income of Rs. 12,06,000/- as income from business from sale of land to M/s. Vastu Land and Buildline Developers on the basis of documents found during the course of search which were hold as unauthentic by the ld. AO in remand proceedings and also discarded by ld. CIT (A), therefore addition upheld by the ld. CIT (A) deserves to be deleted.

2.4. That the ld. CIT (A) has further erred in observing that assesee has made total payment of Rs. 66.00 lacs to the owner of land as no lfurther evidence is available by ignoring the fact that the land owners in the receipts given for Rs. 66.00 lacs has categorically admitted the balance consideration as outstanding thus such observation deserves to be ignored and excluded and consequent addition of Rs. 71,94,000/- based on such baseless observations deserves to be deleted.

the assesse of Rs. 29,927/- being the income earned from plying of vehicles. The ld.

Counsel for the assessee reiterated the submissions as made in the written

submissions and submitted that identical ground was raised in ITA No. 908/JP/

2013.

10.1. The Ld. Departmental Representative has opposed the submissions and the

representatives of both the parties adopted the same argument as were made in ITA

No. 908/JP/2013.

10.2. We have heard the rival contentions and perused the material available

records. The facts are identical as were made in ITA No. 908/JP/2013 whereby we

have decided the similar issue by holding as under :

“ We have heard the rival contentions, perused the material available record and gone through the order of the authorities below. The claim of the assessee is that he was engaged in the business of plying vehicles on hiring. Admittedly, there is no supporting evidence which suggest that the assessee had carried out this activity. Another contention of Ld. Counsel for the assessee is that even if it is assumed that the vehicles were not used for business of hiring of vehicles even then the expenditure as claimed is allowable as the vehicles were used for business purposes. We find that no such claim was made before the authorities below. However, it was incumbent upon the assessee to support this claim with some evidence. Merely, stating that the vehicles were for business purposes, in our view, it would not be sufficient to allow the claim of the assessee. Therefore, in the absence of material evidences, the claim of the assessee can not be allowed. Thus these grounds of assessee’s appeal are dismissed.”

Taking a consistent view, this ground of assessee’s appeal is dismissed.

profit on sale of land of Rs. 12,06,000/-. The Ld. Counsel for the assessee reiterated

the submission as made in the written brief. The submission of the assessee are

that during the year under appeal a return of income was filed under section 153 A

of the Act wherein assessee declared an additional income of Rs. 12,06,00/-being

the profit from the sale of land. The ld. Counsel submitted that documents of

purchase of sale were found and seized during the course of search as annexure A

agriculture land to M/s. Vastu Land Developers and Pvt. Ltd. vide agreements to sale dated 8thAug. 2004 for total consideration of Rs. 1,50,00,000/- and received sale

consideration on various dated as copy of the same was annexed A-25. The said

land was purchased by the assessee from the two agriculturists for a sum of Rs.

1,35,00,000/- and the relevant copy of the purchased agreements were also seized

during the course of search vide Annexure A-25. It was submitted that the

assessee had made the payment of cost of land out of part sale consideration

received from buyer M/s Vastu Land and Developers Pvt. Ltd. on various dates. The

entire transaction resulted into profit of Rs. 12,06,000/-. He submitted that the date

wise receipt of advance and subsequent payment of kastkars against purchases of

subject land is tabulated in the written submission. He drew our attention to Page

no. 4 of the written submissions. He submitted that it is pertinent to note that the

advance receipts of Rs. 1,24,00,000/- from M/s Vastu Land and Build Line Pvt. Ltd.

is duly recorded. He submitted that the contents of the sale agreements and cash

receipts of Rs. 26,00,000/- have been reproduced by the Assessing Officer at pages

6 and 7 of the assessment order. He submitted that the Assessing Officer

misconstrued the terms of agreements dated 8/8/2004. He submitted that in both

the agreements to sale entered into the kastkars agriculturists namely Shri Ram Pal

Meena and Shri Narayan Lal Meena dated 13/10/2003 both the kastkars sold their

share of land to the assessee for sale consideration of Rs. 10 lakhs per Bigha and

advance payment of Rs. 1 lakh was accepted by them, which also finds reference in

the agreements. However, in the agreement of sale no time period was mentioned

for payment of balance sale consideration and it was clearly mention that when the

fulfill payment was made by Shri Ram Sawroop Meena to them, they will transfer the

share of ownership rights in the land to the assessee. He submitted that the

Assessing Oficer without bringing on record and any material or evidence observed

that Shri Ram Swaroop Meena purchased share of agricultural land of Shri Ram Pal

Meena and Shri Narayan Lal Meena in the month of Oct. 2003, whereas M/s Vastu

Land and Build Line Pvt. Ltd. paid first installment of Rs. 64 lakhs to Shri Ram

Swaroop Meena on 7/7/2004 as disclosed in agreement. He submitted as per

records the receipt mentioned at serial nos. 3 and 4 enclosed at assesseee paper

book pages nos. 36 to 37 of Rs.31 lakhs and 32 lakhs respectively issued by the

assessee to Shri Ram Pal Meena and Shri Narayan Lal Meena respectively. He

submitted that in the said receipt , the assessee has accepted the payment of above

amount of both the kastkars. Since, no particular date was mentioned in the receipt

and as the said receipt was given on stamp of Rs. 100/- which was purchase on

7/7/2004. It is therefore, can be presumed that the payment of secure installment

that is Rs. 30 Lakhs each to both the seller was made on the said date only and this

date was also coincide with the advance received from M/s Vastu Land and Build

Line Pvt. Ltd. He submitted that it was agreed by the assessee that the balance

amount will be paid up to 15/08/2004 which proves the fact that the assessee has

not paid the full consideration to kastkars on the date of receipt. During the

appellate proceedings, all the facts were narrated before the Ld. CIT (A) and it was

also contented if the assessing officer had any doubt about the genuineness of the

claim of the assessee he could have issue summoned under section 131 to kastkars

and buyers company to know actual state of transaction. He submitted that such

request was also made by the assessee during the course of assessment

proceedings. However, without acceding to the request of the assessing officer

proceeded to make additions on conjecture and summarize and summarily rejected

the claim of the assessee and alleged that the payment of the land under

consideration was made to the kastkars by the Shri Ram Swaroop Meena from his

unaccounted source. However, the Ld. CIT directed the assessing officer for making

verification by conducting enquiry and furnishing remand reports. The Assessing

Officer in remand report completely changed the basis on which the addition was

made in the assessment order and alleged that the assessee had never sold any

land to M/s Vastu Land and Build Line Pvt. Ltd. He further submitted that in the

second report, which is reproduced at page no. 21 to 22 order of the Ld. CIT. The

assessing officer after categorically analyzing has concluded that the payment to

kastkar were made by M/s Vastu land & Buildline Developers and not by the

assessee, which is based on the letter filed by the company to the assessing officer

that is ITO Ward 2(4) Jaipur, who accepted this contention while completing the

assessment of company. He submitted that it was submitted before the Ld. CIT(A),

if this contention of the assessing officer is taken as correct then it can be safely

concluded that there was neither any sale of land to M/s Vastu Land & Buildline

Developers nor any payment was made to the kastkar by the assessee. He

submitted that if the land is directly purchased from M/s vastu Land & Buildline

Developers question of making addition in the hands of assessee does not arise on

account of unexplained investment on purchase of said land and profit their own

does not arise. He further submitted that by observing contradiction in the finding

of the assessing officer during the assessment proceedings and remand report

proceedings. The Ld. CIT(A) called upon assessment records. On perusal of the

said records two additional documents were found by the Ld. CIT(A), which were

though part of assessment record, yet, were not mention in the assessment order.

He submitted that Annexure-F i.e. Power of Attorney registered by sub- Registrar

Sanganer, father of Ramkaran meena that is brother of the assessee registered on

8/7/2004 handed over all the rights with regard to the said property to him by Shri

Rampal Meena, Shri Narayan Lal Meena, Annexure-G is a sale agreement between

M/s Vastu Land & Buildline Developers dated 6/9/2004 wherein it has been admitted

that the said land has to be sold to M/s Vastu Land & Buildline Developers through

its partners namely Shri Raguveer Singh and Shri Kalyan Singh in lieu of it Rs. 1.50

crores has been received by Shri Ramkarna Meena which is also not signed by the

buyer and unilateral document signed by the Shri Ramkarn Meena. Thus, after

considering all the evidence available on records, the Ld. CIT(A) concluded that

appellant had made payments of Rs. 66 lakhs to Shri Rampal Meena and Shri

Narayan Lal Meena for their share of agricultural property, out of the advance

received from the company and the remaining amount of Rs. 71,94,000/- is held as

an unexplained payment made by the assessee, out of his undisclosed income by

ignoring the papers available in the seized documents. He submitted that the Ld.

CIT(A) concluded that no payment was made by the assesee to kastkars beyond Rs.

66 lakh. The Ld. CIT(A) had no objection so far as transition of sale of land by the

assessee to M/s Vastu Land & Buildline Developers of sale consideration is

concerned which is contrary to second remand report submitted by the assessing

officer. He submitted that few facts are worth consideration purchase of land is

evidenced by Ikrar Nama 13/10/2003 between Shri Rampal Meena and Shri Ram

Swaroop Meena(Annexure-C-1) (Assessess paper book pages 24 to 29), and the

Ikrarnama dated 13/10/2003 between Shri Naryanlal Meena and Shri Ram Swaroop

Meena (Annexure-C-2) (APB-30 to 35). He submitted that on perusal of these

agreements it can be seen that the rights in the land would transfer in favour of the

assessee only after final payment is made. The facts that assessee has paid entire

purchase consideration is evident from the affidavit of Shri Rampal Meena and Shri

Narayan Meena wherein they have acknowledged that no amount remained due on

the part of the assessee. He submitted that all these papers were found during the

course of search. He submitted that the assessing officer had observed that

purchase of land took place on 13/10/2003 whereas M/s Vastu Land & Buildline

Developers paid first installment of the sale consideration on 7/7/2004 and thus

arrived at conclusion that the payments were made by the assessee out of

unexplained source. He submitted that assessing officer has not doubted the

amount paid to the kastkars, as stated in the agreements rather objected the

sources of payment. The objection of the assessing officer was that the payments

were made prior to receipt of sale consideration from Vastu Land & Buildline

Developers. The assessee at the time of entering into agreement paid a sum of Rs.

1 lakh each, source of which has been unexplained while dealing with assessment

proceedings for assessment year 2004-05. He submitted that it is clearly mention

that balance payment would be made subsequently and only on final payment

assessee would be entitled to get land transfer in his name or his family members

name. The Ld. CIT(A) has also accepted the transaction of purchase from kastkars

as genuine by allowing the part cost of acquisition based on certain receipts

acknowledging the payment and has completely ignored the affidavits of the

Rampal Meena and Shri Nayaran Meena acknowledging that they had received

entire sale consideration and nothing remains due on the part of the assessee. He

submitted that these affidavits were also part of seized documents and can not be

inferred, being after thought, he submitted that although no specific receipts

available in respect of balance payment made to kastkars. These affidavits very well

prove that the entire payment as stated in Ikrarnama has been made to them. The

Ld. Counsel for the assessee relied on judgment of the Hon’ble Gujarat High Court

rendered in the case of Glass Lines Equipments Co. Ltd. vs. CIT, 253 ITR 454

(Guj.). He submitted that under these facts stated herein before, the assessee had

duly explained the source of payment made to the kastkars for purchase of land with

all possible evidence. Thus, profit on sale of agriculture land at Rs. 12 lakhs was

declared by the assessee deserves to be accepted.

11.1. On the contrary Ld. Departmental Representative opposed this submission

and supported the orders of the assessing officer.

11.2. We have heard the rival contentions, perused the material available record

and gone through the orders of the authorities below. The assessing officer made

addition on the basis that the payment of the sale consideration was made to

kastkars by shri Ram Swaroop Meena from his unaccounted source much before

receipt of Rs. 1.5 crores from M/s Vastu Land & Buildline Deveopers in the month

of July to Oct. 2004. The source of this investment remained unexplained out of the

total unaccounted payment Rs. 1,35,00,000/- a payment of Rs. 3 lakhs as advance

has been added to the income of the assessee as an unexplained investment in the

assessment year 2004-05. The balance amount of Rs. 1,32,00,000/- was thus

added to the income of assessee under section 69 of the Act, 1961. However, the

Ld. CIT (A) reduced this addition on the basis that all the evidences available on

record by way of submissions made and documents what emerges the facts that

during the course of search evidences was found that the assessee made payments

to Shri Rampal Meena and Shri Narayanlal Meena as per this the assessee made Rs.

1 lakhs each to Shri Rampal Meena and Shri Narayan Meena 13/10/2003 and Rs. 32

lakhs each on 7/7/2004. Thus, the Ld. CIT(A) held that in the absence of any

evidence of payment having been made to this kastkars, over and above Rs. 66

lakhs this was to be taken for the final purchase amount paid to the kastkars. The

contention of the assessee is that , that the Ld. CIT(A) failed to appreciate the facts

in right perspective and construed the documents correctly which were recovered

during the course of search. Undisputed facts that emerges from the records that

the transaction relates to the same land which the assessee is claiming to have

purchased on behalf of M/s Vastu Land & Buildline Pvt. Ltd. and payments regarding

sale consideration of the same was made by the assessee. The claim of the

assessee is that this payments were received from M/s Vastu Land and Buildline Pvt.

Ltd. The assessing officer in the remand report stated that the payment to the

kastkars were made directly by the M/s Vastu Land & Buildline Developers Pvt. Ltd

and believed the version of M/s Vastu Land & Buildline Developers Pvt. Ltd. We find

that there are sufficient evidences on record which were recovered during the search

operation by the revenue, describes the transaction related to the same land

however, the documents so recovered are not believed by the assessing officer.

We are unable to understand as why the assessee would make payment of the same

land to the kastkars and the kastkars would execute the sales deeds in favour of the

company namely M/s Vastu Land & Buildline Developers Pvt. Ltd. The Ld. CIT(A)

has considered part documents as true and the rest of the documents as untrue.

We find that both the authorities have failed to decide the issue in right perspective.

The assessing officer has not confronted the assessee with the letter received from

the company. By no stretch of imagination it can be inferred that the kastkars would

received sale consideration for the same land from two different persons.

11.3. Under these facts, we are of the considered view that the issue requires fresh

consideration by the assessing officer on the basis of the material available on

record. He would also be free to make further enquiry from kastkars and M/s Vastu

land and Buildline Developers Pvt. Ltd. and the assessee would be given sufficient

opportunity to rebut the same . This ground of the assessee’s appeal is allowed for

statistical purposes.

to addition on account of transaction of land to the file of the assessing officer for

afresh decision. This issue is also restored to the file of the assessing officer for

decision afresh.

ITA No. 890/JP/2013

has raised following grounds of appeal:

“1. On the facts and in the circumstances of the case, the ld. CIT (A), Central, Jaipur has erred in deleting the addition of Rs. 66,00,000/- out of Rs. 1,32,00,000/- made by AO u/s 69 of the IT Act, for unaccounted payment for purchase of land.

Rs. 1,32,00,000/-. The respective representatives of the parties have adopted the

argument as were made in respect of ground no. 2 to 3 in ITA 909/JP/2013. We

have decided this issue in part as under:

“We have heard the rival contentions, perused the material available record and gone through the orders of the authorities below. The assessing officer made addition on the basis that the payment of the land in consideration was made to kastkars by shri Ram Swaroop Meena from his unaccounted source much before receipt of Rs. 1.5 crores from M/s Vastu Land & Buildline Deveopers in the month of July to Oct. 2004. The source of this investment remain unexplained out of the total unaccounted payment Rs. 1,35,00,000/- a payment of Rs. 3 lakhs as advance has been added to the income of the assessee as an unexplained investment in the assessment year 2004-05. The balance amount of Rs. 1,32,00,000/- was thus edit to the assessee under section 69 of the Act, 1961. However, the Ld. CIT (A) reduced this addition on the basis that all the evidences available on record by way of submissions made and documents what emerges the facts that during the course of search evidences was found that the assessee made payments to Shri Rampal Meena and Shri Narayanlal Meena as per this the assessee made Rs. 1 lakhs each to Shri Rampal Meena and Shri Narayan Meena 13/10/2003 and Rs. 32 lakhs each on 7/7/2004. Thus, the Ld. CIT(A) held that in the absence of any evidence of payment having been made to this kastkars. Over and above Rs. 66 lakhs this was to be taken for the final purchase amount paid to the kastkars. The contention of the assessee is that , that the Ld. CIT(A)

fail to appreciate the facts in right perspective and construed the documents correctly which were recovered during the course of seach. Undisputed facts emerges that emerges from the records that the transaction relates to the same land which the assessee is claiming to have purchase on behalf of M/s Vastu Land & Buildline Pvt. Ltd. and payments regarding sale consideration of the same was made by the assessee. The claim of the assessee is that this paymers were receive from M/s Vastu Land and Buildline Pvt. Ltd. the assessing officer in the remand report as stated that the payment to the kastkars were made directly by the M/s Vastu Land & Buildline Developers Pvt. Ltd and believed the version of M/s Vastu Land & Buildline Developers Pvt. Ltd. We find that there is a sufficient evidence on record which were recorded during the search operation by the revenue. Describes the transaction related to the same land the documents so recovered are not believed by the assessing officer. We are unable to understand as why the assessee would make payment of the same land to the kastkars and the kastkars would execute the sales deeds in favour of the company namely M/s Vastu Land & Buildline Developers Pvt. Ltd. The Ld. CIT(A) has considered part documents as true and the rest of the documents as untrue. We find that both the authority have failed to decided the issue in right perspective. The assessing officer has not confronted the assessee with the letter received from the company. By no stretch of imagination it can be inferred that the kastkars would received sale consideration for the same land from two different persons. Under these facts, we are of the considered view that the issue require fresh consideration by the assessing officer on the basis of the material available on record. He would also be free to make further enquiry from kastkars and M/s Vastu land and Buildline Developers Pvt. Ltd. and the assessee would be given sufficient opportunity to rebut. This ground of the assessee’s appeal is allowed for statistical purposes.”

16.1. So, this issue is also restored to file of the assessing officer for decision

afresh. The ground raised in the revenue’s appeal is allowed for statistical purposes.

16.2. In the result appeal of the assessee in ITA No. 909/JP/2013 pertaining to

assessment year 2005-06 and appeal of the revenue in ITA No. 890/JP/2013

pertaining to the assessment year 2005-06 are partly allowed for statistical

purposes.

ITA No. 629/JP/2013

assessment year 2010-11. The assessee has raised following grounds of appeals :-

1.1 That the Ld. CIT(A) has further erred in ignoring the fact that most of the jewellery was the ancestral jewellery of assessee’s family and was acquired more than 25 years back and looking to the social status of the family the addition uphold towards the entire silver jewellery/items owned by entire family deserves to be deleted.

2.1.That the ld. CIT (A) has further erred in ignoring the fact that the cash belonging to other family members and is duly backed by the respective books of accounts have been accepted by same assessing authority in their assessments completed u/s 143(3) , thus the addition made towards the cash belonging to such family members deserves to be deleted at 13,45,923/-.

2.2.That the ld. CIT (A) has further erred in ignoring the fact that cash belonging to assessee and his wife at Rs. 3,54,051/- is duly recorded in books of accounts maintained in regular course and such books of accounts have not

been doubted by the ld. AO thus the addition of the cash belonging to assessee and his wife at Rs. 3,54,051/- deserves to be deleted.

2.3.That the ld. CIT (A) has further erred in placing reliance on the statements of the assessee recorded during the course of search by ignoring the fact that such admission has been rebutted by assessee with plausible explanation.

officer made addition of Rs. 28,40,000/- as unexplained investment, addition of Rs.

16,99,974/- on account of cash in hand in respect of five individuals and addition of

Rs. 15,10,567/- on account of investment in Jewellery. Aggrieved by this, the

assessee preferred an appeal before Ld. CIT(A) who after considering the

submissions partly allowed the appeal, thereby he deleted the addition of Rs.

28,40,000/-, sustained addition of Rs. 1,57,890/- out of addition of Rs. 15,10,567/-

and confirmed the addition of Rs. 16,99,974/-. Aggrieved by this, the assessee has

filed the present appeal.

submissions as made in the written submissions. The ld. Counsel for the assessee

submitted that during the course of search at the residential premises of the

assessee and his family member the total jewellery worth of Rs. 15,10,567/- was

found in terms of Annexure ‘JF’ dated 18/03/2010. The ld. Counsel submitted that

during the assessment proceedings assessee had explained that the investment in

Gold and Silver Jewellery was made by the assessee and their family member out of

withdrawal of remuneration from group company and also or their savings. The

investment in jewellery is duly recorded in their personal book of amount, he drew

our attention to (APB 52-55). The Ld. Counsel submitted that the Jewellery was

acquired by the assessee and his family member, at the time of their marriage and

other social functions. Which was solemnized almost 15 to 20 years back. Thus, the

entire jewellery is deserve to be hold as unexplained. He submitted that under thee

facts the authorities were justified in making the addition.

19.1. On the contrary, the Ld. Departmental Representative contrary opposed the

submission.

19.2. We have heard the rival contentions, perused the material available record

and gone through the order of the authorities below. The Ld. CIT(A) restricted the

addition to the extent of Rs. 1,57,890/- after giving benefit of CBDT’s instruction

dated 11/5/1994. We find that the Ld. CIT(A) has not considered this facts that thi

jewellery was acquired to 15 to 20 years ago. After considering totality of the facts

we therefore direct the assessing officer to delete the addition. Ground no. 1 to 1.1

of the assessee’s appeal is allowed.

the submission as made in the written brief. He submitted that the allegations of

the Ld. CIT(A) do not find force in view of the facts that the assessing officer

miserably failed to point out any defects in the cash book of the family member and

also failed to bring on record any contrary evidence/material to reject the cash book

so submitted or not acceptable or the source of cash balance appearing against

various individuals family members have not been satisfactorily explained. He

submitted that copy of balance sheet of the family member of the assessee as on

date of search mentioning cash balance on the date of search is in parity with the

cash found during the course of search. He drew our attention to paper book pages

52 to 56. He further submitted that cash balances belonging to other family

members amounting to Rs. 13,45,923/- is duly backed by the respective books of

accounts which have been accepted by the same authorities in their respective

assessment completely under section 143(3) of the Income Tax Act, 1961, wherein

return income was accepted thus cash balance appearing in their individual books on

account deserves to be accepted. He drew our attention to the paper book pages

60 to 69 where the assessment orders are enclosed. He further submitted that cash

belonging to assessee and his wife of Rs. 3,54,051/- was duly recorded in books of

account maintained in regular course and such books of accounts have not been

doubted in the case of assessee himself wherein the income declared as per book on

account was accepted. Thus cash belonging to assessee and his wife at Rs.

3,54,051/- deserves to be deleted.

20.1. On the contrary, Ld. Departmental Representative opposed the submissions

and supported the orders of the authorities below.

20.2. We have heard the rival contentions, perused the material available on

record. We find force into the contention of Ld. Counsel for the assessee when the

cash in hand has been duly accepted in the hands of individual family members.

Therefore, making the addition of the same amount in the hands of the assessee is

not justified. Accordingly, we hereby, direct the assessing officer to delete his

addition.

to the assessment year 2010-11) is allowed.

ITA No. 206/JP/2016:

ITA No. 206/JP/2016. The assessee has raised solitary ground as under:

“ The Assessing Officer and Commissioner of Income Tax (Appeals), Alwar, Rajasthan erred in fact and law in making addition of Rs. 2,00,000/- received from Mohini Poonia as Advance for Sale of immovable assets without considering the facts submitted.”

The only ground is against the confirmation of addition of Rs. 2 lakhs.

lakhs on account of cash deposits in the bank account of the assessee. The

assessing officer rejected the explanation that money was received from Ms. Mohini

Punia. On further appeal before Ld. CIT(A) the addition came to be sustained. The

Ld. CIT(A) did not consider the evidences filed before him on the ground for want

of genuineness and the documents were not be relied. Aggrieved by this the

assessee is before this Tribunal.

24.1. Ld. Counsel for the assessee reiterated the submission as made in the written

submissions. The Ld. Counsel submitted that authorities below failed to make proper

enquiries. He submitted that no enquiry was made on the material furnished. He

submitted that the material evidence in the form of confirmation and evidence to

support the credit worthiness of the creditors was duly furnished. He further

submitted that the Ld. CIT (A) failed to appreciate that the money was returned

through banking channels. He submitted that merely because money is deposited as

cash deposits in the bank account should not be the sole ground for making

addition. The Ld. CIT(A) ought not to have brushed aside of the evidences of the

assessee.

24.2. On the contrary, ld. Departmental Representative opposed the submission

and supported the order of the authorities below.

24.3. We have heard the rival contentions, perused the material available on record

and gone through the orders of the authorities below. In this case, the assessing

officer made addition on the basis of cash deposits in the bank account. The

explanation before the assessing officer was that this amount of Rs. 2 lakhs was

taken or Ms. Mohini Punia and it was subsequently returned both the authority

below did not accept the contentions of the assessee. There is no dispute with

regard to the fact that the assessee furnished the evidences before the Ld. CIT(A) in

the form of confirmation agreement and the income tax returns. No enquiry was

made by the assessing officer even during the remand proceedings on these

evidences. In our considered view AO ought to have made enquiry when there was

specific confirmation by Ms. Mohini Punia. Moreover, there is an evidence on record

administrating that money was return to the Ms. Mohini Punia. There is debit entry

in the name of Ms. Mohini Punia in the bank’s statement of the assessee.

24.4. Under these facts, we are unable to sustain the addition, therefore we direct

the assessing officer to delete the addition. The grounds raised in the appeal is

allowed.

ITA NO. 598/JP/2015 & ITA No. 83/JP/2013

83/JP/2013 in the case of Shri Ram Karan Meena.

26.1. First, we take up assessee’s appeal in ITA No. 598/JP/2015. The assessee

ha raised following grounds of appeal.

“ 1. The Assessing Officer and Commissioner of Income tax (Appeals) Alwar, Rajasthan erred in fact and law in making addition of Rs. 184384.00 without considering the bank account withdrawals in cash as on 06.02.2003 amounting to Rs. 3,40,000.00.

facts giving rise to this ground is that during the assessment proceedings the

assessee claim sum of Rs. 3,84,384/- as opening balance as on 1/4/2003. The AO

accepted the opening balance to the extent of Rs. 2 lakhs and balance in sum of Rs.

1,84,384/- was added to the income of the assessee. Against this, the assessee

preferred an appeal before Ld. CIT(A) who after considering the submissions

sustained the addition. Thus, the assessee is before this Tribunal by way of present

appeal.

27.1. The Ld. Counsel for the assessee submitted that finding of authority below is

patently wrong and its contrary to the material on record. He vehemently argued

that it was stated before Ld. CIT (A) that there was an withdrawal of sum of Rs.

3,40,000/- from the SB Account No. 3867 of the assessee held at Punjab National

Bank on 6/2/2003. This amount remained with assessee. In support of this

contention he drew our attention on page no. 14 where statement of bank account

is enclosed. He submitted that bare reading of the statement would demonstrate

that the authorities below were not justified in making addition and sustaining the

same.

27.2. On the contrary, the Ld. Departmental representative opposed the submission

of the assessee and supported the orders of the authorities below.

27.3. We have heard the rival contentions, perused the material available on

record. We find that a specific submission was made before the Ld. CIT(A) that a

sum of Rs. 3,40,000/- was available with the assessee in the form of bank

withdrawal. This fact is not disputed by the revenue. The Ld. CIT(A) rejected the

submission, on the basis that there was cash deposit and withdrawal from the bank

account on the same date. We find that this finding of Ld. CIT(A) is contrary to the

contents of the bank statement. As per the bank statement, there is an entry of

cash deposit on 20/1/2003 of Rs. 3,40,000/- and withdrawal of the same amount as

on 6/2/2003. Further, we find that there is no substantial cash deposits and withdrawal in the bank’s statement post 6th Feb. 2003. It is further noted that there

is an entry of deposits of Rs. 2,03,000/- on 22/5/2003 and the withdrawal of Rs.

2,03,000/- on same date which is post 1/4/2003. Under these undisputed facts we

are of the view that the assessing officer was not justified in making addition.

Accordingly, we direct the assessing officer to delete the addition.

ITA No. 83/JP/14

directed against the order Ld. CIT(A), Central, Jaipur dated 1/11/2013. The

assessee has raised the following grounds of appeal.

The only effective ground is against the confirmation of penalty under section 271D

of the Act.

271D pertaining to assessment year 2005-06. It was found that the assessee had

received advance/loans/deposits from Shri Ram Swaroop Meena in cash not through

account pay check or account pay draft on loan amount exceeding Rs. 20,000/-. It

was alleged that the total amount received was Rs. 12,06,000/- which was in

violation of section 269SS of the IT Act. Subsequently, the JCIT imposed a penalty

of Rs. 12,06,000/- vide order dated 25/6/2012. This order was assailed by the

assessee before Ld. CIT(A) who however sustained the penalty. Now, the assessee

is in further appeal before this Tribunal.

29.1. The ld. Counsel submitted that the authorities below failed to appreciate the

fact that there was no actual transfer of cash. Assessee merely booked entries, the

amount was neither loan nor deposit. He submitted that it was pleaded before

authorities below that the business was being carried out by the assessee and his

brothers. Therefore it was not actual transfer of cash. He submitted that such book

entries would not fall under the ambit of section 269SS of the Act, as such provisions

of section 271D of the Act would not be applicable. He placed reliance on various

case laws, more particularly on the judgment of the Hon’ble Gujarat High Court

rendered in the case of CIT Vs. Nartwarlal Purshottamdas Parekh (2008)303 ITR

5(Guj).

29.2. On the contrary, the ld. Departmental Representative opposed the

submissions and supported the reasoning of authorities below. He also placed

reliance on the Hon’ble Madras High Court rendered in the case of Kasi Consultant

Corporation Vs. DCIT (2009) 311 ITR 0419 (Mad.).

29.3. The Ld. AR also placed reliance on the judgment of the Hon’ble Andhra

Pradesh High Court rendered in the case of Gururaj Mini Roller Flour Mills Vs.

Additional CIT 370 ITR 50 (AP). The ld. AR also placed reliance on the decision of

the coordinate bench rendered in the case of Chandra Cement Ltd. Vs. Deputy

Commissioner of Income Tax (2000) 68 TTJ 35(JP-Trib).

29.4. We have heard the rival contentions and perused the material available

record. The contention of the assessee is that the provision of section 271D is not

applicable as the assessee has not taken loans or advances, it is mere book entry. It

is also stated that such book entry transfer was for the purpose of making

investment. It is also stated that the assessee was carrying on joint business with

his brothers. Therefore, this cannot be treated as loan and advances in strict sense.

The Hon’ble Andhra Pradesh High Court in the case of Gururaj Mini Roller Flour Mills

Vs. Additional CIT (supra) has held that if their exists reasonable cause for failure to

comply with section 271D and 271E or other related provisions, penalty need not be

imposed. It is further held that making book adjustment of the funds, by a firm vis-

a-vis its sister concern, can by no means be said to be the one taken in clear

violation or contravention of the said provisions. The coordinate bench in the case

of Chandra Cement limited Vs. Deputy Commissioner of Income Tax 68 TTJ(JP)35

observed that when one single individual is managing the affair of two concerns and

the decision to transfer the funds from one concern to another or to repay the

funds could have been said to have been largely influenced by the same individual, it

can not be said that transaction partake the nature of either deposit or loan. In the

present case the genuineness of the transaction is not doubted by the assessing

officer. Therefore, in the light of the judgment of the Hon’ble Andhra Pradesh High

Court in the case of Gururaj Mini Roller Flour Mills Vs. Additional CIT (supra) and

also the decision of the coordinate bench in the case of Chandra Cement Ltd. Vs.

Deputy Commissioner of Income Tax (supra), we are of the view that the

authorities below were not justified in confirming the penalty. Our this view is also

fortified by the judgment of the Hon’ble Gujarat High Court rendered in the case of

CIT Vs. Nartwarlal Purshottamdas Parekh (supra). Therefore, we direct the

assessing officer to delete the penalty. This ground of the assessee’s appeal is

allowed.

ITA No. 607/JP/2015

has raised following grounds of appeals :-

1.1. That the ld. CIT (A) has further erred in upholding the disallowance of the following expenses claimed out of vehicle hiring income arbitrarily considering the genuineness of the claim.

Particulars Amount Depreciation 1,51,560.00 Interest on car loan 63,632.00 Repairing and maintenance 7,860.00 Salary 60,000.00 Bank charges 20,003.00 Total 3,03,055.00

1.2. That the ld. CIT (A) has further erred in upholding the observation of ld. AO at page 2 of the assessment order that assessee during the course of assessment proceedings has not adduced any evidence in support of expenses claimed and AO has failed to appreciate the reply of the assessee in question No. 9 reproduced by the AO at same page wherein assessee has categorically mentioned about the loans taken on such vehicles. Hence the expenses so claimed deserves to be allowed and income be classified as earned from vehicle hiring business.

30.1. Only effective ground of this appeal is during the course of receipts of Rs.

3,51,355/- from hiring of vehicles business as unaccounted income from other

sources. It is stated by the representative of the parties that similar ground is raised

in ITA No. 908/JP/2013 pertaining to the assessment year 2004-05. Both the ld.

Departmental Representatives of the parties have adopted the same argument as

were addressed in ITA No. 908/JP/2013(supra).

30.2. We have heard the rival contentions, perused the material available on record

and gone through the order of the authorities below. We find that the assessee’s

appeal in ITA No. 908/JP/2013 has raised identical ground no. 1 to 1.4 wherein we

have decided the issue as under :-

““We have heard the rival contentions, perused the material available record and gone through the order of the authorities below. The claim of the assessee is that he was engaged in the business of plying vehicles on hiring. Admittedly, there is no supporting evidence which suggest that the assessee had carried out this activity. Another contention of Ld. Counsel for the assessee is that even if it is assumed that the vehicles were not used for business of hiring of vehicles even then the expenditure as claimed is allowable as the vehicles were used for business purposes. We find that no such claim was made before the authorities below. However, it was incumbent upon the assessee to support this claim with some evidence. Merely, stating that the vehicles were for business purposes, in our view, it would not be sufficient to allow the claim of the assessee. Therefore, in the absence of material evidences, the claim of the assessee can not be allowed. Thus these grounds of assessee’s appeal are dismissed.”

Therefore, taking the consistent view as facts are identical in this year also and no

change into the facts and circumstances have been pointed out by either of the

party. We hereby dismiss the appeal of the assessee.

ITA NO. 608, 609 & 610/JP/2015 :

Since common grounds are involved in all these appeals, we are disposing off all

these appeals together, for the sake of convenience. The grounds raised in these

appeals are same except change in figures, therefore, we reproduce the grounds

pertaining to Assessment Year 2007-08 in ITA No. 608/JP/2015 as under :-

1.1. That the ld. CIT (A) has further erred in upholding the disallowance of the following expenses claimed out of vehicle hiring income arbitrarily considering the genuineness of the claim.

Particulars Amount Depreciation 90,936.00 Interest on car loan 63,871.00 Repairing and maintenance 7,584.00 Salary 60,000.00 Bank charges 405.00 Total 2,22,796.00

1.2. That the ld. CIT (A) has further erred in upholding the observation of ld. AO at page 2 of the assessment order that assessee during the course of assessment proceedings has not adduced any evidence in support of expenses claimed and AO has failed to appreciate the reply of the assessee in question No. 9 reproduced by the AO at same page wherein assessee has categorically mentioned about the loans taken on such vehicles. Hence the expenses so claimed deserves to be allowed and income be classified as earned from vehicle hiring business.

32.1. Only effective ground of this appeal is during the course of receipts of Rs.

3,06,796/- from hiring of vehicles business as unaccounted income from other

sources. It is stated by the representative of the parties that similar ground is raised

in ITA No. 908/JP/2013 pertaining to the assessment year 2004-05. Both the ld.

Departmental Representatives of the parties have adopted the same argument as

were addressed in ITA No. 908/JP/2013(supra).

32.2. We have heard the rival contentions, perused the material available on record

and gone through the order of the authorities below. We find that the assessee’s

appeal in ITA No. 908/JP/2013 has raised identical ground no. 1 to 1.4 wherein we

have decided the issue as under :-

“We have heard the rival contentions, perused the material available record and gone through the order of the authorities below. The claim of the assessee is that he was engaged in the business of plying vehicles on hiring. Admittedly, there is no supporting evidence which suggest that the assessee had carried out this activity. Another contention of Ld. Counsel for the assessee is that even if it is assumed that the vehicles were not used for business of hiring of vehicles even then the expenditure as claimed is allowable as the vehicles were used for business purposes. We find that no such claim was made before the authorities below. However, it was incumbent upon the assessee to support this claim with some evidence. Merely, stating that the vehicles were for business purposes, in our view, it would not be sufficient to allow the claim of the assessee. Therefore, in the absence of material evidences, the claim of the assessee can not be allowed. Thus these grounds of assessee’s appeal are dismissed.”

Therefore, taking the consistent view as facts are identical in all these years also and

no change into the facts and circumstances have been pointed out by either of the

parties, we hereby dismiss all the appeals of the assessee.

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

Sd/- Sd/- ( HkkxpUn ½ ( dqy Hkkjr) ( BHAGCHAND) ( KUL BHARAT ) ys[kk lnL;@Accountant Member U;kf;d lnL;@Judicial Member Jaipur Dated:- 28/02/2016. Pooja/ आदेश की प्रतिलिपि अग्रेषित@ब्वचल वf जीम वतकमत वितूंतकमक जवरू

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