TaxTMI 
TaxTMI 
2025 (4) TMI 2103
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....mposing penalty of Rs. 25,00,000/- under section 271D without appreciating the fact that the assessee had received the impugned amount net in his individual capacity but in the capacity of Director of the company M/s Millennium Build Home Private Limited and the penalty, if any was to be levied, it had to be done in the hands of the Company. 3. The Appellant craves leave to take additional grounds of appeal before or at the time of hearing of the appeal and/or modify any of the above grounds." 3. Succinctly, the fact as culled out from the record are that a search & seizure operation under section 132(1) of the Income-tax Act, 1961 was carried out on 07.09.2017 at the various premises of "Resonance Group, Kota". In that search several persons/premises were covered u/s 132 of the Act. The case of the assessee was covered under that search proceeding. Consequent to search action, the case of the assessee was centralized to Central Circle-Kota by the Pr. Commissioner of Income-tax, Kota vide his order dated 12.10.2017. In that search action various incriminating documents / loose papers were found and seized. Out of them, one 'Ikrarnama' was seized by a search part....
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....r of M/s Millennium Build Home Pvt. Limited. Apparently the transaction of sale of shops does not belong to Shri Ajay Bakliwal in his individual capacity. He has signed this agreement in the representative capacity as Director of M/s Millennium Build Home Pvt Ltd, Kota, This fact is apparent from the 1st para of the agreement. It is submitted that in the assessment order of Shri Ajay Bakliwal for the Assessment Year 2016-17 the leamed AO has reproduced page 2 and 3 of the agreement in the assessment order itself, but page no. 1 was omitted to have been reproduced. The Page no. 1 of the agreement is scanned below which establishes the fact beyond doubt that the agreement was signed by Shri Ajay Bakliwal as director of M/s Millennium Build Home Private Limited, Kota. The First para of the first page of the agreement reproduced above very clearly states that the agreement is being executed by Shri Ajay Bakliwal as a representative of M/s Millennium Build Home Pvt. Ltd., Kota being a director of the company. In the above circumstances the transaction of sale of shops and the receipt of Rs. 25,00,000/- as advance against the sales of these shops does not belon....
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.... enclosed. In this assessment order it has been mentioned by the learned AO that it was the Company M/s Millennium Build Home Pvt. Ltd. who was constructing multi storied building namely Millennium Apartment, Parvati Puram, Kota and many of the flats of Millennium Apartment, Parvati Puram, Kota have been Booked by Shri Ajay Bakliwal being the director of the company. The booking as well as advance amount of these Flats of Millennium Apartment, Parvati Puram, Kota have been considered in the assessment order of M/s Millennium Build Home Pvt. Ltd. The following para no 5 appearing on page 2 of the assessment order of M/s millennium Build home Pvt. Ltd for A.Y. 2016-2017 is relevant in the above regard and the same is quoted below. "Documents regarding receipt of cash against booking/sale of Flats in M/s Millennium Build Home Private Limited were found and seized. The assessee company was constructing a multi storied building i.e. Millennium Apartment, Parvati Puram, Kota. Many Flats have been booked by Shri Ajay Bakliwal in F.Y. 2014-15 and 2015-16. Few flats have also been booked in previous year" The above para shows that Millennium Apartment, Parvati Puram, Kota ....
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....um Build Home Pvt. Ltd., Kota. The amount of Rs. 25,00,000/- was received by Shri Ajay Bakliwal as a representative capacity as director of M/s Millennium Build Home Pvt. Ltd., Kota which were constructed and owned by the aforesaid company and not by Shri Ajay Bakliwal in his individual capacity. Ld. AO noted that while making this submission the assessee has conveniently ignored the cancellation deed dated 29.01.2016 of the said shops in which it is clearly mentioned that Shri Mayank Jain and Shri Harish Kohli has taken back the amount of Rs. 25,00,000/- from Shri Ajay Bakliwal. There is no mention of any transaction between M/s Millennium Build Home Pvt. Ltd., Kota and both the buyers. Hence, the contention of the assessee completely differs from the facts as stated in cancellation deed. The cancellation deed was made part of the penalty order by the ld. AO. The assessee has further submitted that the bookings as well as advanced amount of these Flats of Millennium Apartment, Parvati Puram, Kota have been considered in the assessment order of M/s Millennium Build Home Pvt. Ltd. But, in the assessment order of M/s Millennium Build Home Pvt. Ltd. a table of booking status and....
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....he assessee has accepted that he has taken cash of Rs. 25,00,000/- from Shri Mayank Jain and Shri Harish Kohli as advance against sale of shops at Millennium Apartment, Parvatipuram, Kunhadi Kota on 06.06.2015. The assessee returned the amount in cash on cancellation of the deal on 23.02.2016. Thus, it is established that the assessee has accepted aforesaid cash and violated the provisions of section 269SS of the Income Tax Act, 1961 and thereby levied the penalty of Rs. 25,00,000/-. 4. Aggrieved from that order levying penalty by the Addl. CIT, Central Range, Udaipur the assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here in below: Validity of penalty order passed u/s 271D of the Act and imposing a penalty of Rs. 25,00,000/- 4.3 I have considered the facts of the case and written submissions of the appellant as against the observations/findings of the Addl./Jt. CIT in the Penalty order for the year under consideration. The contentions/submissions of the appellant are being discussed and decided as under- Facts of the case are considered. The arguments put forth ....
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....hy the agreement was not registered? -How many similar unregistered and unaccounted transactions were undertaken by the Director which are not actually entered in the books of accounts of the Company ? - Is such transactions are in the knowledge of other shareholders and management of the Company? - Is the Director has committed a fraud by accepting money in the name of Company and not depositing money in the books of accounts of the Company? The probable answers to these querries will prove that the transaction were not belonging to the Company. This is established by the documents further relied upon by the JCIT. It is argued that the Ld. Jt. Commissioner of Income Tax, Central, Udaipur has relied on cancellation of the above agreement deed which was not the subject matter of Provision of Section 269SS. The JCIT stated in the penalty order that in the cancellation deed dated 29.01.2016 of the said shops, it is clearly mentioned that Shri Mayank Jain and Shri Harish Kohli has taken back amount of Rs. 25,00,000/- from Shri Ajay Bakliwal. There is no mention of any transaction between M/s Millennium Build Home Pvt. Ltd., Kota and....
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.... (iv)maximum amount outstanding in the account at any time during the previous year, "(v) whether the loan or deposit was taken or accepted by cheque or bank draft or use of electronic clearing system through a bank account;" (vi) in case the loan or deposit was taken or accepted by cheque or bank draft, whether the same was taken or accepted by an account payee cheque or an account payee bank draft (b) Particulars of each specified sum in an amount exceeding the limit specified in section 269SS taken or accepted during the previous year- (i) name, address and Permanent Account Number (if available with the assessee) of the person from whom specified sum is received: (ii) amount of specified sum taken or accepted: (iii) whether the specified sum was taken or accepted by cheque or bank draft or use of electronic clearing system through a bank account; (iv) in case the specified sum was taken or accepted by cheque or bank draft, whether the same was taken or accepted by an account payee cheque or an account payee bank draft. (Particulars at (a) and (b) need not be given in the case of a Government compan....
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....ntioned in the document is not relevant. What is relevant is the transaction of any loan or deposit or any specified sum. Hence, even if the properties mentioned in the seized documents are ignored, the violation of section 269SS is established. The sum so The relevant section 269SS is reproduced as under- "269SS. Mode of taking or accepting certain loans, deposits and specified sum.-No person shall take or accept from any other person (herein referred to as the depositor), any loan or deposit or any specified sum, otherwise than by an account payee cheque or account payee bank draft or use of electronic clearing system through a bank account, if,- From the plain reading of the provisions of section 269SS, it is evident that in case a person takes or accepts from any other person, the specified sum, otherwise than by an account payee cheque or account payee bank draft or use of electronic clearing system through a bank account, if the amount is of Rs. twenty thousand or more, provisions of section 269SS are contravened. Supreme Court Of India in the case of Al Ameen Educational Trust v. Commissioner of Income-tax [2021] 131 taxmann.com 127 (SC)/(2021) 283....
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...., there was reasonable cause for having availed loan transactions Assessing Officer having rejected assessee's explanation, passed penalty order under section 271D High Court by impugned order held that merely because director deposited cash obtained by it from JD in current account of assessee-company on very same day and assessee utilized it to pay salaries, rent and EMI commitments, same could not be a ground to be taken as a mitigating factor to escape from rigour of levy of penalty under section 2710 Whether special leave petition filed against impugned order was to be dismissed - Held, yes [Para 3] [in favour of revenue] High Court Of Rajasthan in the case of Commissioner of Income-tax v. Chandra Cement Ltd [2016] 74 taxmann.com 75 (Rajasthan)/[2017] 393 ITR 324 (Rajasthan)/[2017] 291 GTR 581 (Rajasthan) [31-08-2016) held that Where assessee-company, engaged in setting up of cement plant, raised unsecured loan from Managing Director in cash in excess of Rs. 20,000, mere fact that said amount was utilized for payment of constructional activities directly would not alter character of deposits In the present case also, the assessee failed to discharge its b....
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....ee categories the period of limitation for cases falling under category (i), ie, clause (1)(a) is the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed or six months from the end of the month in which the order of the Dy. CIT(A) or the CIT(A) or, as the case may be, the Tribunal is received by the Chief CIT or CIT, whichever period expires later. 22. The period of limitation for the cases falling under category II is six months from the end of the month in which such order on revision is passed and the period of limitation for the cases falling under the above category III is the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from the end of the month in which action for imposition of penalty is initiated, whichever period expires later. In the last category, filing of appeal in respect of order passed in proceedings during which penalty proceedings were initiated is not relevant. To this effect, a Circular No. 551, dated 23-1-1990 [(1990) 82 CTR (St.) 325] and another Circular N....
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....lty proceedings can be initiated independent of any proceedings but obviously, the penalty proceedings can be initiated only when the default is brought to the notice of the concerned authority which may be during the course of any proceedings and, therefore, for this type of cases where the penalty proceedings have been initiated in corinection with the defaults for which no statutory mandate is there about any particular proceedings during the course of which only such penalty proceedings can be initiated, a different period of limitation has been prescribed under clause (c) as a separate category. In cases falling under clause (c), penalty proceedings are to be completed within six months from the end of the month in which the proceedings during which the action for imposition of penalty is initiated, are completed, or six months from the end of the month in which action for imposition of penalty is initiated, whichever period expires later. There is no provision under clause (c) for the extended period of limitation commensurating with completion of the appellate proceedings, if any, arising from the proceedings during the course of which such penalty proceedings are initiated ....
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....oceedings can be initiated independent of any proceedings but obviously, the penalty proceedings can be initiated only when the default is brought to the notice of the concerned authority which may be during the course of any proceedings and, therefore, for this type of cases where the penalty proceedings have been initiated in connection with the defaults for which no statutory mandate is there about any particular proceedings during the course of which only such penalty proceedings can be initiated, a different period of limitation has been prescribed under clause (c) as a separate category. In cases falling under clause (c), penalty proceedings are to be completed within six months from the end of the month in which the proceedings during which the action for imposition of penalty is initiated, are completed, or six months from the end of the month in which action for imposition of penalty is initiated, whichever period expires later. In the present case, the Penalty u/s 271D was initiated on 24.12.2021. The penalty order was passed on 22.06.2022. Hence, the order is passed six months from the end of the month in which action for imposition of penalty is initiated. Henc....
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....he Act runs up to 28.02.2019 since the AO passed order imposing penalty u/s 271D & 271E of the Act, on 20.06.2019. In our considered view, the order passed by the AO is well within time limit prescribed sec. 275(1)(c) of the Act, and thus, we reject the arguments taken by the Ld. Counsel for the assessee on limitation. The assessee has relied upon the decision of the Hon'ble Delhi High Court in the case of Rishikesh Buildcon (P.) Ltd. (supra), and argued that the Hon'ble Delhi High Court held that the limitation prescribed u/s. 275(1)(c) of the Act, commenced from the date the AO sent a proposal to the Joint/Addl. CIT for penalty proceedings, but not from the date the Officer imposing penalty notice issued u/s 274 r.w.s.271D & 271E of the Act. We find that the Hon'ble Delhi High Court had considered the issue in light of the facts where there is a huge gap of nearly five years from the date, the AO sent a proposal to the Officer imposing penalty and the notice issued by the Officer imposing penalty and under those facts, the Hon'ble Delhi High Court came to the conclusion that the limitation prescribed u/s. 275(1)(c) of the Act, runs from the date the AD sent propos....
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....later period also expired on 30-9-2003 when six months expired from the end of the month in which the action for imposing the penalty was initiated. The order as passed by the Joint Commissioner for the penalty under section 271D on 28-5-2004 was clearly hit by the bar of limitation and has rightly been set aside in the orders impugned. [Para 9] Even when the authority competent to impose penalty under section 2710, was the Joint Commissioner, the period of limitation for the purpose of such penalty proceedings was not to be reckoned from the issue of first show cause by the Joint Commissioner, but the period of limitation was to be reckoned from the date of issue of first show cause for initiation of such penalty proceedings." In the case relied upon by the appellant, it was held that the period of limitation for the purpose of such penalty proceedings was not to be reckoned from the issue of first show cause by the Joint Commissioner but the period of limitation was to be reckoned from the date of issue of first show cause for initiation of such penalty proceedings. The assessee in the present case has not established that the fist show cause notice for initiati....
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....that the assessee has accepted cash of Rs. 25,00,000/- in the form of advance against sale of these shops, and had thus, violated the provisions of section 269SS. It would be pertinent to mention that the advance had been accepted by the assessee in his capacity as Director of Millenium Builhome Pvt. Ltd., and not in his individual capacity. The AO passed on this information to the Addl.CIT, who levied penalty u/s 271D. The penalty order passed by the Addl.CIT was time barred. The appeal of the assessee was dismissed by the CIT(A) on the legal as well as factual issue. Submission on the grounds of appeal Ground No.1 The Ld.CIT(A) has erred in confirming the penalty order dated 22.06.2022 passed by the JCIT- Central, Udaipur which was clearly barred by limitation u/s 275(1)(c) of the Act At the outset, it is submitted that based on the undisputed facts available on record, imposition of penalty vide the impugned order u/s 271D passed by the ld. JCIT, Jaipur on 22.06.2022, is clearly barred by the limitation in as much as, the law u/s 275(1)(c) reads as under: 275. (1) No order imposing a penalty under this Chapter shall be passed x-------....
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.... be reckoned from the date of issue of first show cause for initiation of such penalty proceedings". CIT Vs. Hissaria Brothers [2016] 386 ITR 719 (SC) "Penalty under ss. 271D and 271E-Limitation under s. 275- Computation- Penalty orders under ss. 271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation- CIT vs. Hissaria Bros. (2007) 211 CTR (Raj) 156 affirmed." Application over the Facts of Present case: No penalty u/s 271D could be imposed after the expiry of limitation prescribed being the later of (a) expiry of the related financial year or (b) within a period of 6 months from the end of the month in which action for imposition of penalty was taken by the Assessing Officer. The ld. JCIT in the impugned penalty order has observed that the assessment for AY 2016-17 was completed by the ACIT, Central Circle, Kota u/s 143(3) r.w.s. 153A of the Act on 28.12.2019 stating as under: As per page No. 91 & 92 of Exhibit-22 Sh. Ajay Kumar Baikliwal has made agreement with Sh. Mayank Jain and Sh. Harish Kohli for sale of six shops situated at ground floor of multist....
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....y other proceedings during which penalty proceedings for S.271D and 271E are initiated have got no relation with the computational or assessment aspect therefore such appellate proceedings are not relevant for sustaining such type of penalties. Even otherwise, no appeal was filed by the assessee against the assessment order. It has been held that in such cases, S.275 (1)(a) has got no application. Kindly refer CIT Vs. Hissaria Brothers [2016] 386 ITR 719 (SC) (para 27). "27. By these amendments, the three categories were made for applying limitation for completing the penalty proceedings taking into consideration the various penalty proceedings for default of certain provisions of the Income-tax Act which are not necessarily linked with proceedings for any particular assessment year in the course of which only penalty proceedings were required to be initiated. Such consequences of default were not linked with the principal assessment proceedings for any specific assessment year but were independent of it." In this regard, CBDT issued circular No.10/2016 dated 26.04.2016 (copy enclosed) making it clear that the period of limitation of penalty proceedings u/s 271D &....
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....ived the impugned amount not in his individual capacity but in the capacity of Director of the company M/s Millennium Build Home Private Limited and the penalty, if any was to be levied, it had to be done in the hands of the Company. The facts of the case are that the assessment was completed on 28.12.2019 u/s 143(3) r.w.s.153A on the returned income. In para 5 of the assessment order, the Ld. A.O. has discussed regarding Violation of section 269SS, referring to page-91 & 92 of Ann-22 found and seized during the search, stating that the assessee had made agreement with Sh. Mayank Jain and Harish Kohli, for sale of his six shops situated at ground floor of his multistory building Millenium Apartment and received Rs. 25,00,000/- in cash on 06.06.2015 which is contrary to the provisions of section 269SS. At this juncture, it would be pertinent to mention that the scrutiny assessments of Millennium Build Home Private Limited u/s 143(3) r.w.s. 153C for AY 2012-13 to AY 2018-19 have been completed by the same AO and the issue involved in all these years was cash advances received on booking of flats/shops in Millenium Apartments. The AO was well aware that Millenium Bui....
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....O went into hibernation. After 14 months, he woke up from his slumber and referred the matter to the Jt.CIT imposition of penalty. It would be pertinent to mention that the impugned property, i.e. Shops in Millenium Apartment, never appeared in the balance sheet of the assessee for any Financial year. So, when assessee is not the owner of these properties, how come the advance received against sale of these shops be considered in the hands of the assessee. Moreover, the cash advance received against the shops was never credited to the books of the assessee. The Jt.CIT ought to have proved this fact before inposing the penalty. The sale deed, relying on which, penalty has been imposed by the Jt.CIT, in no unambiguous terms, mentions that the advance against the impugned property is being taken by Ajay Bakliwal in his capacity as director of Millenium Buildhome Pvt. Ltd. Inspite of this fact, without verification of record of the assessee, the Competent Authority drew adverse inference and imposed penalty u/s 269SS of Rs. 25,00,000/- which is not in accordance with law & facts of the case. Without prejudice to the above, there did exist a reasonable cause in terms o....
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....o 86]. As regards the cancellation deed he has submitted the first page wherein it is categorically evident that the transaction is for and on behalf of the company Millenium where he is director and therefore, the contention raised by the ld. AO is against the evidence on record and thereby he contested even on merits and thereby prayed to delete the levy of penalty. 7. The ld DR is heard who relied on the findings of the lower authorities and more particularly advanced the similar contentions as stated in the order of the ld. CIT(A). As regards the legal ground ld. DR submitted that the period cited as being barred by limitation was covered by the Covid-19 and therefore, the said ground has no force. As regards the acceptance of the money by company the same is not mentioned in the audit report that the same is accepted in violation of provision of section 296SS of the Act. Based on those arguments he supported the order of the ld. CIT(A) and also filed following written submissions on 30.01.2025 and 02.03.2021 as under:- "Written submission dated 30.01.2025 Subject: Non-Receipt of Documents as Directed by the Hon'ble ITAT in the Case of Ajay Bakliwal AY-....
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....produced hereunder:- During the assessment proceeding, the assessee was asked to submit details regarding the above transaction. The assessee has replied that the deal was cancelled and the amount was returned. The assessee has accepted that he has taken cash of Rs. 25,00,000/- from Shri Mayank Jain and Shri Harish Kohli as advance against sale of seven shops at Milenium Apartment Parvatipuram, Kunhadi Kota on 06.06.2.015. The assessee returned the amount in cash on cancellation of deal on 23.02.2016. These facts have been accepted by the assessee. Since it is established and accepted by the assessee that transaction in cash above Rs. 20,000/- occurred for sale of immovable property, therefore, provision of section 269SS is applicable in the case of the assessee. In the light of above facts and circumstance of the case, it appears that Shri Ajay Bakliwal has taken cash of Rs. 25,00,000/- during AY 2016-17. Section 269SS provides that any No person shall take or accept from any other person (herein referred to as the depositor), any loan or deposit or any specified sum, otherwise than by an account payee cheque of account payee bank draft or use e....
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.... that is dealt by the provision of section 275 of the Act which reads as under: Bar of limitation for imposing penalties. 275. (1) No order imposing a penalty under this Chapter shall be passed- (a) in a case where the relevant assessment or other order is the subject-matter of an appeal to the 28-29[Joint Commissioner (Appeals) or to the] Commissioner (Appeals) under section 246 or section 246A or an appeal to the Appellate Tribunal under section 253, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the 28-29 [Joint Commissioner (Appeals) or the] Commissioner (Appeals) or, as the case may be, the Appellate Tribunal is received by the 30[***]Principal Commissioner or Commissioner, whichever period expires later : Provided that in a case where the relevant assessment or other order is the subject-matter of an appeal to the 31[Joint Commissioner (Appeals) or to the] Commissioner (Appeals) under section 246 or section 246A, and 31[the Joint Commissioner (Appeals) or] the Commissi....
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....d otherwise been in appeal before the CIT(A) against the original assessment order and the appeal was decided on 13.02.2004, the same was hardly of relevance so far the penalty proceedings under Section 271D were concerned. As held by this Court in Hissaria Bros. (supra), completion of appellate proceedings arising out of assessment proceedings has no relevance over sustaining such penalty proceedings. As held clearly by this Court, in such a matter, clause (c) of Section 275(1) would be applicable. Section 275(1)(c) could be noticed as under:- "275. Bar of limitation for imposing penalties. (1) No order imposing a penalty under this Chapter shall be passed- ..... (c) in any other case, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from the end of the month in which action for imposition of penalty is initiated, whichever period expires later." 9. In the present case, the first show cause notice for initiation of proceedings was issued by the AO on 25.03.2003 and was served on the assessee on 27.03.2003. Obvious....
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....ntrary to the provisions of section 269SS. Accordingly, a reference was made by the ACIT Central Circle Kota to Addl./JCIT CIT, Central Range, Udaipur for considering initiating penalty proceedings u/s 271D of the Income Tax Act against the assessee and thereby the penalty of Rs. 25 lac was levied against the assessee. As is evident from the record that the Agreement of sale of shops at Millennium Apartment, Parvati Puram, Kota is between M/s Millennium Build Home Pvt. Limited Kota and Shri Mayank Jain & Shri Harish Kohli. It is submitted that agreement was between M/s Millennium Build Home Pvt. Ltd., and Shri Mayank Jain and Shri Harish Kohli for a total sum of Rs. 45,00,000/- and against the sale consideration a sum of Rs. 25,00,000/- was received in cash as advance on 06.06.2015. Shri Ajay Bakliwal signed that agreement as Director of M/s Millennium Build Home Pvt. Limited. Apparently, the transaction of sale of shops does not belong to Shri Ajay Bakliwal in his individual capacity. He has signed this agreement in the representative capacity as Director of M/s Millennium Build Home Pvt Ltd, Kota, This fact is apparent from the 1st para of the agreement. In the above circumstance....
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....Home Private Limited and Shri Ajay Bakliwal was a director in this company. In the aforesaid circumstances the issue of sale of shops and advance taken by Shri Ajay Bakliwal in his representative capacity as director belongs to M/s Millennium Build Home Private Limited and not to Shri Ajay Bakliwal in his individual capacity Thus, the show cause notice issued by ld. AO under section 274 read with section 271D is also based on the wrong appreciation of the fact and thus required to be quashed. In the light of that facts ground no. 2 raised by the assessee is allowed. In the result, the appeal of the assessee is allowed. Order pronounced in the open court on 11/04/2025. ============= Document 1 यह कि समà¥à¤ªà¥‚रà¥à¤£ à¤à¥à¤—तान होने पर मोके पर दà¥à¤•à¤¾à¤¨à¥‹à¤‚ का कबà¥à¤œà¤¾ मौके पर केता को समà¥à¤à¤²à¤¾ दिया जायेगा तथà¤....
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....¤à¤µà¤‚ पाबंद रहेंगे । लिहाजा यह इकरारनामा दोनों पकà¥à¤·à¤•à¤¾à¤°à¤¾à¤¨ ने अपनी राजी खà¥à¤¶à¥€ पूरà¥à¤£ होशो हवास में बिना किसी नशे पतà¥à¤¤à¥‡ के 100/- रूपये के सà¥à¤Ÿà¤¾à¤®à¥à¤ª पर तहरीर कर दिया है जो कि सनद रहे और वकà¥à¤¤ जरूरत काम आये । नहरीरी तारीख : CAnd हसà¥à¤¤à¤¾à¤•à¥à¤·à¤° विकेता गवा....
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....¥‹à¤¨à¥‡ के कारण उकà¥à¤¤ दà¥à¤•à¤¾à¤¨à¥‹à¤‚ का विकय इकरार मंयक जैन उमà¥à¤° 26 वरà¥à¤· पà¥à¤¤à¥à¤° शà¥à¤°à¥€ अजीत कà¥à¤®à¤¾à¤° जैन निवासी 229, महावीर नगर कोटा (राज.) à¤à¤µà¤‚ हरीश कोहली पà¥à¤¤à¥à¤° शà¥à¤°à¥€ हरà¤à¤—वानदास कोहली उमà¥à¤° 51 वरà¥à¤· निवासी मकान नं. à¤-381, तलवंडी कोटा (राज.) से रूपये 45,00,000/- अकà¥à¤·à¤°à¥‡ पैतालीस ....