DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. NARESH KUMAR GUPTA, SRIGANGANAGAR

per quintal for an aggregate amount of Rs. 7,09,75,070/-. Assessee

contended that entire sum of negative stock is justifiable as the

stock on account of the goods purchased from Kanda Edible Oil

35 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta Private Limited vide invoice dated 31/03/2014 in the facts and

circumstances of the case has not been given credit. The contention

of the ld. AO was that there is a large gap between the date of

delivery of the goods and the date of invoice and the date of delivery

is prior to the date of invoice. In the number of invoices as discussed

in the assessment order there is a delay in the date of invoice vis-a-

vis the date of delivery and such invoices and dates of deliveries

have been accepted in the assessment order. This shows the

practice of regular nature of the business of the assessee-appellant.

Out of the purchases so made in the case of one invoice of goods

purchased from Kanda Edible Oil Private Limited the delay is

abnormally high which is the reason that the same has been rejected

in the assessment order and thereby the alleged negative stock and

its peak was worked out. Ld. AO excluded that delivery of goods of

Kanda Edible Oil Private Limited wherein abnormal delay of one

invoice was observed and Id. AO has prepared the stock register

taking all entries on the basis of invoice date and worked out the

peak negative stock.

36 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta Ld. AO, on page 5 to 8 of the assessment order, has

reproduced reply of the appellant on this query of the Id. AO on such

transaction. Ld. AO in para 2 on page 13 of assessment order taken

an adverse inference with respect to the questioned invoice alleging

that the delay is abnormal of delivery date and date of invoice. In the

proceeding before the ld. CIT(A) the assessee-appellant has

summarized the trades where dates are different was considered by

the ld. AO, based on that set of facts ld. CIT(A) has considered the

arguments of the assessee that there is difference in dates in

several trades and it reflects a regular practice in the business of the

assessee. From the fact as is evident that one invoice issued by

Kanda Edible Oil Private Limited on 31/03/2014 is placed at Paper

book page 43, wherein the delivery date of the goods was mentioned

as 01/06/2013. Further the assessee has also filed the confirmation

from Kanda Edible Oil Private Limited which is placed at page 44

wherein the party has confirmed the fact of delivery of the goods on

01/06/2013. As per the facts mentioned in the assessment order,

neither in course of survey nor during assessment any fact was

brought on record to show cause that the goods were delivered on

37 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta any other date than that mentioned in the invoice relied upon.

Revenue in this appeal could not brought on record any evidence so

as to reject the evidence in the form of seller's confirmation in the

assessment order and there is no reference to any adverse finding

from the third party inquiry if any or that of the contention of the

invoice. The Id. AO has observed on pg. 15 of assessment order that

sauda bahi / contract note etc. were not produced, in this regard the

assessee-appellant submitted that no sauda bahi / contract notes

are separately maintained rather the same is mentioned in the

invoices and the stock register which were produced during the

assessment proceedings. In the assessment order there is no

reference to any material which would have been found during

survey which would corroborate the findings arrived in the

assessment order. Whereas the stand of the assessee-appellant that

the delivery was received on 01.06.2013 even during the survey and

it is not the case of otherwise fact having been present after survey

a case of afterthought. Ld. AR has argued that during the survey the

business records of the appellant were checked in detail. In survey,

statement of the authorized person was recorded wherein the survey

38 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta team in question No. 2 specifically required the assessee to explain

the fact of delivery of the goods in respect of the above impugned

bill. In the question during the survey in the same question details of

sale by the group entity M/s N.M. Agro Foods Products Private

Limited to the third party Kanda & Company and purchase of the

same quantity by the appellant are asked. In question no. 2, the

delivery details of sale of 5000 Qtl guwar gum by group concern M/s

N.M. Agro Foods Products Private Limited to Kanda & Company vide

bill No.65 on 21/05/2013 have been asked and it has been stated in

the question that no delivery details, truck number etc. are

mentioned on bill. Further in the same question, in continuation,

question has been asked with respect to impugned purchase bill

dated 31.03.2014 from Kanda Edible Oil Private Limited. The

assessee-appellant in response to the same stated that the delivery

of the goods took place on 01.06.2013 but the bill was received on

31.03.2014. The appellant-assessee has stated in submissions that

N.M. Agro Food Product Private Limited sold Guwar Gum to Kanda &

Company (A sister concern of Kanda Edible Oil Private Limited Rs.

14,12,50,000/- @ 28250/-on 21/05/2013 vide Bill No. 65. Kanda &

39 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta Company sold the same quantity of Gwar Gum to Kanda & Company

Oils Private Limited for Rs. 13,72,50,000/- @21450/- per qtil. Kanda

& Company Oils Private Limited sold the same quantity @ 30250/-

per qtl for Rs. 15,12,50,000/- to N.M. Food Product i.e. the assessee

vide bill No. 271 dated 31/03/2014 but delivery of the goods were

made on 01/06/2013.

Further to this fact it is stated by assessee-appellant that "We

may further point out that this purchase is made Ex- Wherehouse as

mentioned in the copy of the purchase bill itself”. The delivery of this

is verifiable from the circumstantial evidence as found in the survey

itself and specially discussed in the statement recorded in survey

where assessee made surrender of Rs.1,00,00,000/- on the basis of

this transaction. As we note from the statement that N.M.Agro Food

Product Private Limited (this is a group concern of the assessee-

appellant) sold Gwar Gum to Kanda & Company (A sister concern of

Kanda Edible Oil Private Limited) for Rs.14,12,50,000/-28250/-on

21/05/2013 vide Bill No. 65. At this time N.M.Agro Good Product

Private Limited was having stock of guwar gum in hand at 5466.65

qtl Copy of the stock register in support of the same placed on

40 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta record. The delivery of these goods was done symbolic and thereby

goods remained at the same godown. Kanda & Company sold the

same quantity of Gwar Gum to Kanda & Company Oils Private

Limited for Rs.13,72,50,000/-21450/- per qtl. This delivery was also

symbolic and goods remained at the same place. Kanda & Company

Oils Private Limited sold the same quantity @30250/- per qui for (vi)

Rs. 15,12,50,000/- to N.M. Food Product i.e. the assessee vide bill

No. 271 dated 31/03/2014 but delivery of the goods were made on

01/06/2013. This delivery was also symbolic. In fact goods sold from

group concern was come back to the assessee. Goods remained at

the godown of sister cocern itself. On perusal of the details it is seen

that the invoices were issued and the goods were sold ex-warehouse

and the same goods came to be purchased back by the assessee-

appellant. Further the assessee in its statement itself has clarified

that delivery was received on 01/06/2013 but the bill was received

on 31/03/2014. This has also confirmed by the party through

confirmation and mentioning the delivery date on the bill. In the

assessment order the same has been rejected only on account of

large gap in the delivery date and date of invoice and where the gap

41 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta is not large the same were accepted. Appellant has also filed letter

issued by Ganganagar Traders Associtaion of Sriganganar region

(PB 36). Invoice dates and delivery dates can differ specially in large

quantity orders and invoice dates by default cannot be treated as

delivery date. No inquiry based evidence has been relied on in the

assessment order. There is no reference to any documents having

been found during survey showing transaction of any unaccounted

purchases by the appellant. The legal precedent cited before us

says that it is trite law that suspicion howsoever strong cannot take

place of a legal proof. The Hon'ble Supreme Court in the case of

Sreelekha Banerjee vs. CIT (1963) 49 ITR 112 (SC) has held that

"The Department cannot by merely rejecting unreasonably a good

explanation, convert good proof into no proof. Considering this facts

and circumstances of the case, it is obvious that the invoice dates by

default cannot be treated as delivery dates. No inquiry based

evidence has been brought on record in the assessment order.

There is no finding from the survey regarding any unaccounted

purchases/sale. Even during survey same stand was adopted. The

confirmations have been filed by appellant. Considering the totality

42 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta of facts and circumstances, the stated delivery dates can not be

rejected and that there is no negative stock if the stock register is

seen in terms of the delivery dates and thus no addition is justifiable

on the issue. The assessee also raised an alternative ground before

the ld. CIT(A) stating that it has been held in so many cases that no

sale can take place without the purchase and if the appellant has

indulged into bogus purchases in such a case a percentage of the

bogus purchases can be added to arrive at the net income of the

appellant. The appellant is a trader and not a manufacturer of the oil

in which the appellant is dealing. The books of accounts of the

appellant have been rejected in the assessment order. During the

survey proceedings the appellant has already offered an additional

income of Rs.1,00,00,000 on the same invoice which is 14.09% of

the impugned invoice of Rs. 7,09,75,070. Even as held by our

Hon’ble Jurisdictional High Court in the case of Clarity Gold that in

such type of case the profit is required to be estimated and in the

present case since G.P. is better, no addition on G.P. can be done

by inclusion of the income declared by the assessee. From the

perspective of the gross profit ratio, the G.P. rate during the year is

43 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta 1.73% and the same gets enhanced to 2.04% after considering

surrender which is better as compared to 0.92% declared in the last

year and no evidence of unrecorded purchase/ sale was found in

survey or otherwise brought on record by the ld. AO. even in case of

a scenario of rejection of books of accounts, no addition over and

above surrendered income is called for on the issue. Thus, we do

not find any infirmity in the finding so recorded by the ld. CIT(A)

while deleting the made in the assessment order of Rs.

7,09,75,070/- and thereby we do not found any merits in the grounds

so raised by the revenue. In the light of this discussion ground no. 1

raised by the revenue stands dismissed.

not justified in deleting the addition of Rs.2,87,229/- on account of

out of the claim of interest without appreciating the fact that that in

the case of Lally Motors India (P.) Ltd. Vs PCIT, Hon'ble ITAT

Amritsar in [2018] 93 taxmann.com 39 (Amritsar - Trib.)/[2018] 170

ITD 370 (Amritsar - Trib.) held that Section 14A would apply even if

no dividend was earned by assessee from investments in shares.

The brief facts related to the dispute is that assessee-appellant is

44 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta having investment of Rs.1,38,95,388/- in agricultural land and

Rs.41,89,301/- in residential house as on 31-03-2014. The income

received from these investments being exempt from tax, the

provision of section 14A read with rule 8D is required to be applied

as contended by the ld. AO and accordingly, the AO, by applying the

provisions of section 14A, made disallowance of Rs.Rs.2,87,229/-.

The assessee-appellant submitted that the disallowance u/s 14A is

attracted only when exempt income is earned. During the year the

assessee has not earned any exempt income from these land or

residential house and therefore no disallowance can be made u/s

14A. To support this contention the assessee-appellant placed

reliance on various cases laws including Supreme Court decision in

case of PCIT Vs. Oil Industry Development Board (2019) 262

Taxman 102 and CIT Vs. Chettinad Logistics (P.) Ltd. (2018) 257

Taxman 2. As we note from the order of the lower authority wherein

the assessee-appellant also contended that there was mistake in

calculation of the disallowance as the AO should have considered

net interest of Rs.1,00,50,643/ and net investment of Rs.

1,80,84,689/-. On this basis even as per the AO the correct

45 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta disallowance works out to Rs.25,210/- only. As regards the

contention of the revenue change in the law and decision of Lally

Motors India (P.) Ltd. Vs PCIT (Supra), the assessee-appellant

vehemently stated that the amendment made by Finance Act, 2022

to section 14A by inserting a non- obstante clause and Explanation

will take effect from 1-4-2022 and cannot be presumed to have

retrospective effects in the case of the assessee. To support this

view the assessee-appellant relied on the decision of Principal

Commissioner of Income-tax (Central) v. Era Infrastructure (India)

Ltd. [2022] 141 taxmann.com 289 (Delhi)/[2022] 288 Taxman 384

(Delhi)/[2022] 448 ITR 674 (Delhi) [20-07-2022] wherein it was held

that the amendment made by Finance Act, 2022 to section 14A by

inserting a non- obstante clause and Explanation will take effect

from 1-4-2022 and cannot be presumed to have retrospective effects

and thereby we found force in the arguments of the ld. AR of the

assessee. Considering that aspect of the matter and the fact that the

assessee has not earned any exempt income and thereby in the year

under consideration no addition can be made and this precedent

support the contention of the assessee as in detailed elaborated in

46 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta the decision of the ld. CIT(A) and therefore, we do not find any

infirmity in the finding of the ld. CIT(A). In light of this discussion

ground no. 2 raised by the revenue stands dismissed.

not justified in restricting the addition of Rs.97,63,413/- made by the

AO on account of disallowance of interest paid u/s 36(1)(iii) to

Rs.24,42,040/- without appreciating the fact that the assessee has

advanced interest bearing business funds and has diverted the same

for non-business purposes to other persons without charging interest

with an ulterior motive to reduce the incidence of his own case.

The brief facts related to this issue is that the net interest

claimed by the assessee-appellant was at Rs. 97,63,413. Based on

the submission ld. CIT(A) considered that the interest expenses are

incurred for the purpose of the business whereas the Ld. AO is

treating the same as incurred on giving interest free advance. Ld.

CIT(A) noted that the disallowance of entire interest expenses

appears to the apparently incorrect as fund are also utilized in the

business as evident from the balance sheet. Therefore ld. CIT(A)

find that it would be reasonable if the total interest expenses is

47 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta considered to be used in the total closing inventory and debtors and

than compare the interest attributable to the advance to related

parties and interest income received from them. On analysis of the

balance sheet CIT(A) noted that the gross payment of the interest is

Rs.4,48,24,980. This interest expenses is incurred on the interest

bearing funds utilized in the stock of Rs. 54,34,68,474 and debtors

of Rs. 349,45,15,887 totaling to Rs. 403,79,84,361. He also noted

from the arguments made by the ld. AR of the assessee that on

analysis of the debtors it is seen that the outstanding debtors

relating to group concern of the assessee works out to Rs.

175,63,73,496 as on 31/03/2014 comprising of the following parties

only:-

Nand Lal Mahabir Prasad- Rs.49,44,97,897 Manoj Traders Rs.56,27,39,927 N.M. Exports Rs.69,91,36,372 Rs. 175,63,74,196

Ld. CIT(A) thereby considering that arguments noted that the total

interest expenses incurred are divided in the inventory and debtors

than the proportionate interest expenses incurred in relation to the

investment in these debtors works out to Rs. 1,94,97,212

48 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta (4,48,24,980 x 175,63,74,196 / 403,79,84,361). As against this the

assessee during the year receieved interest of Rs. 1,70,55,172 from

the above three parties:-

Nand Lal Mahabir Prasad Rs 48,99,429 Manoj Traders Rs.63,12,330 N.M. Exports Rs.58,43,413 ----------------- Rs. 1,70,55,172

Therefore, ld. CIT(A) find the difference in the interest attributable at

Rs. 1,94,97,212 and interest recovered at Rs. 1,70,55,172 works out

to Rs. 24,42,040 (1,94,97,212 1,70,55,172). This interest is

considered as incurred on advancing the funds to related parties

without interest/at lower interest. Considering all these facts the

disallowance made by the AO is restricted to Rs. 24,42,040 and

balance disallowance was directed to be deleted by him.

the revenue raised ground no. 3 in his appeal whereas the assessee

has filed cross objections making the additional of Rs. 24,42,040/-

Since this issue is common for both the parties we considered it fit to

decide together.

49 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta 16. As is evident from the record that the assessee-appellant has

paid interest of Rs.4,48,24,479/- (APB-17) on the unsecured loan and to

the creditors on delayed payment of purchases. The assessee also

received interest of Rs.3,47,74,334/- (APB 22) on loans given. Thus net

interest paid and claimed to have been is Rs.1,00,50,642/- and this facts

are not in dispute. In the assessment order the ld. AO noted that assessee

has not charged any interest or charged very nominal interest from various

parties. Further party wise details of interest paid and charged were not

filed by assessee. Accordingly he made disallowance of interest of

Rs.97,63,413/- [(1,00,50,642 – 2,87,229*) *being interest already

disallowed] by holding that assessee has diverted the interest bearing

funds for non business purpose to other persons without charging any

interest from them. Whereas the first appellant authority noted that interest

of Rs.4,48,24,980/- was incurred on interest bearing funds which were

utilized in stock & debtors of Rs.403,79,84,361/- whereas the outstanding

debtors relating to the group concern is Rs.175,63,74,196/-. Thus ld.

CIT(A) made the proportionate interest with reference to the debtors of

group concern was worked out at Rs.1,94,97,212/- whereas the interest

received from these debtors was Rs.1,70,55,172/-. Accordingly he

50 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta confirmed the disallowance out of interest to the extent of Rs.24,40,040/-

(1,94,97,212-1,70,55,172) and the balance was deleted by him based on

the submission of the assessee-appellant. The total claim of the assessee

for payment of interest for an amount of Rs.4,48,24,980/- is on account of

payment of interest paid to the following parties:-

Particulars Amount Interest paid on unsecured and secured loans Rs.2,30,89,920/- Interest paid to the creditors for delayed payment of Rs.2,17,35,059/- purchases Total Rs.4,48,24,980/-

The party wise details of interest paid of Rs.4,48,24,980/- was filed in the

paper book page 45-46 and the interest paid to creditors for

Rs.2,17,35,059/- are in the normal course of business. Before us the ld. AR

of the assessee-appellant argued that interest to the creditor paid was out

of commercial expediency like borrowing from parties rather than to

supplier itself and therefore, the same cannot be compared for making the

disallowance and in support reliance was made on the decision of the apex

court in the case of S. A. Builders 288 ITR 1 (Supra) wherein apex court

held that ;

“24. In our opinion, the High Court as well as the Tribunal and other income-tax authorities should have approached the question of allowability of interest on the borrowed funds from the above angle. In other words, the High Court and other authorities should have enquired as to whether the interest free loan was given to

51 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta the sister company (which is a subsidiary of the assessee) as a measure of commercial expediency, and if it was, it should have been allowed. 25. The expression "commercial expediency" is an expression of wide import and includes such expenditure as a prudent businessman incurs for the purpose of business. The expenditure may not have been incurred under any legal obligation, but yet it is allowable as a business expenditure, if it was incurred on grounds of commercial expediency.” The ld. AR of the assessee-appellant also placed on service the decision of

apex court in the case of Hero Cycles (P.) Ltd. Vs. CIT (Central) (2015) 379

ITR 347 (SC) to the contention so raised for the sustained disallowance

wherein it has been held that ;

“Once it is established that there is nexus between the expenditure and the purpose of business (which need not necessarily be the business of the assessee itself), the Revenue cannot justifiably claim to put itself in the arm-chair of the businessman or in the position of the Board of Directors and assume the role to decide how much is reasonable expenditure having regard to the circumstances of the case. It further held that no businessman can be compelled to maximize his profit and that the income tax authorities must put themselves in the shoes of the assessee and see how a prudent businessman would act. The authorities must not look at the matter from their own view point but that of a prudent businessman.” Based on that contention the ld. AR of the assessee-appellant submitted

that if that part of the interest is excluded from the disallowance computed

by the ld. CIT(A) then in that case there is income earned by the assessee

as interest and therefore, the disallowance sustained is not correct based

on the above facts and once the interest received is more than the interest

paid, no disallowance is called for.

52 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta The ld. AR of the assessee-appellant also stated that the interest of

Rs.2,30,89,920/- is partly used in giving the advances and partly for the

purpose of business too. On advances given interest earned is

Rs.3,47,74,334/- which is much more than the interest paid of

Rs.2,30,89,920/-. The AO has referred to certain parties from whom no

interest or lesser interest has been charged and the explanation in respect

of each of such party as filed before us reads as under :

Name of the Opening Closing Remarks party Balance Balance Nand Lal Mahabir 30,34,71,392 49,44,97,897 He is a debtor to whom goods Prasad sold. There is no stipulation for (PB 47-48) charging interest from him. Only in certain bills where there was delay in payment of more than the normal time, interest is charged. Manoj Traders 32,28,97,214 56,27,39,927 He is a debtor to whom goods (PB 49-52) sold. There is no stipulation for charging interest from him. Only in certain bills where there was delay in payment of more than the normal time, interest is charged. N.M Exports 15,02,67,851 69,91,36,372 He is a debtor to whom goods (PB 53-54) sold. There is no stipulation for charging interest from him. Only in certain bills where there was delay in payment of more than the normal time, interest is charged. Vikas WSP 65,01,90,627 NIL (PB 55) Sat Vichar Dealer 4,28,74,244 4,28,74,244 The balance is coming from (PB 56) earlier years and there is no

53 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta stipulation of charging interest. Gravity Commo 4,20,16,531 2,11,11,546 The balance is coming from Sales earlier years and there is no (PB 57) stipulation of charging interest. Shiva Associates 62,78,00,000 21,44,48,445 This is the running account of (PB 58-59) the party from whom assessee has received funds and also advanced funds. There is no stipulation for charging interest from him. VikasChemigum 15,67,45,512 53,07,45,512 The assessee sold as well as India Ltd. purchased goods from this (PB 60-61) party. No interest is charged or paid on the transactions undertaken with him.

We note that ld. CIT(A) while dealing with the issue held that the entire

interest of Rs.4,48,24,980/- on borrowed funds has been utilized in stock

and debtors of Rs.403,79,84,361/- whereas as discussed herein above,

such interest is only Rs.2,30,89,920/-. Therefore, even if the calculation

made by CIT(A) is corrected, the proportionate interest expenses incurred

in relation to investment in stock & debtor would work out to

Rs.1,00,43,263/- (2,30,89,920*1,75,63,74,196/4,03,79,84,361) against

which the interest received is Rs.1,70,55,172/-. Hence no disallowance out

of the interest is called for. In the light of these facts as discussed herein

above the ground no. 3 raised by the revenue stands dismissed and that of

the ground no. 1 of the cross objection raised by the assessee is allowed.

54 ITA No. 458/JPR/2024 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta 17. Ground no. 4 raised by the revenue and ground no. 2 of cross

objection raised by the assessee being general does not require our

adjudication. Ground no. 3 raised by the assessee before us for which no

arguments were placed and therefore, we deem it fit for academic purpose

only.

In the results the appeal of the revenue stands dismissed and the

cross objection filed by the assessee stands allowed.

Order pronounced in the open court on 28/11/2024.

Sd/- Sd/- ¼Mk0 ,l- lhrky{eh½ ¼ jkBkSM+ deys'k t;UrHkkbZ ½ (Dr. S. Seethalakshmi) (Rathod Kamlesh Jayantbhai) U;kf;d lnL;@Judcial Member ys[kk lnL;@Accountant Member Tk;iqj@Jaipur fnukad@Dated:- 28/11/2024 *Ganesh Kumar, Sr. PS आदेश की प्रतिलिपिअग्रेf’ात@ब्वचल वf जीम वतकमत वितूंतकमक जवरू 1. The Appellant- DCIT, Central Circle-3, Jaipur. 2. izR;FkhZ@ The Respondent- Sh. Naresh Kumar Gupta, Sri Ganganagar. vk;djvk;qDr@ The ld CIT 3. 4. vk;dj vk;qDr¼vihy½@The ld CIT(A) 5. विभागीय प्रतिनिधि] आयकरअपीलीय अधिकरण] जयपुर@क्त्ए प्ज्Aज्ए Jंपचनत 6. xkMZQkbZy@ Guard File (ITA No. 458/JPR/2024 & CO No. 09/JPR2024) vkns'kkuqlkj@ By order,

सहायकपंजीकार@Aेेजज. त्महपेजतंत