Citation Codes

Equivalent Citations

citation codes

Case Number

ITA 1106/JPR/2018

Disposition

in part

Advocates

Acts

SECTION 56 INCOME TAX ACT 1961
sub-clause (viii) of clause (24) of section 2;] 54 [(ib) income referred to in sub-clause (ix) of clause (24) of section 2;] 7 55 [(ic) income referred to in sub-clause (x) of clause (24) of section 2,
clause (b) of sub-section (2)(vii),
sub-clause (ii) of clause (14) of section 2; (d) "property"70[means
sub-section (2) of section 50C; (b)
provisions of sub-section (1),
provisions of section 50C and sub-section (15) of section 155
sub-clause (xi) of clause (24) of section 2,
U/s 56(2)(b) of Income Tax Act, 1961

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Smart Summary

Concise Analytical Summary of the Opinion: ITA No.1106/JP/2018 (Assessment Year 2015-16)

Factual and Procedural Background

The appeal arises from an order dated 24/08/2018 of the Commissioner of Income Tax (Appeals), Ajmer, in respect of Assessment Year 2015-16. The assessee, Radha Kishan Kungwani (proprietor of M/s Mahendra Gulkand Works), filed a return declaring total income of Rs. 7,08,230/-. During scrutiny the Assessing Officer (A.O.) noted that the assessee purchased Flat No. 3105, E-Wing, Whispering Tower, Mulund (W), Mumbai, under a registered sale agreement dated 16/09/2014 for Rs. 1,38,03,550/-. The Sub-Registrar's valuation for stamp duty at registration was Rs. 1,53,43,036/-. The A.O. proposed an addition of Rs. 15,39,496/- under Section 56(2)(vii)(b) of the Income Tax Act—the difference between the consideration recorded in sale documents and the stamp duty valuation.

The assessee contended that the flat had been booked earlier (booking referenced as 06/09/2010 in the record) and paid earnest/advance amounts of Rs. 2,51,000 on 10/10/2010 and Rs. 9,87,090 on 14/10/2010 (total Rs. 12,38,090), and produced cheque evidence for these payments. The A.O. accepted that payments were made but rejected the claim that an earlier agreement existed, treated the stamp duty value as on the registration date, and made the addition. The CIT(A) upheld the A.O.'s addition. The assessee appealed to the Income Tax Appellate Tribunal (ITAT), Jaipur Bench ("SMC"), which heard the matter (hearing by video conference) and pronounced its order on 19/08/2020.

Legal Issues Presented

Whether the differential between the stamp duty valuation and the sale consideration should be computed with reference to the stamp duty value as on the earlier booking date/part-payment date (10/10/2010), by application of the proviso(s) to Section 56(2)(vii) of the Income Tax Act, rather than the date of registration (16/09/2014)?
Whether the facts (booking coupled with part payment by cheque and subsequent registered agreement containing the payment schedule) establish an agreement prior to registration so as to attract the proviso to Section 56(2)(vii) permitting the earlier stamp duty valuation date?

Arguments of the Parties

Appellant's Arguments

The assessee produced a letter from the builder dated 16/10/2017 confirming receipt of payments at the time of booking and confirming the booking details and amounts.
The assessee argued that the booking of the flat, together with the part payments made by cheques on 10/10/2010 and 14/10/2010, constituted an agreement to purchase within the meaning and scope of Section 56(2)(vii) proviso (i.e., an agreement prior to registration fixing the consideration).
Therefore, the appellant contended the stamp duty value should be taken as on the date of booking/payment (10/10/2010), and not as on the date of registration (16/09/2014).

Respondent's Arguments

The Departmental Representative (DR) submitted that both the A.O. and the CIT(A) had found that the assessee failed to produce any agreement dated 06/09/2010 as claimed, and that the payments made on 10/10/2010 and 14/10/2010 were not on the date of the alleged agreement.
Accordingly, the DR argued the assessee failed to satisfy the conditions of the proviso to clause (b) of Section 56(2)(vii) and relied on the findings/orders of the authorities below upholding the addition.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The Tribunal reviewed the factual matrix and statutory text relied upon by the parties. Key findings and analytical steps recorded by the Tribunal include:

Undisputed facts: the registered sale agreement dated 16/09/2014 recorded the consideration as Rs. 1,38,03,550/-, and the stamp duty valuation at registration was Rs. 1,53,43,036/-. The A.O. invoked Section 56(2)(vii) to add the difference.
The Tribunal recognized that the assessee produced evidence of part payments by cheques dated 10/10/2010 (Rs. 2,51,000) and 14/10/2010 (Rs. 9,87,090), and that the A.O. did not dispute that those payments were made.
The assessee also produced a builder's confirmation letter dated 16/10/2017 confirming the booking and receipt of the specified payments; the Tribunal noted this confirmation was not disputed by the A.O.
The registered (final) agreement dated 16/09/2014 contained a payment schedule tied to various stages of project completion, which the Tribunal interpreted as evidence that the terms and payment structure were agreed at the time of booking and were incorporated into the final agreement.
Applying the plain language of Section 56(2)(vii) and its provisos, the Tribunal reasoned that where (a) an agreement fixing consideration exists prior to registration, and (b) the purchaser has paid consideration or part thereof by a mode other than cash on or before the date of such earlier agreement, the stamp duty value on the earlier agreement date may be taken for the purpose of the provision. The Tribunal found these conditions satisfied on the facts: booking + part payments by cheque showed an agreement between parties at the time of booking.
Consequently, the Tribunal concluded that the proviso to Section 56(2)(vii) applied and that the stamp duty/fair market value should be determined as on the date of booking/part payment (treated in the order as 10/10/2010).
On that basis, the Tribunal set aside the orders of the lower authorities and remanded the matter to the Assessing Officer to apply stamp duty valuation as on 10/10/2010; if the stamp duty valuation on that earlier date exceeds the purchase consideration then the difference would be chargeable under Section 56(2)(vii)(b).

Holding and Implications

APPEAL ALLOWED FOR STATISTICAL PURPOSES

Direct effect on the parties:

The Tribunal allowed the assessee's appeal (for statistical purposes) and set aside the orders of the A.O. and CIT(A) to the extent they applied stamp duty valuation as on the date of registration (16/09/2014).
The matter was remanded to the Assessing Officer with directions to apply the stamp duty valuation as on the date of booking/part payment (identified in the order as 10/10/2010). Thereafter, if the stamp duty valuation so determined is higher than the consideration actually paid, the excess would be liable to be added to the assessee's income under Section 56(2)(vii)(b) of the Income Tax Act.

Broader implications: The Tribunal's decision turns on the factual finding that booking plus part payment by non-cash mode established an earlier agreement for the purpose of the proviso to Section 56(2)(vii). The opinion does not purport to lay down a new legal precedent beyond its application to the facts; no case law precedents were cited in this order.

Order pronounced in open court on 19 August 2020. Bench: Shri Vijay Pal Rao (Judicial Member) & Shri Vikram Singh Yadav (Accountant Member). Appeal number and parties as recorded in the opinion: ITA No.1106/JP/2018; Appellant: Radha Kishan Kungwani (proprietor M/s Mahendra Gulkand Works); Respondent: I.T.O., Ward 1(2), Ajmer.

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RADHA KISHAN KUNGWANI, AJMER v. INCOME TAX OFFICER, WARD-1-2, AJMER

vk;dj vihyh; vf/kdj.k] t;iqj U;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES "SMC",

JAIPUR

Jh fot; iky jko] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy l-a @ITA No. 1106/JP/2018

fu/kZkj.k o"kZ@Assessment Year :2015-16

Radha Kishan Kungwani, cuke I.T.O.

Prop.- M/s Mahendra Gulkand Vs. Ward 1(2),

Works, 381/22, Nawab Ka Bera, Ajmer.

Ajmer, Raj-305001.

LFkk;h y[s kk la-@thvkbZvkj la-@PAN/GIR No.: AINPK 6120 G vihykFkhZ@Appellant izR;FkhZ@Respondent

fu/kZkfjrh dh vksj l@s Assessee by: Shri Sunil Porwal (CA) jktLo dh vksj ls@ Revenue by : Ms. Chanchal Meena (Addl.CIT) lquokbZ dh rkjh[k@ Date of Hearing : 18/08/2020

mn?kks"k.kk dh rkjh[k@ Date of Pronouncement : 19/08/2020

vkns'k@ ORDER

PER: VIJAY PAL RAO, J.M.

This appeal by the assessee is directed against the order dated 24/08/2018 of the ld. CIT(A), Ajmer for the A.Y. 2015-16. The assessee has raised following grounds:

"Under the facts and circumstances of the case, the ld. CIT(A) has erred in:

1. Confirming the addition of Rs. 15,39,496/- U/s 56(2)(b) of Income Tax Act, 1961 as inadequate consideration.

2. Any other matter with the prior permission of chair."

2. The hearing of the appeal was concluded through video conference in view of the prevailing situation of Covid-19 Pandemic. The assessee is proprietor of M/s Mahendra Gulkand Works and filed his return of income on 29/09/2015 declaring total income of Rs.7,08,230/-. During the scrutiny assessment, the A.O. noted that the assessee has purchased a Flat No. 3105, E-Wing, Whispering Tower, LBS Marg, Mulund (W), Mumbai for a consideration of Rs. 1,38,03,550/- on 17/09/2014 whereas the Sub-Registrar, Mumbai has determined the market value for the purpose of stamp duty at Rs. 1,53,43,036/-. Accordingly, the A.O. proposed to invoke provisions of Section 56(2)(b) of the Income Tax Act, 1961 (in short, the Act) to make the addition of the differential amount between the same consideration shown in the sale documents and stamp duty valuation taken by the Sub-Registrar. The assessee has explained that the flat was booked by the assessee on 10/10/2010 and an amount of Rs. 12,38,090/- was paid as earnest money at the time of booking of the said flat. The assessee produced proof of payment on 10/10/2010 as well as 14/10/2010 of Rs. 2,51,000/- and Rs. 9,87,090/- respectively through cheques. Though, the A.O. has not disputed the payment made by the assessee on 10/10/2010 and 14/10/2010, however, the A.O. has denied this claim of the assessee and taking fair market value of the flat as on the date of

booking in view of provisions of Section 43-CA of the Act on the ground that the assessee has not produced any agreement prior to the sale agreement registered on 17/09/2014. The A.O. accordingly, made an addition of Rs. 15,39,496/- being the difference between the stamp duty valuation and the sale consideration shown by the assessee.

4. The assessee challenged the action of the A.O. before the ld. CIT(A) but could not succeed as the ld. CIT(A) has upheld the addition made by the A.O. on the similar reasoning that the assessee has failed to produce the agreement with the builder at the time of booking of the flat.

5. Before us, the ld AR of the assessee has submitted that the assessee has produced the letter issued by the builder dated 16/10/2017 wherein the builder has confirmed the amount received at the time of booking through cheques and therefore, the booking itself is an agreement of purchase of the flat in question. Thus, the ld AR has submitted that once the assessee has brought on record a documentary evidence for the part payment of the purchase consideration on 10/10/2010 and 14/10/2010 through cheques and the builder has accepted the booking of the flat by the assessee on 06/09/2010 then the booking of purchase of flat coupled with the payment made by the

assessee in pursuant to the booking of the flat constitute an agreement as provided U/s 56(2)(vii) of the Act. Thus, the ld AR has contended that the A.O. has wrongly adopted the stamp duty value as on the date of registration of the produced document on 16/09/2014 instead of stamp duty valuation on 06/09/2010.

6. On the other hand, the ld DR has submitted that the A.O. as well as the ld. CIT(A) has given a finding that the assessee has failed to produce any agreement as claimed by the assessee dated 06/09/2010 even the payments made by the assessee on 10/10/2010 and 14/10/2010 are not on the date of alleged agreement, therefore, the assessee has failed to satisfy the conditions provided in proviso to clause

(b) of Section 56(2)(vii) of the Act. She has relied on the orders of the authorities below.

7. We have considered the rival submissions as well as relevant material on record. There is no dispute that the assessee has purchased a flat in question from HDIL vide sale agreement dated 16/09/2014 registered with Sub-Registrar, Mumbai for a consideration of Rs. 1,38,03,550/-. The valuation made for the purpose of stamp duty purposes at the time of registration is at Rs. 1,53,43,036/-. The A.O. has invoked the provisions of Section 56(2)(vii) of the Act for making the

addition of the differential amount between the stamp duty valuation and purchase consideration paid by the assessee. The assessee has claimed that the assessee booked this flat on 06/09/2010 and made advance payment of Rs. 2,51,000/- on 10/10/2010 and Rs. 9,87,090/- on 14/10/2010 total amounting to Rs. 12,38,090/-. The A.O. has not disputed these payments made by the assessee vide two cheques dated 10/10/2010 and 14/10/2010. The only dispute is regarding whether the stamp duty valuation has to be taken as on the date of booking of the flat and part payment made by the assessee or at the time of final registration of the purchased document. The assessee produced confirmation of the builder regarding the payments received at the time of booking of flat of Rs. 2,51,000/- and Rs. 9,87,090/- through cheques. Vide letter dated 16/10/2017, the builder has specifically confirmed that the cost of flat is Rs. 1,38,03,550/- and the booking was done by payment of Rs. 2,51,000/- by cheque dated 10/10/2010 drawn on Andhra Bank. This fact is otherwise not disputed by the A.O. We further note that even in the final agreement which is registered on 16/09/2014, the payment schedule is given which is as per the various stages of completion of project, therefore, the parties at the time of booking, agreed for the payment as it is part of the agreement registered on 16/09/2014. All these facts and undisputed part payment

made by the assessee through cheques on 10/10/2010 and 14/10/2010 clearly established that at the time of booking, there was an agreement between the parties regarding the purchase and sale of the flat in question and payment of the purchase consideration as per the agreed schedule between the parties. Thus, even if there is no separate agreement between the parties in writing but the agreement which is registered itself shows that the terms and conditions as contained in the said agreement were agreed between the parties at the time of booking of the flat. Hence, in our considered opinion that there was an agreement between the parties regarding purchase and sale of flat in question at the time of booking of the said flat and part payment made by the assessee on 10/10/2010 through cheque and there is subsequent payment on 14/10/2010 through cheque. Thus, the booking of the flat and part payment by the assessee constitute agreement between the parties as the terms and conditions which are reduced in writing in the agreement registered on 16/09/2014 relates to the performance of both the parties right from the beginning i.e. date of booking of the flat. The provisions of Section 56(2)(vii) of the Act reads as under:

56. (2) In particular, and without prejudice to the generality of the provisions of sub-section (1), the following incomes, shall be chargeable to income-tax under the head "Income from other sources", namely :—

(i) dividends ; 53 [(ia) income referred to in sub-clause (viii) of clause (24) of section 2;] 54 [(ib) income referred to in sub-clause (ix) of clause (24) of section 2;]

55 [(ic) income referred to in sub-clause (x) of clause (24) of section 2, if such income is not chargeable to income-tax under the head "Profits and gains of business or profession";]

56 [(id) income by way of interest on securities, if the income is not chargeable to income-tax under the head "Profits and gains of business or profession";]

(ii) income from machinery, plant or furniture belonging to the assessee and let on hire, if the income is not chargeable to income-tax under the head "Profits and gains of business or profession";

(iii) where an assessee lets on hire machinery, plant or furniture belonging to him and also buildings, and the letting of the buildings is inseparable from the letting of the said machinery, plant or furniture, the income from such letting, if it is not chargeable to income-tax under the head "Profits and gains of business or profession";

57 [(iv) income referred to in sub-clause (xi) of clause (24) of section 2, if such income is not chargeable to income-tax under the head "Profits and gains of business or profession" or under the head "Salaries";]

58 [(v) where any sum of money exceeding twenty-five thousand rupees is received without consideration by an individual or a Hindu undivided family from any person on or after the 1st day of September, 2004⁵⁹[but before the 1st day of April, 2006], the whole of such sum :

Provided that this clause shall not apply to any sum of money received—

(a) from any relative; or

(b) on the occasion of the marriage of the individual; or

(d) in contemplation of death of the payer; or 60 [(e) from any local authority as defined in the Explanation to clause (20) of section 10; or

(f) from any fund or foundation or university or other educational institution or hospital or other medical institution or any trust or institution referred to in clause (23C) of section 10; or

(g) from any trust or institution registered under section 12AA^60a[or section 12AB].]

Explanation.—For the purposes of this clause, "relative"⁶¹

means—

(i) spouse of the individual;

(ii) brother or sister of the individual;

(iii) brother or sister of the spouse of the individual;

(iv) brother or sister of either of the parents of the individual;

(v) any lineal ascendant or descendant of the individual;

(vi) any lineal ascendant or descendant of the spouse of the individual;

(vii) spouse of the person referred to in clauses (ii) to (vi);] 62 [(vi) where any sum of money, the aggregate value of which exceeds fifty thousand rupees, is received without consideration, by an individual or a

Hindu undivided family, in any previous year from any person or persons on or after the 1st day of April, 2006⁶³[but before the 1st day of October, 2009], the whole of the aggregate value of such sum:

Provided that this clause shall not apply to any sum of money received—

(a) from any relative; or

(b) on the occasion of the marriage of the individual⁶⁴; or

(d) in contemplation of death of the payer; or

(e) from any local authority as defined in the Explanation to clause (20) of section 10; or

(f) from any fund or foundation or university or other educational institution or hospital or other medical institution or any trust or institution referred to in clause (23C) of section 10; or

(g) from any trust or institution registered under section 12AA^64a[or section 12AB].

Explanation.—For the purposes of this clause, "relative" means—

(i) spouse of the individual;

(ii) brother or sister of the individual;

(iii) brother or sister of the spouse of the individual;

(iv) brother or sister of either of the parents of the individual;

(v) any lineal ascendant or descendant of the individual;

(vi) any lineal ascendant or descendant of the spouse of the individual;

(vii) spouse of the person referred to in clauses (ii) to (vi);] 65 [(vii) where an individual or a Hindu undivided family receives, in any previous year, from any person or persons on or after the 1st day of October, 2009 ⁶⁶[but before the 1st day of April, 2017],—

(a) any sum of money, without consideration, the aggregate value of which exceeds fifty thousand rupees, the whole of the aggregate value of such sum;

67 [(b) any immovable property,—

(i) without consideration, the stamp duty value of which exceeds fifty thousand rupees, the stamp duty value of such property;

(ii) for a consideration which is less than the stamp duty value of the property by an amount exceeding fifty thousand rupees, the stamp duty value of such property as exceeds such consideration:

Provided that where the date of the agreement fixing the amount of consideration for the transfer of immovable property and the date of registration are not the same, the stamp duty value on the date of the agreement may be taken for the purposes of this sub-clause:

Provided further that the said proviso shall apply only in a case where the amount of consideration referred to therein, or a part thereof, has been paid by any mode other than cash on or before the date of the agreement for the transfer of such immovable property;]

(i) without consideration, the aggregate fair market value of which exceeds fifty thousand rupees, the whole of the aggregate fair market value of such property;

(ii) for a consideration which is less than the aggregate fair market value of the property by an amount exceeding fifty thousand rupees, the aggregate fair market value of such property as exceeds such consideration :

Provided that where the stamp duty value of immovable property as referred to in sub-clause (b) is disputed by the assessee on grounds mentioned in sub-section (2) of section 50C, the Assessing Officer may refer the valuation of such property to a Valuation Officer, and the provisions of section 50C and sub-section (15) of section 155 shall, as far as may be, apply in relation to the stamp duty value of such property for the purpose of sub-clause (b) as they apply for valuation of capital asset under those sections :

Provided further that this clause shall not apply to any sum of money or any property received—

(a) from any relative; or

(b) on the occasion of the marriage of the individual; or

(d) in contemplation of death of the payer or donor, as the case may be; or

(e) from any local authority as defined in the Explanation to clause (20) of section 10; or

(f) from any fund or foundation or university or other educational institution or hospital or other medical institution or any trust or institution referred to in clause (23C) of section 10; or

(g) from any trust or institution registered under section 12AA ^67a[or section 12AB]; ⁶⁸[ or]

68 [(h) by way of transaction not regarded as transfer under clause (vicb) or clause (vid) or clause (vii) of section 47.] Explanation.—For the purposes of this clause,—

(a) "assessable" shall have the meaning assigned to it in the Explanation 2 to sub-section (2) of section 50C;

(b) "fair market value" of a property, other than an immovable property, means the value determined in accordance with the method as may be prescribed⁶⁹;

(c) "jewellery" shall have the meaning assigned to it in the Explanation to sub-clause (ii) of clause (14) of section 2;

(d) "property"⁷⁰[means the following capital asset of the assessee, namely:—]

(i) immovable property being land or building or both;

(ii) shares and securities;

(iii) jewellery;

(iv) archaeological collections;

(v) drawings;

(vi) paintings;

(vii) sculptures; ⁷¹[***]

(viii) any work of art; ⁷²[or]

72 [(ix) bullion;]

73 [(e) "relative" means,—

(i) in case of an individual—

(A) spouse of the individual;

(B) brother or sister of the individual;

(D) brother or sister of either of the parents of the individual;

(E) any lineal ascendant or descendant of the individual;

(F) any lineal ascendant or descendant of the spouse of the individual;

(G) spouse of the person referred to in items

(B) to (F); and

(ii) in case of a Hindu undivided family, any member thereof;]

(f) "stamp duty value" means the value adopted or assessed or assessable by any authority of the Central Government or a State Government for the purpose of payment of stamp duty in respect of an immovable property;]

Thus, as per clause (b) of sub-section (2)(vii), if the assessee has received immovable property for a consideration which is less than the stamp duty value, the value of such property as exceeds such

consideration shall be chargeable to income tax under the head income from other sources. However, the first and second proviso carve out the exception for taking stamp duty value on the date of agreement prior to the date of registration if an amount of consideration or part thereof has been paid by any mode other than the cash before the date of agreement for transfer of such immovable property. Therefore, if there is an agreement between the parties, fixing the amount of consideration for transfer of immovable property prior to the date of registration and the purchaser has made the payment of consideration or part thereof before the date of that registered agreement for transfer by any mode other than cash then the value as determined for the stamp duty will be taken on the date of such earlier agreement. In the case in hand, all these facts are duly acknowledged by the parties in the registered agreement that earlier there was a booking of flat and the assessee paid part payment of consideration. Hence, the proviso first and second to Section 56(2)(vii) of the Act would be applicable in the case and the

stamp duty valuation or the fair market value of the immovable property shall be considered as on the date of booking and payment made by the assessee towards booking of the flat. Accordingly, the orders of the authorities below are set aside and the matter is remanded to the record of the A.O. to apply the stamp duty valuation as on 10/10/2010 when

the assessee booked the flat and made the part payment of consideration and consequently, if any difference being the stamp duty valuation is higher than the purchase consideration paid by the assessee, the same would be added to the income of the assessee under the provisions of Section 56(2)(vii)(b) of the Act.

8. In the result, appeal of the assessee is allowed for statistical purposes.

Order pronounced in the open court on 19^thAugust, 2020. Sd/- Sd/-

¼foØe flag ;kno½ ¼fot; iky jko½

(VIKRAM SINGH YADAV) (VIJAY PAL RAO)

ys[kk lnL;@Accountant Member U;kf;d lnL;@Judicial Member Tk;iqj@Jaipur

fnukad@Dated:- 19/08/2020

*Ranjan

vkns'k dh izfrfyfi vxzsf'kr@Copy of the order forwarded to:

1. vihykFkhZ@The Appellant- Shri Radha Kishan Kungwani, Ajmer.

2. izR;FkhZ@ The Respondent- I.T.O. Ward 1(2), Ajmer.

3. vk;dj vk;qDr@ CIT

4. vk;dj vk;qDr¼vihy½@The CIT(A)

5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur

6. xkMZ QkbZy@ Guard File (ITA No.1106/JP/2018) vkn's kkuqlkj@ By order,

lgk;d iathdkj@Asst. Registrar

RADHA KISHAN KUNGWANI, AJMER v. INCOME TAX OFFICER, WARD-1-2, AJMER

Concise Analytical Summary of the Opinion: ITA No.1106/JP/2018 (Assessment Year 2015-16)

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

Appellant's Arguments

Respondent's Arguments

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

RADHA KISHAN KUNGWANI, AJMER v. INCOME TAX OFFICER, WARD-1-2, AJMER

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