A.D. Jain, J.M.: AO informed Addl. CIT, Rewari Range, Rewari that against summons under s. 131 of IT Act requiring assessee to be personally present or to file photo copy of conveyance deed/sale deed, neither any adjournment was sought nor any compliance was made, on three different dates. Subsequently, penalties amounting to Rs. 30,000, for alleged three defaults, were imposed. learned CIT(A) confirmed penalties. assessee is in further appeal before us. contention of assessee in statement of fact has been that assessee is State Government Officer. His office is run in name of Sub- Registrar, Rewari, through its registration clerk. office has been created under Indian Registration Act and Punjab Land Registration Manual. All Court summons are issued in name of registration clerk. summons in question were served in office. registration clerk was directed to comply with them. He was not aware of procedure. He supplied relevant information with signature of Sub-Registrar to ITO, Rewari. registration clerk visited office of ITO on all three days. However, his attendance was not marked. information, as supplied, was accepted by AO without any objection. Thus, assessee was under bona fide impression that due compliance had been made. Undisputedly, as also observed by learned CIT(A), requirement for assessee was either to attend in person or to produce photo copies of requisite documents. dispute is as to whether having supplied attested copies instead of photo copies as required by AO, assessee has committed any default so as to attract penalty under s. 272A(1)(c). As per s. 131 of IT Act, AO shall, for purpose of this Act, have same powers as are vested in Court under CPC, when trying suit in respect of, inter alia, compelling production of documents. Court of Civil Procedure is general Court governing procedure to be adopted by Civil Court. Wherever copies of documents are to be produced in civil proceedings, certified copies of documents are ones required to be filed and not merely photo copies. This is because certified copies have clearly more evidentiary value than photo copies. Moreover, undeniably, there is no provision under Punjab Land Registration Manual, i.e., statute governing assessee, to supply photo copies of title deeds. assessee submitted certified copies before AO. penalty in question has been levied merely because instead of photo copies, as assessee was required by AO to do, certified copies were supplied. In effect, assessee did supply requisite copies available from record. As discussed above, certified copies definitely carry more evidentiary value than photo copies. Therefore, assessee cannot be said to have committed any default. Otherwise too, for same default, penalty has been levied thrice over. This is unsustainable. Be that as it may, in view of above discussion, we do not find any default to have been committed by assessee, so as to attract levy of penalty in question. These penalties are hereby cancelled. As result, assessee s appeal is allowed. *** SUB-REGISTRAR REWARI v. INCOME TAX OFFICER