Where Assessing Officer did not point out
any specific defect in books of account or method of accounting consistently
followed by assessee and no inflated purchases or suppressed sales or expenses
not incurred for business purposes were found, provisions of section 145(3)
were not applicable
IN THE ITAT JODHPUR BENCH
Drillcon (Raj) (P.) Ltd.
v.
Additional Commissioner of Income-tax*
HARI OM MARATHA, JUDICIAL MEMBER
AND N.K. Saini, ACCOUNTANT MEMBER
AND N.K. Saini, ACCOUNTANT MEMBER
IT Appeal Nos. 400 & 401 (Jodh.) of
2012
[ASSESSMENT YEARS 2008-09 & 2009-10]
[ASSESSMENT YEARS 2008-09 & 2009-10]
APRIL 30, 2013
Section 145 of the Income-tax Act, 1961 -
Method of accounting - Rejection of accounts [Valuation of stock] - Assessment
years 2008-09 and 2009-10 - Assessing Officer rejected books of account of
assessee on ground that proportionate expenses incurred by assessee on account
of insurance on goods in transit, fright and handling, etc., were to be added
in computation of closing stock - Whether since Assessing Officer did not point
out any specific defect in books of account or method of accounting
consistently followed by assessee and no inflated purchases or suppressed sales
or expenses not incurred for business purposes were found, provisions of
section 145(3) were not applicable - Held, yes - Whether further, all expenses
which were added by Assessing Officer on proportionate basis for valuation of
closing stock were already included in purchase and method of valuation of
assessee was cost or market price, addition in closing stock was not correct -
Held, yes [Para 9][In favour of assessee]
FACTS
■
|
The Assessing Officer having found that
the assessee had not proportionally disallowed expenses relating to insurance
on goods in transit, freight and handing entry-tax (purchase, and channel
finance bank interest, rejected books of account maintained by the assessee
and made upwards adjustment in closing stock.
|
|
■
|
The Commissioner (Appeals) confirmed
addition made by the Assessing Officer and also upheld the rejection of books
of account under section 145(3).
|
|
■
|
On second appeal :
|
HELD
Valuation of closing stock
■
|
It is noticed that the Assessing Officer
made the impugned addition by invoking the provisions of section 145(3)
however, no specific defects have been pointed out in the books of account
maintained by the assessee in regular course of its business. The Assessing
Officer did not point out any inflated purchase or suppressed sales. The
claim of the assessee was that the expenses considered by the Assessing
Officer for increasing the value of the closing stock had already been
debited in the books of account and those expenses were directly related with
the purchases because insurance on goods in the transits was incurred to
cover the transit risk and the expenses were already debited as part of the
purchase, therefore, not to be added while valuing the closing stock. Similar
was the position with regard to freight and handling expenses. The assessee
incurred freight and handling charges at the time of purchase of goods so it
was directly connected with the cost of goods purchased, it was not to be
again added while valuing the closing stock. As regards to the entry tax, the
explanation of the assessee that it was paid to the State Govt. when the
goods specified in the list under VAT Act were brought to the local area for
consumption or use, so it was directly related to the purchases and not to be
added again while valuing the closing stock, appears to be plausible.
Similarly Channel Finance Bank Interest was charged by the Bank and in this
regard the assessee has submitted that its principal companies collected
their receivables from channel finance banks and it is mandatory. The
principal companies provided 30 days credit facility against purchase of
goods and at that stage it was part of the trading expenses which were
already recorded by the assessee in its books of account.
|
|
■
|
All the expenses which were added by the
Assessing Officer on proportionate basis for the valuation of closing stock
were already included in the purchase and the method of valuation of the
assessee was cost or market price whichever was less. This fact is also clear
from col. 12(a) in form 3 CD which is part of tax audit report under section
44AB. In the said column the auditor mentioned that the valuation by the
assessee is "at cost including direct expenses or market value whichever
is less". It is also mentioned in Col. 12(b) that there was no deviation
in the above method. It is also an admitted fact that the department has
accepted the tax audit report and pointed out no discrepancy in the said
report. Therefore, the Assessing Officer was not justified in making the
addition in the valuation of the closing stock particularly when the same
valuation of the stock had also been accepted by VAT authorities and
Commercial Tax Officer in their respective assessment orders.
|
|
■
|
In the present case, it is also noticed
that for assessment year 2004-05 the assessment was framed under section 143(3)
after making proper scrutiny and valuation of the closing stock was accepted,
during the year under consideration, there is no deviation in valuing the
closing stock from the method of valuation accepted by the Department in
assessment year 2004-05, so there was no occasion to make addition in the
year under consideration as expenses pointed out by the Assessing Officer
were already included by the assessee in the cost of purchase and the stock
available with the assessee was out of purchase. Therefore, the proportionate
amount of the expenses which was already recorded in the books of account as
those were directly linked to the purchase, added by the Assessing Officer in
the valuation of closing stock, was not correct.
|
Rejection of books of account
■
|
In the present case, the Assessing
Officer while rejecting the books of account of the assessee by invoking the
provisions of section 145(3) had not given any other reason except the
observation that the proportionate expenses incurred by the assessee on
account of insurance on goods in transit, freight and handling, entry tax
(purchase) and channel finance interest, were to be added. The Assessing
Officer did not point out any specific defect in the books of account or the
method of accounting consistently followed by the assessee. It is also not
the case of the Assessing Officer that there was a deviation in valuing the
closing stock in comparison to the earlier year, no inflated purchases or
suppressed sales or expenses not incurred for the business purposes was
found. Even the gross profit declared by the assessee on turnover which was
higher in comparison to earlier year, has not been doubted by the Assessing
Officer. Therefore, the provisions of section 145(3) were not applicable to
the facts of this case and Commissioner (Appeals) was not justified in
confirming the impugned addition made by the Assessing Officer.[Para 9]
|
CASES REFERRED TO
CIT v. British Paints India Ltd. [1991]
54 Taxman 499 (SC) (para 4).
Shailendra Bardia for the Appellant. G.R. Kokani for the Respondent.
ORDER
N.K. Saini, Accountant Member - These two
appeals by the assessee are directed against the common order of CIT(A),
Udaipur dt. 22nd Aug., 2012.
2. First we will take ITA No. 400/Jd/2012
for asst. yr. 2008-09.
3. In this appeal the assessee although has
raised six grounds but only grievance relates to confirmation of addition of
Rs. 4,76,573 made by the AO on account of valuation of closing stock by
rejecting the books of account under s. 145(3) of the IT Act, 1961 (herein
referred as "the Act").
4. The facts of the case in brief are that
the assessee filed return of income on 29th Sept., 2008 showing total income at
Rs. 82,21,290 which was processed under s. 143(1) of the Act. The case was
selected for scrutiny. The AO noticed that the assessee had shown closing stock
of Rs. 3,80,85,778 as on 31st March, 2008. However, proportionate related
expenses had not been taken into account by the assessee for valuing the
closing stock as under :
(i)
|
Insurance—Goods in transit
|
19,010
|
|
(ii)
|
Freight & inward handling
|
6,59,161
|
|
(iii)
|
Entry-tax (purchase)
|
1,23,490
|
|
(iv)
|
Channel finance bank interest
|
10,18,292
|
|
(v)
|
Insurance—Goods in stock
|
94,342
|
The assessee explained that it was
consistently following the same method as in the earlier years and that
insurance for goods in transit is for covering transit risk purchase while
freight and handling expenses had been incurred at the time of purchasing the
goods. It was further stated that entry-tax had to be paid when the goods were
brought into the local area for consumption and sale as per VAT Act. As regards
to the channel finance bank interest, it was explained that the principal
company provided 30 days against purchase of goods while Channel Finance Bank
provided 60 days credit and the principal companies collect their receivables
from the Channel Finance Bank, the interest was linked to the purchase of goods
and that insurance of the goods in stock was taken for safety of the stock. The
AO did not find merit in the submissions of the assessee and was of the view
that proportionate amount of expenses had to be taken into consideration for
valuing the closing stock so that correct profits may be determined. Reliance
was placed on the judgment of' Hon'ble Supreme Court in case of CIT v. British
Paints India Ltd. [1991]
54 Taxman 499. Accordingly, the AO made an addition of proportionate
account of related expenses i.e., Rs. 4.,76,573 (25 per cent of total
expenditure of Rs. 19,06,295) which was worked out on the basis of ratio of
total purchases with the closing stock after rejecting the books of account under
s. 145(3) of the Act.
5. The assessee carried the matter to the
learned CIT(A) and the submissions made as incorporated in para 4.2 of the
impugned order are reproduced verbatim as under :
"(A) As per the second ground of
appeal there is no change in the method of accounting or basis of valuation of
the closing stock as dealt with by AO in para 9 at page Nos. 7 to 12 of the
assessment order for asst. yr. 2008-09.
The closing stock has been valued as per
normal accounting principles at cost or market price, whichever is less. The
said facts have also been stated in the audited balance sheet appearing in
accounting policies of the company and notes on account. The same practice has
been consistently followed since inception of the company.
(B) The said facts were also accepted in
the earlier assessment order under s. 143(3) for income-tax asst. yr. 2004-05
of the same appellant. The appellant company is maintaining stock records which
were produced during the assessment proceedings on 26th Oct., 2010 along with
books of account for the relevant assessment year.
(C) It is the company's practice to take
the physical stock at the end of the year and being tallied with the records
maintained thereof. The said facts have also been stated by the auditors in
their audit report. The AO while completing the assessment has overlooked the
auditor's report. The audit report is not an empty formality which has never
been controverted by the AO for valuation of the closing stock.
(D) The assessee is assessed under Rajasthan
VAT Act, 2003 and CST Act, 1956 and the trading results have been accepted by
them as per copy of the assessment filed herewith for asst. yr. 2007-08 (1st
April, 2007 to 31st March, 2008). The accounts are subject to VAT audit in
which the trading results have been accepted by the Commercial Taxes
Department. (Annex. 10)
The contentions of the assessee are
supported by CIT v. Anandha Metal Corporation [2005]
273 ITR 262 (Mad.). (Case law 2)
The AO has relied on the case CIT v. British
Paints India Ltd. [1991]
91 CTR (SC) 108 : [1991] 54 Taxman 499 (SC). The same is not applicable in
the instant case because appellant is a trading concern. Whereas the above
judgment referred the valuation of stock in processed and finished goods which
has no relevance and the facts are totally different and the case was of a manufacturer
and here is the case is of a trader and service provider and also backed by the
earlier assessment of the AO under scrutiny for asst. yr. 2004-05 duly
supported by citation in the case of I.G.E. (India) Ltd. v. Jt CIT [2008]
26 SOT 367 (Mumbai) and decision of High Court of Allahabad CIT v. Ema
India Ltd. (Case law 3)
(E) The observation made by the learned AO
for increase in the value of the closing stock in the light of certain expenses
narrated in para 9 of the assessment order, the said items for valuation have
already been considered in the closing stock and clearly appearing in the Sch.
3 of the audited P&L a/c. In addition to this the said fact was also
mentioned in submissions made vide letter dt. 9th March, 2010.
(F) That on the facts and circumstances of
the case and in law, the learned AO grossly erred in making upward adjustment
of the closing stock valuation amounting to Rs. 4,76,573 without pointing out
any defect in the method of accounting and merely on hypothetical basis based
on suspicion. Without appreciating that the assessee's case is factually supported
by all the records for purchases, sales, sale bills, etc. and legally backed by
Supreme Court (five Judge bench order) in the case of Chainrup Sampatram v. CIT
[1953]
24 ITR 481 (SC) upheld in Voltamp Transfomers Ltd. v. CIT [2008]
217 CTR (Guj.) 254 : [2008] 7 DTR (Guj.) 84 : [2008] 327 ITR 360 (Guj.).
Here it was worth noting that neither it is
the case of learned AO that what assessee did was palpably incorrect (that is,
what the assessee adopted was plausible valuation rate, but learned AO
suggested higher/better rate) nor it is the case of learned AO that assessee's
valuation is totally unrecognized as per accounting/tax pronouncements.
It is well settled by the Hon'ble Supreme
Court of India in the case of Investment Ltd. v. CIT [1970]
77 ITR 533 (SC) (at p. 537) as well as in the case of United Commercial
Bank v. CIT [1999]
156 CTR (SC) 380 : [1999] 240 ITR 355 (SC) (at p. 367) that it is always
open to an assessee to adopt any method of keeping accounts for the purpose to
value his stock-in-trade either at cost price or market price. It has been held
that the method of accounting regularly employed can be discarded by the
Department only if, in the opinion of the taxing authorities, income of the
trade cannot be properly deduced thereform. Similarly, it has been held that if
the Department has accepted the practice so adopted for previous year, then
there must be justifiable reason for not accepting the same in particular year.
That is, as noticed in above Supreme Court orders it is specifically held that
it is open to an assessee to adopt any of the methods for computation of the
value of the stock and interference in such method, adopted by the assessee,
can only be made if it is found that the income of the trade cannot be properly
deduced therefrom.
The appellant has further relied on
decision in case of Bombay High Court in CIT v. Tata Iron & Steel Co. Ltd. 1975
CTR (Bom.) 80 : [1977] 106 ITR 363 (Bom.); Gujarat High Court in Voltamp
Transformers Ltd. v. CIT [2008]
217 CTR (Guj.) 254 : [2008] 7 DTR (Guj) 84 : [2008] 327 ITR 360 (Guj); The
Supreme Court in case of CIT v. Bilahari Investment (P) Ltd. [2008]
215 CTR (SC) 201 : [2008] 3 DTR (SC) 329 : [2008] 299 ITR 1 (SC) : Bombay
High Court in CIT v. Tata Iron & Steel Co. Ltd. (supra), and High Court of
Rajasthan in Malawi Hamjivan Jagannath v. Asstt. CIT [2007]
207 CTR (Raj.) 19.
The appellant further mentioned as under :
In the light of above for valuation of closing stock, rejection of audited
accounts under s. 145(3) by the learned AO is not correct being whole thing is
appearing on the face of the P&L a/c. Further, in addition to accounting
principles and details, the arrived results matched with the earlier year
results matching as per comparative GP chart enclosed. (Annexure 13)
The AO has grossly erred in applying the
provisions of s. 145(3) of the Act, without pointing out any specific defect in
the books of account, method of accounting followed by the assessee during the
preceding years based on hypothesis particularly when the gross profit for the
year was reasonable. The valuation of the closing stock cannot be changed by
the AO. As such the provisions of above section have been wrongly applied
without considering the merits of the case and the case laws mentioned above."
6. The learned CIT(A) after considering the
submissions of the assessee observed that the main contention of the assessee
was that the value of closing stock had been taken at cost or market price,
whichever was less, the books of account had been audited and this method had
been consistently followed since inception of the company and accepted by the
Department. The learned CIT(A) confirmed the addition made by the AO and upheld
the rejection of books of account under s. 145(3) of the Act by observing in para
4.3 of the impugned order as under :
"(i) In this context, it may be
mentioned that it has been held by the Supreme Court in CIT v. British Paints
India Ltd. [1991]
91 CTR (SC) 108 that it is not only the right but the duty of the AO to
consider whether or not the books disclose the true state of accounts and the
correct income can be deduced therefrom. It is incorrect to say that the
officer is bound to accept the system of accounting regularly employed by the
assessee, the correctness of which had not been questioned in the past. There
is no estoppel in these matters and the officer is not bound by the method
followed in the earlier years.
It is seen that assessee has submitted
trading account to the AO which is as under :
Trading account for the year ended 31st
March, 2008
Particulars
|
Amount
|
Particulars
|
Amount
|
|||||
Opening Stock
|
2,36,56,555
|
Sales
|
15,71,28,177
|
|||||
Total purchase cost
|
15,48,74,802
|
%
|
Closing
Stock |
3,80,85,778
|
||||
Less : Addl. discount which
is received from purchases |
24,15,579
|
|||||||
Less input credit
|
4,37,697
|
28,53,276
|
1.84
|
|||||
Net purchase value as per point No. 2
|
15,20,21,526
|
|||||||
Add : Expenses incurred during the year
|
Insurance-Goods
in transit |
19.010
|
||||||
Freight & inward
handling |
6,59,161
|
|||||||
Entry tax
|
1,23,490
|
|||||||
Channel Finance
Bank interest |
10,18,292
|
18.19,955
|
1.18
|
|||||
Gross total
|
||||||||
Net purchase cost
|
15,38,41,481
|
|||||||
Gross profit
|
1,77,15,919
|
|||||||
Total
|
19,52,13,955
|
Total
|
19,52,13,955
|
From the above trading account, it is
apparent that assessee has debited all these above expenses directly related to
purchases of the goods while these expenses have not been taken into
consideration while valuing the closing stock. The chart submitted for valuing
the closing stock by the assessee is as under:
Drillcon (Reg) (P.) Ltd., Udaipur Stock
statement :
Month : March 2008
|
Date :
|
31-03-2008
|
||
Item : Description
|
Model
|
Type
|
Value
|
|
Spare parts and accessories for all Atlas
Cocpco Products.
|
AC
|
Assorted
|
64,78,160
|
|
Spare parts and accessories for all
Ingersoll-Rand Products
|
IR
|
Assorted
|
13,12,637
|
|
Spare parts and accessories for all
Escorts Construction Eqpt. Products
|
ECE
|
Assorted
|
31,22,739
|
|
Spare parts and accessories for all Volvo
Products (trucks and buses)
|
VLV
|
Assorted
|
1,17,96,570
|
|
Spare parts and accessories for all Volvo
RMD Products
|
VLV
|
Assorted
|
60,65,170
|
|
Spare parts and accessories for all Volvo
VCE Products
|
VLV
|
Assorted
|
66,39,564
|
|
Spare parts and accessories for all
Doosan Products
|
DO
|
Assorted
|
26,70,938
|
|
Total value of parts and accessories
|
3,80,85,778
|
From this, it is apparent that assessee has
only taken the cost of goods in the closing stock and not incidental expenses
incurred by the assessee relating to purchase of goods which is not as per AS 2
and the AO has in detail pointed out that in such cases correct taxable profits
for the year cannot be determined by the method followed by the assessee.
Further, it is also relevant to note that
as per s. 145A of the IT Act, all the taxes, duties or fees are to be included
while determining the closing stock for the inventory valuation which has not
been done by the assessee regarding entry-tax. Further, the Accounting
Standards for the valuation of inventory required that all the incidental
expenses of purchases are to be included into the closing stock.
The case laws relied upon by the assessee
are not applicable in the facts and circumstances of the case under
consideration. In fact, in the case of I.G.E. India Ltd. v. Jt. CIT [2008]
26 SOT 367 (Mumbai), it has been held that the valuation of closing stock
has to be done by adding direct cost and overheads to the raw material cost and
the above finding is in favour of the Revenue. Moreover, the addition has been
made by the AO following the decision of Hon'ble Supreme Court in the case of CIT
v. British Paints India Ltd. [1991]
91 CTR (SC) 108: [1991] 188 ITR 44.
Accordingly, rejection of books of account
of the assessee under s. 145(3) of the IT Act and the addition made of Rs.
4,76,573 on account of closing stock is upheld. Both the above grounds of
appeal are dismissed."
Now the assessee is in appeal.
7. The learned counsel for the assessee
reiterated the submissions made before the authorities below and further
submitted that the AO did not point out any defect in the books of account
maintained by the assessee in the course of its regular business and also did
not doubt the method of accounting consistently followed by the assessee. It
was further stated that the learned CIT(A) also had not appreciated the facts
and the evidences of the case produced by the assessee and just confirmed the
addition by relying on a single case i.e. British Paints India Ltd. (supra)
which in fact was not applicable to assessee's case because the said judgment
referred the valuation of stock while in assessee's case the matter was related
to the trading concern. It was contended that the learned CIT(A) had also
overlooked the assessee's contention by not considering the relating expenses
in closing stock valuation and since such expenses had already been included in
the purchases, there was no question for its further addition, therefore, the
said addition has been made merely on the basis of conjectures and surmises. It
was submitted that the closing stock had been valued as per normal accounting
principles at cost or market price, whichever is less and the said fact was
also stated in the balance sheet appearing in the books of account. It was
emphasised that the same, practice had been consistently followed by the
assessee without any change since its inception, therefore, there was no
justification for making the addition particularly when gross profit declared
by the assessee at 11.274 per cent was almost in consonance with the earlier
year's at 11.28 per cent even when the turnover had increased to Rs. 1,571.28
lakhs in comparison to sales in earlier year at Rs. 1,131.94 lakhs. It was also
pointed out that the method of valuation of closing stock has been accepted by
the Revenue while completing the assessment under s. 143(3) of the Act for
asst. yr. 2004-05 and even the valuation of stock had also been accepted by the
VAT and sales-tax authorities in their respective assessments. Therefore, the
learned CIT(A) was not justified in confirming the arbitrary addition made by
the AO.
8. In his rival submissions, the learned
Departmental Representative for the Revenue strongly supported the orders of
authorities below and reiterated the observations made by the AO in the
assessment order dt. 29th Oct., 2010.
9. We have considered the submissions of
both the parties and carefully gone through the material available on record.
In the present case, it is noticed that the AO made the impugned addition by
invoking the provisions of s. 145(3) of the Act, however, no specific defects
have been pointed out in the books of account maintained by the assessee in
regular course of its business. The AO did not point out any inflated purchase
or suppressed sales. The claim of the assessee was that the expenses considered
by the AO for increasing the value of the closing stock had already been
debited in the books of account and those expenses were directly related with
the purchases because insurance on goods in the transits was incurred to cover
the transit risk and the expenses were already debited as part of the purchase,
therefore, not to be added while valuing the closing stock. Similar was the
position with regard to freight and handing expenses. The assessee incurred
freight and handling charges at the time of purchase of goods so it was
directly connected with the cost of goods purchased, it was not to be again
added while valuing the closing stock. As regards to the entry-tax, the
explanation of the assessee that it was paid to the State Government when the
goods specified in the list under VAT Act were brought to the local area for
consumption or use, so it was directly related to the purchases and not to be
added again while valuing the closing stock, appears to be plausible. Similarly
channel finance bank interest was charged by the bank and in this regard the
assessee has submitted that its principal companies collected their receivables
from channel finance banks and it is mandatory. The principal companies
provided 30 days credit facility against purchase of goods and at that stage it
was part of the trading expenses which were already recorded by the assessee in
its books of account. All the expenses which were added by the AO on proportionate
basis for the valuation of closing stock were already included in the purchase
and the method of valuation of the assessee was cost or market price, whichever
was less. This fact is also clear from col. 12(a) in Form 3CD which is part of
tax audit report under s. 44AB of the Act. In the said column the auditor
mentioned that the valuation by the assessee is "at cost including direct
expenses or market value, whichever is less". It is also mentioned in col.
12(b) that there was no deviation in the above method. It is also an admitted
fact that the Department has accepted the tax audit report and pointed out no
discrepancy in the said report. Therefore, the AO was not justified in making
the addition in the valuation of the closing stock particularly when the same
valuation of the stock had also been accepted by VAT authorities and CTO
respective assessment orders (copies of which are placed in assessee's paper
book). In the present case, it is also noticed that for asst. yr. 2004-05 the
assessment was framed under s. 143(3) of the Act after making proper scrutiny
and valuation of the closing stock was accepted during the year under
consideration, there is no deviation in valuing the closing stock from the
method of valuation accepted by the Department in asst. yr. 2004-05, so there
was no occasion to make addition in the year under consideration as expenses
pointed out by the AO were already included by the assessee in the cost of
purchase and the stock available with the assessee was out of purchase. Therefore,
the proportionate amount of the expenses which was already recorded in the
books of account as those were directly linked to the purchase, added by the AO
in the valuation of closing stock, was not correct. In the present case, the AO
while rejecting the books of account of the assessee by invoking the provisions
of s. 145(3) of the Act had not given any other reason except the observation
that the proportionate expenses incurred by the assessee on account of
insurance on goods in transit freight and handling, entry-tax (purchase) and
channel finance interest, were to be added. The AO did not point out any
specific defect in the books of account or the method of accounting
consistently followed by the assessee. It is also not the case of the AO that there
was a deviation in valuing the closing stock in comparison to the earlier year,
no inflated purchases or suppressed sales or expenses not incurred for the
business purposes were found. Even the gross profit declared by the assessee on
turnover which was higher in comparison to earlier year, has not been doubted
by the AO. We therefore, considering the facts of the present case, are of the
view that the provisions of s. 145(3) of the Act were not applicable to the
facts of this case and the learned CIT(A) was not justified in confirming the
impugned addition made by the AO delete the addition made by the AO and
sustained by the learned CIT(A).
10. For the asst. yr. 2009-10 in ITA No.
401/Jd/2012, the facts are Identical as in ITA No. 400/Jd/2012 for asst. yr.
2008-09. Therefore, our findings given in the former part of this order for
asst. yr. 2008-09 shall apply mutatis mutandis for asst. yr. 2009-10.
11. In the result both the appeals of the
assessee are allowed.
[2013] 40 taxmann.com 83 (Jodhpur - Trib.)
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