PREM PRAKASH AGARWAL,NAYA BAZAR AJMER vs. DCIT CENTRAL CIRCLE AJMER, JAIPUR ROAD AJMER

PER BENCH These two appeals are filed by the assessee aggrieved from the order of the Commissioner of Income Tax (Appeals), Jaipur-5 [Here in after referred as (CIT(A))] for the assessment year 2013- 14 & 2016-17 dated 08.12.2023, which in turn arises from the order passed by the DCIT, Central Circle, Ajmer passed under Section 271(1)(c) of the Income tax Act, 1961 (in short 'the Act') dated 23.03.2022.

2 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT 2. Since the issues involved in the assessee’s appeal for both

the assessment years are almost identical and are almost

common, except the difference in figure of penalty disputed,

therefore, both these appeals were heard together with the

agreement of both the parties and are being disposed off by this

consolidated order.

No. 755/JP/2023 may be taken as a lead case for discussions as

the issues involved in the lead case are common and inextricably

interlinked or in fact interwoven and the facts and circumstances of

other cases are identical except the difference in the amount of

penalty in other assessment year. The ld. DR did not raise any

specific objection against taking that case as a lead case.

Therefore, for the purpose of the present discussions, the case of

ITA No. ITA No. 755/JP/2023 is taken as a lead case. Based on

the above arguments we have also seen that for both the appeals

grounds are similar, facts are similar and arguments were similar

and therefore, were heard together and are disposed by taking

3 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT lead case facts, grounds, and arguments from the folder in ITA No.

755/JP/2023.

mention that the assessee has assailed the appeal in ITA No.

755/JP/2023 on the following grounds;

“1. That the penalty order confirmed by the ld. CIT(A) is bad in law as which is based on notice u/s 274 r.w.s 271(1)(c) which does not unambiguously state whether the Appellant has concealed its income or furnished inaccurate particulars thereof. 2. That Ld. CIT(A) in the order has not considered the fact regarding satisfaction whether the Appellant has concealed its income or furnished inaccurate particulars thereof. 3. On the facts and in the circumstances of the case the CIT(A) has grossly erred in confirming the penalty of Rs. 6,20,000/- u/s 271(1)(c) of the IT. Act, 1961, for the assessment year 2013-14. The appellant craves leave to add, alter, amend or withdraw any of the grounds of appeal during the course of appellate proceedings.”

seizure action u/s 132 of I.T. Act, 1961 was carried out on

12.09.2018 at the residential and business premises of R. P.

Group of Ajmer. Various assets had been found at the time of

search and some of them were also seized at various places of the

group at the time of action u/s 132 of I.T. Act. Certain incriminating

documents/Loose papers/Books of accounts etc. were also found,

4 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT inventorized and some of them also seized or impounded at the

time of search/survey u/s 132/133A of the IT. Act.

5.1 The assessee is associated with the above Group. In the

instant case the assessee has filed its original ROI u/s 139(1) of

the IT. Act, 1961 on 28.03.2014 declaring thereon total income of

Rs. 7,84,830/-. Total income of Rs. 7,84,830/- was offered in the

return of income filed on 12.06.2019 in compliance to notice u/s

153A of the IT. Act, 1961. However, the assessee had submitted a

revised computation of income u/s 153A in which total income was

shown at Rs. 28,46,470 but the same was not given any

cognizance in the assessment proceedings owing to the reason

that there is no such provision available in the Act to revise a

return filed in response to notice u/s 153A of the IT. Act, 1961.

5.2 During the course of assessment proceedings, the assessee

was asked to given the explanation of all the exhibits seized at the

time of search proceedings. In response the assessee, submitted

that some of these deals with the details of the property sold and

purchased by all Agarwal family. The assessee Sh. Prem Prakash

5 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT Agarwal was indulged in property brokerage business which the

assessee has disclosed in the assessment proceeding for Rs.

20,61,640/-. The same was considered as undisclosed brokerage

income and consequent to that action the ld. AO also levied the

penalty u/s. 271(1)(c) of the act vide order dated 23.03.2022

contending that the assessee has concealed the income as per

provision of section 271(1)(c) of the Act and thereby hold the

assessee liable to pay a sum of Rs. 6,20,000/-

an appeal before the ld. CIT(A). Apropos to the grounds so raised

by the assessee, the relevant finding of the ld. CIT(A) is reiterated

here in below:

“5.13 In the instant case, it is evident that during the course of assessment proceedings, the assessee had offered the undisclosed brokerage income of Rs. 20,61,640/- for taxation but the assessee had not disclosed this income in the return of income filed in response to notice issued u/s 153A of the I.T. Act, 1961. Meanwhile during the course of assessment proceedings, the assessee had submitted a revised computation of income declaring therein undisclosed brokerage income of Rs. 20,61,640/-. It shows that the assessee was aware with the facts of the case and entries found in the seized material and consequences of hiding the true facts of the case. The assessee had not voluntarily offered the undisclosed brokerage income of Rs. 20,61,640/- but it was based on the facts and the entries found in the seized material. 5.14 In view of the above narrated facts and circumstances of the case, I am of the considered opinion that the appellant has failed to prove that

6 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT there was no concealment of income and I hold that the AO has rightly imposed a penalty u/s 271(1)(c) of the Act for concealment of income.”

assessee preferred the present appeal on the grounds as stated

here in above. In support of the grounds so raised by the assessee

the ld. AR of the assessee, he has relied upon the following written

submission.

“Most respectfully, the humble appellant submits that the present appeal has been filed against the order dated 08/12/2023 passed by the Ld CIT (A) Jaipur -5 whereby the Ld CIT (A) has dismissed the appeal in toto, summarily rejecting all submissions/contentions of the appellant. Ld CIT (A) confirmed the penalty u/s 271(1) (c) of the Income Tax Act levied by the Ld Assessing Officer at Rs 6, 20,000/ Brief facts of the case as also noted by the Ld CIT (A) in his order are as under: “ Para 3.1 A search and seizure action u/s 132 of the I.T.Act, 1961 was carried out on 12.09.2018 at the residential and business premises of R.P.Group of Ajmer. Various assets along with certain incriminating documents/loose papers/Books of accounts etc. were also found, inventoried and some of them were also seized or impounded at the time of Search/Survey u/s 132/133A of the I.T.Act,1961. 3.2 The assessee is associated with the above Group. In the instant case the assessee has filed its original ROI u/s 139(1) of the I.T.Act,1961 on 28.03.2014 declaring thereon total income of Rs. 7,84,830/-. Total income of Rs. 7, 84,830/- was offered in the return of income filed on 12.06.2019 in compliance to notice u/s 153A of the I.T. Act, 1961. However, the assessee had submitted a revised computation of income u/s 153A in which total income was shown at Rs. 28, 46,470/- but the same was not given any cognizance in the assessment proceedings owing to reason that there is no such provision available in the Act to revise a return filed in response to notice u/s 153A of the I.T.Act,1961. Decision of the LD CIT (A)

7 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT In deciding the appeal the Ld CIT (A) observed as under:

“5. Decision (For grounds 1-3) I have considered the facts of the case, gone through the relevant assessment orders, penalty orders and the paper-book & submission of the appellant and the various case laws. All grounds are related to only imposing penalty u/s 271(1) (c) of the I.T.Act, 1961, therefore all of them are taken as together. The contentions/ submissions of the appellant are being discussed and decided as under:

5.3 During the course of assessment proceedings, the assessee had offered an amount of Rs. 20, 61,640/- on account of brokerage income which was neither disclosed in the original return of income filed u/s 139(1) of the I.T. Act, 1961 nor in the return of income filed in response to notice issued u/s 153A of the I.T. Act, 1961 for the A.Y.2013-14.

5.6 As per the provisions of section 271(1) (c) of the I.T. Act 1961, the assessee was liable to pay the amount of tax evaded as penalty on the undisclosed income of the specified previous year by way of penalty in addition to tax payable by it as the undisclosed income was neither declared in the ITR filed u/s 139(1) of the Act nor in the return submitted in response to the Notice issued u/s 153A of the Act.

5.9 The appellant had relied on the judgments of

Hon’ble High Court of Madya Pradesh in the case of CIT Vs Suresh Chand Mittal 241ITR124 (2000) MP

Supreme Court Judgement in Sir Shadilal Sugar and General Mills Ltd. Vs. CIT, [1987]168 ITR 705

Hon’ble ITAT Delhi Bench in the case of M.G.Contractors Pvt.Ltd. Vs DCIT, Central Circle-1, Faridabad in ITA Nos 7034 to 7038/Del/2014 and many others…..

The facts of the above referred cases are different from the present case. In the present case during the course of assessment proceedings, the assessee was asked to give the explanation of all the exhibits seized at the time of search proceedings. In response the assessee, submitted that some of these deals with the details of the property sold and purchased by the all Agarwal family. The assessee Shri Prem Prakash Agarwal was indulged in property brokerage business. These pages were showing brokerage receivable, received, accruing and net amount of brokerage at the end of relevant diwali. The net amount mentioned on these papers which was offered by the assessee as income from brokerage.

8 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT 5.13 In the instant case, it is evident that during the course of assessment proceedings, the assessee had offered the undisclosed brokerage income of Rs.20,61,640/- for taxation but the assessee had not disclosed this income in the return of income filed in response to notice issued u/s 153A of the I.T. Act, 1961. Meanwhile during the course of assessment proceedings, the assessee had submitted a revised computation of income declaring therein undisclosed brokerage income of Rs. 20,61,640/-. It shows that the assessee was aware with the facts of the case and entries found in the seized material and consequences of hiding the true facts of the case. The assessee had not voluntarily offered the undisclosed brokerage income of Rs. 20, 61,640/- but it was based on the facts and the entries found in the seized material.

5.14 In view of the above narrated facts and circumstances of the case, I am of the considered opinion that the appellant has failed to prove that there was no concealment of income and I hold that the AO has rightly imposed a penalty u/s 271(1)(c) of the Act for concealment of income.”

From the decision of the Ld CIT (A) it is clearly discernible that the Ld CIT (A) has not categorically held that the jurisdiction to levy penalty was validly assumed by the Assessing Officer as the assessee was not confronted with the specific charge of Section 271(1)(c) of the Income Tax Act by the Ld Assessing Officer. Ld CIT(A) only observed that the undisclosed interest income detected pertains to specified previous year and in the assessment order, the AO had made addition only on account of undisclosed income. Hence the contention of the appellant is not acceptable that the notices were without specifying the default of the assessee and without specifying that whether the appellant has concealed its income or furnished inaccurate particulars thereof.

Evidently, the ground of appeal has been dismissed by the Ld CIT (A) in a very casual manner. Here ld CIT (A) is mentioning that the undisclosed interest income detected pertains to specified previous year and in the assessment order, the AO had made addition only on account of undisclosed income, whereas addition to the income was of income from brokerage offered to tax by the appellant himself during the course of assessment proceedings, by way of filing revised computation of income and paying taxed due thereon.

So far as the merits of the case are concerned, Ld CIT (A) confirmed the levy of penalty merely for the reason that the income offered to tax by way of revised computation was not disclosed in the return of income. Only for this reason, Ld CIT (A) held that the case laws relied upon by the Appellant are distinguishable. In this regard observations of the Ld CIT (A) are reproduced again for ready reference;

9 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT

“ As per the provisions of section 271(1)( c) of the I.T. Act 1961, the assessee was liable to pay the amount of tax evaded as penalty on the undisclosed income of the specified previous year by way of penalty in addition to tax payable by it as the undisclosed income was neither declared in the ITR filed u/s 139(1) of the Act nor in the return submitted in response to the Notice issued u/s 153A of the Act”.

In this regard it is submitted that filing of revised computation of income during the course of assessment proceedings tantamount to filing the revised return of income. The Ld Assessing Officer though observed that there is no provision for revising the return filed u/s 153A, however, it remains an undisputed fact that assessment of total income has been made only by accepting the revised computation of income. Ld Assessing Officer has not given any independent findings nor has independently computed any income on the basis of entries/ recordings in loose papers. Whatever has been offered by the appellant by way of revised computation has been accepted as such merely with the observation that there is no provision for revising return filed u/s 153A. Despite that, revised computation has not been rejected but duly accepted by the Ld Assessing Officer and assessment has been made only on the revised computation of income. In the circumstances, the appellant cannot be held guilty of concealing or furnishing inaccurate particulars of his income when income has duly been offered to tax and taxes due thereon has also been paid during the course of assessment proceedings itself.

It is submitted that filing of revised computation during the course of assessment proceedings which has duly been accepted by the department without any variation amounts to full and true disclosure of particulars of income. In this regard reference can be gainfully made to the decision of Hon’ble High Court of Gujarat in the case of Cheldas Khushaldas Patel And Ors. vs Commissioner Of Income-Tax 1992, 196 ITR 200 Guj wherein the Hon’ble High Court held as under:

“ 7. The Commissioner, in the case of the firm, refused to waive penalty and interest for the assessment years 1976-77 and 1977-78 only on the ground that the returns filed beyond the prescribed period could not be considered to be returns in the eye of law. As pointed out above, since the returns for the said two assessment years were filed beyond the period prescribed for making assessment, the Income-tax Officer issued notice under section 148 of the Act and at the request of the petitioners treated the returns which were earlier filed as returns filed in response to the notice under section 148. It is urged on behalf of the Revenue that disclosure of income voluntarily and in good faith, as envisaged under sub-clauses (a) and (c) of sub-section (1), could be

10 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT made only by filing a valid return and, if disclosure was not made by a valid return, such disclosure could not be considered, even if it was made voluntarily and in good faith

Thus, in view of the legal position as to the true import of filing revised computation of income, explained by the Hon’ble High Court of Gujarat, the appellant cannot be held guilty of not furnishing correct particulars of its income. Merely because there is no express provision u/s 153A of the Act for revising the return of income, the revised computation which has the effect of substituting the original computation and particularly in the circumstances when the revised computation has not been tinkered

11 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT with by the Ld AO in any manner and has been accepted as it is, the assessee should not be visited with a penalty for citing technicalities alone. Evidently, the revised computation of income is in substitution of original computation of income and has to be treated as such. In the circumstances, the appellant cannot be visited with a penalty.

In support of the submission that penalty cannot be levied in the peculiar facts and circumstances of the case of the appellant, in addition to the various judicial authorities cited before the Ld CIT(A) which have also been noted by the Ld CIT(A) at para 5.9 of his order, it is submitted that the Hon’ble Ahmedabad Bench of the Tribunal in a recent decision dated 17th May 2023 in the case of DCIT, Central Circle-1(1), Ahmedabad v. NBM Iron & Steel Trading Pvt. Ltd. [ITA No. 205/Ahd/2022, dated May 17, 2023] held that if an assessee during a survey surrendered his income and later showed that income in his regular income tax return, no penalty can be imposed on the assessee. Delhi Bench of the Hon’ble ITAT in the case of ACIT vs. Ashok Raj Nath [2015-ITR V-ITAT-MUM-129] has held that when the assessee voluntary disclosed additional income in the course of assessment proceedings and paid tax thereon and revenue has not placed any material that assessee want to conceal his income there is no basis arises for imposition of penalty. Hon’ble Punjab High Court in the case of CIT vs. Suraj Bhan [2007] 159 Taxman 26 has held that penalty could not be imposed when assessee has filed revised return showing higher income and give explanation that higher income was offered to buy peace of mind and to avoid litigation. Hon’ble ITAT Mumbai Bench in the case of ITO vs. Gope M. Rochlani [2013-ITRV-ITAT-MUM-119] has held that undisclosed income offered in belated return filed u/s 139(4) is eligible for immunity from penalty under Explanation 5 to s. 271(1)(c). Similar views were expressed in Hon’ble Gujarat High Court in case of Kirit Dayabhai patel V ACIT (ITA 1181 of 2010) and hold that if income is disclosed in the return filed u/s153A , no penalty is attracted In the circumstances, it is prayed that the penalty levied by the Ld Assessing Officer and upheld by Ld CIT (A) be cancelled. It is prayed accordingly.”

The ld. AR of the assessee in addition to the written submission

vehemently argued that the assessee has offered the income by

12 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT filling the revised computation of income as at that time no ITR was

filed as the assessment was continued. Since, the income is

voluntarily surrendered by filling the revised computation of income

and has paid the tax along with the interest no penalty can be

levied u/s. 271(1)(c) of the Act. To support this view he relied upon

the decision of Gujarat High Court in the case of Cheldas

Khushaldas Patel and other as quoted in the written submission.

authorities and more particularly advanced the similar contentions

as stated in the order of the ld. CIT(A). The ld. DR further argued

that ld. AO has mentioned the reasons that the assessee has not

disclosed the income in the return of income filed and it is clear

from the finding of the ld. AO and that of the ld. CIT(A) that the

assessee has concealed the particulars of income and therefore

the penalty be sustained.

placed on record. The brief facts of the case is that in the instant

case the assessee has filed its original ROI u/s 139(1) of the

13 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT I.T.Act,1961 on 28.03.2014 declaring thereon total income of Rs.

7,84,830/-. Total income of Rs. 7, 84,830/- was offered in the return

of income filed on 12.06.2019 in compliance to notice u/s 153A of

the I.T. Act, 1961. However, the assessee had submitted a revised

computation of income u/s 153A in which total income was shown

at Rs. 28, 46,470/- but the same was not given any cognizance in

the assessment proceedings owing to reason that there is no such

provision available in the Act to revise a return filed in response to

notice u/s 153A of the I.T.Act,1961. During the course of

assessment proceedings, the assessee was asked to given the

explanation of all the exhibits seized at the time of search

proceedings. In response the assessee, submitted that some of

these deals with the details of the property sold and purchased by

all Agarwal family. The assessee Sh. Prem Prakash Agarwal was

indulged in property brokerage business which the assessee has

disclosed in the assessment proceeding for Rs. 20,61,640/-. The

same was considered as undisclosed brokerage income and

consequent to that action the ld. AO also levied the penalty u/s.

271(1)(c) of the act vide order dated 23.03.2022 contending that

the assessee has concealed the income as per provision of section

14 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT 271(1)(c) of the Act and thereby hold the assessee liable to pay a

sum of Rs. 6,20,000/-. In the first appeal the ld. CIT(A) has

confirmed the action of the ld. AO in levying the penalty by holding

that

5.13 In the instant case, it is evident that during the course of assessment proceedings, the assessee had offered the undisclosed brokerage income of Rs.20,61,640/- for taxation but the assessee had not disclosed this income in the return of income filed in response to notice issued u/s 153A of the I.T. Act, 1961. Meanwhile during the course of assessment proceedings, the assessee had submitted a revised computation of income declaring therein undisclosed brokerage income of Rs. 20,61,640/-. It shows that the assessee was aware with the facts of the case and entries found in the seized material and consequences of hiding the true facts of the case. The assessee had not voluntarily offered the undisclosed brokerage income of Rs. 20, 61,640/- but it was based on the facts and the entries found in the seized material. 5.14 In view of the above narrated facts and circumstances of the case, I am of the considered opinion that the appellant has failed to prove that there was no concealment of income and I hold that the AO has rightly imposed a penalty u/s 271(1)(c) of the Act for concealment of income.”

Thus, the bench noted that it was disputed that the assessee has

offered the income by filling the computation of income at time of

the assessment proceeding and thereafter the assessment was

completed accepting that additional income declared by the

assessee by filling the computation of income and the same has

been accepted by the revenue without any change. Thus, the

assessee though surrendered the income at the time of

15 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT assessment by filling the correct computation of income and has

paid the tax due thereon along with the interest, thus, the said

disclosure hold valid without any adjustment and made good faith

voluntarily. We support this view from the decision of the Hon’ble

High Court of Gujarat in the case of Cheldas Khushalas Patel and

Ors. Commissioner of Income Tax on 31 January, 1992, 1992 196

ITR 200 Guj wherein the Hon’ble High Court held as under:-

“7. The Commissioner, in the case of the firm, refused to waive penalty and interest for the assessment years 1976-77 and 1977-78 only on the ground that the returns filed beyond the prescribed period could not be considered to be returns in the eye of law. As pointed out above, since the returns for the said two assessment years were filed beyond the period prescribed for making assessment, the Income-tax Officer issued notice under section 148 of the Act and at the request of the petitioners treated the returns which were earlier filed as returns filed in response to the notice under section 148. It is urged on behalf of the Revenue that disclosure of income voluntarily and in good faith, as envisaged under sub-clauses (a) and (c) of sub-section (1), could be made only by filing a valid return and, if disclosure was not made by a valid return, such disclosure could not be considered, even if it was made voluntarily and in good faith

16 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT section 273A. It cannot be gainsaid that the return of income discloses the total income of the assessee filing the return. Therefore, merely because the return of income is filed beyond the period prescribed for making assessment, it would not mean that it does not disclose income. As pointed out above, a return of income does disclose the total income of the assessee and such return would not cease to be disclosure of his total income, merely because it is filed beyond the period prescribed for making assessment. In other words, it is not necessary that there should be a valid return filed before the expiry of the period prescribed for making assessment for making disclosure as envisaged under sub-clauses (a) and (c) of sub-section (1) of section 273A. Sub-clause (b) of sub-section (1) also speaks about full and true disclosure of particulars of income. So far as a case covered by clause (ii) of sub-section (1) is concerned, such full and true disclosure has to be made prior to the detection by the Income-tax Officer of concealment of particulars of income or of the inaccuracy of particulars furnished in respect of such income. Such disclosure could also be by a revised return or an application or a letter addressed to the taxing authority. Disclosure contemplated by sub-clauses (a), (b) and (c) cannot have different meanings. In other words, it has the same meaning and such disclosure could be made by a return within or beyond the prescribed time for making assessment or by a letter or an application to the taxing authority.”

Respectfully following the finding of the Hon’ble Gujarat High Court

wherein the similar view is taken that if the assessee filed the letter

/ computation at the time of the assessment proceeding and such

disclosure could be treated as disclosure of income made by the

assessee and thereby does not hold liable the assessee for any

penalty u/s. 271(1)(c) of the Act.

In terms of these observations, the appeal of the assessee in

ITA no. 755/JP/2023 is allowed.

17 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT 10. The fact of the case in ITA No. 756-JP-2023 is similar to the case in ITA No. 755-JP-2023 and we have heard both the parties and persuaded the materials available on record. The bench has noticed that the issues raised by the assessee in this appeal No. 756/JP/2023 is equally similar on set of facts and grounds. Therefore, it is not imperative to repeat the facts and various

grounds raised by both the parties. Hence, the bench feels that the decision taken by us in ITA No. 755/JPR/2023 for the Assessment Year 2013-14 shall apply mutatis mutandis in the case of Prem Prakash Agarwal in ITA No. 756-JP-2023 for the Assessment Year

2016-17. In the result, both appeals of the assessee are allowed.

Order pronounced in the open court on 09/02/2024.

Sd/- Sd/- ¼ jkBkSM deys’k t;arHkkbZ ½ ¼ lanhi xkslkbZ ½ (Sandeep Gosain) (Rathod Kamlesh Jayantbhai) U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member Tk;iqj@Jaipur fnukad@Dated:- 09/02/2024 *Ganesh Kumar, PS आदेश की प्रतिलिपि अग्रेf’ात@ब्वचल वf जीम वतकमत वितूंतकमक जवरू 1. vihykFkhZ@The Appellant- Prem Prakash Agarwal, Ajmer 2. izR;FkhZ@ The Respondent- DCIT, Central Circle, Ajmer, Jaipur Road, Ajmer

18 ITA Nos. 755 & 756/JPR/2023 Prem Prakash Agarwal vs. DCIT 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 Nos. 755 & 756/JPR/2023} vkns'kkuqlkj@ By order, सहायक पंजीकार@Aेेज. त्महपेजतंत