ANURAG KUMAR MAHESHWARI,KASGANJ V. ITO WARD 4(3)(3), KASGANJ

ITA 139/AGR/2023

AI Insights

The case revolves around the income tax assessments made on Anurag Kumar Maheshwari for the assessment year 2017-18, which included unexplained cash deposits during the demonetization period and presumptive income from these deposits. The Assessing Officer made additions to the assessee's income based on these deposits, treating them as unexplained money and presumptive income under sections 69A and 44AD of the Income Tax Act, respectively. The CIT(A) upheld these additions. However, the Tribunal found that the actual owner of the bank account and the deposits was Neeraj Kumar, the assessee's brother, who had declared these transactions in his own tax returns. The Tribunal's decision emphasized the need for the department to have pursued the matter against Neeraj Kumar rather than Anurag Kumar Maheshwari.

• Counselvise Citation: [2024] 140 COUNSELVISE.COM (IT) 23168 (ITAT-AGRA)
• Duration Of Justice: 1 year(s) 1 month(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 29-11-2024
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Next Hearing Date: 27-11-2024
• Assessment Year: 2017-2018
• Appeal Filed On: 21-10-2023
• Other Referred Cases: Collector Land Acquisition, Anantnag & Ors. vs Mst. Katiji & Ors. (1987) 167 ITR 471 (SC)
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SHAILENDRA SRIVASTAVA
• Assessee Lawyers: PANKAJ GARGH; APPLYING PROFIT RATE OF OF SAID DEPOSITS; APPLYING PROFIT RATE OF
• Keywords: Condonation of delay; Business income
• Section: 144; 143(3); 142(1); 143(2); 250; 131; 22; 133(6); 44AD; 13; 69A

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL AGRA (SMC) BENCH, AGRA BEFORE: SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER ITA No. 139/Agr/2023 Assessment Year: 2017-18 Anurag Kumar Maheshwari, Shawar Gate, Kasganj (U.P.) PAN: BYCPM2478P v. Income-tax Officer, Ward 4(3)(3), Kasganj. (Appellant) (Respondent) Assesseeby : Sh. Pankaj Gargh, Advocate Revenue by : Sh. Shailendra Srivastava, Sr.DR Date of hearing : 27.11.2024 Date of Pronouncement : 29.11.2024 ORDER This appeal in ITA No. 139/Agr/2023 for the assessment year 2017-18 has arisen from the appellate order dated 28.02.2023 (DIN& Order No. ITBA/NFAC/S/250/2022-23/1050185323(1)) passed by ld. Commissioner of Income-tax(Appeals),NFAC, Delhi, whichin turn, has arisen from the assessment order dated 05.12.2019 passed by Assessing Officer u/s. 143(3) of the Income-tax Act, 1961. 2.Grounds of Appeal raised by the assessee in the memo of appeal filed with Income Tax Appellate Tribunal, Agra, reads as under : ITA No. 139/Agr/2023 2 “1 Because the Ld. CIT(A), NFAC has grossly erred both on facts and in law in brushing aside the submission along with documents filed during appellate proceedings and in confirming all the additions made by the Assessing Officer in the assessment Order dated 05.12.2019. 2 Because the addition of Rs 7,11,500/- made u/s 69A and further addition of Rs 4,97,810/- being net Profit on presumptive basis has been wrongly and arbitrarily confirmed by the Id. CIT (A), NFAC. Considering the facts of the case the additions made by the Assessing Officer should have been deleted by the Ld. CIT (A). 3 Because considering the facts of the case it cannot be said that the current bank account no. 384601010011133 is jointly owned by the appellant. 4 Because the Ld. CIT (A) has erred in solely relying on the pay-in slips of the deposits in bank account ignoring the undisputed fact that on the same pay-in slip the name mentioned in which the deposited amount is to be credited is Anurag Kumar Neeraj Kumar which is owned by Neeraj Kumar as prop. of M/s Anurag Kumar Neeraj Kumar and the transactions of this bank account has been duly considered and disclosed by Neeraj Kumar in his ITR filed for AY 2017-18 as he has filed the return on presumptive basis u/s 44AD. 5 Because under the facts and circumstances of the case the Ld. CIT (A), NFAC should have deleted all the additions made by the Assessing Officer instead of confirming the same. 6. Because the appellant craves the right to add, alter, amend, modify or/and delete any or all the grounds of appeal at the time of hearing or earlier.” 3. At the outset, it is observed that this appeal is filed belatedly by 174 days before the Income-tax Appellate Tribunal, Agra beyond the time prescribed u/s. 253(3) of the Act. The assessee has filed application dated 20.10.2023supported by letter dated 17.10.2023 of ITA No. 139/Agr/2023 3 M/s Arun Sachin and Associates (Advocates) along with affidavit of the assesseedated 17.10.2023, praying for condonation of delay, wherein it is stated that the assessee has nominal source of income and was filing return through its counsel Mr. Sachin Maheshwari, Advocate of Kasganj. The assessee being not conversant with the Income-tax procedures, the email-ID of the staff member of the counsel was registered on the Income Tax Portal. The order of ld. CIT(Appeals) was not communicated to the assessee either by the counsel or from the office of counsel, and it is only when the noticedated 18.09.2023 to deposit outstanding arrears of demand was received by post from the Income tax department , jurisdictional Assessing Officer , then the assessee came to know about the order passed by ld. CIT(A) u/s. 250 of the Act. The assessee also filed one letter from the counsel Shri Sachin Maheshwari, Advocate of Kasganj, wherein it is sated that the email ID mentioned in the Income-tax Portal was of his staff, and his office staff did not see the email received from ld. CIT(A) in time and the assesseewas not communicated about the same. Assessee also supported the above ITA No. 139/Agr/2023 4 contention by way of affidavit dated 17.10.2023. Ld. DR has no serious objection to the condonation of delay. 3.2 After hearing both the parties and considering material on record, I am of the considered view that the delay in filing this appeal belatedly beyond the time period prescribed u/s. 253(3) of the Act, needs to be condoned, as the assessee could not be penalised due to non-communication of the CIT(Appeals) order by the staff of the counsel of assessee. Further, there is switch over phase been underway from the physical mode to electronic mode of framing faceless assessment by AO , e-adjudicationby faceless mode of appeal by the ld. CIT(Appeals) etc. wherein notices, summons , replies , assessments orders, appellate orders etc. are alsocommunicated/uploaded via electronically been done, and in this switch over period, there are likely to be some hiccups both at the end of assessee as well as department and hence, liberal view has to be taken so far as condonation of delay in filing appeal is concerned. If substantial justice and technical considerations are pitted against each other, Courts will lean towards advancement of Substantial Justice , unless malafide is at writ large. I do not find any ITA No. 139/Agr/2023 5 mala fide on the part of the assessee in filing this appeal belatedly before the Tribunal beyond the time prescribed. The assessee is not likely to gain by filing this appeal belatedly with ITAT. I, therefore, condone the delay in filing of this appeal belatedly by the assessee beyond the time prescribed u/s. 253(3) of the Act. Reliance is placed on the decision of Hon’ble Supreme Court in the case of Collector Land Acquisition, Anantnag &Ors. vs Mst. Katiji&Ors. (1987) 167 ITR 471 (SC). Thus, I condone the delay in filing this appeal and proceed to decide the appeal on merits.I order accordingly. 4. Brief facts of the case are that the assessee filed return of income on 16.03.2018 declaring income of Rs.2,84,600/-. Case of the assesseewas selected for framing limited scrutiny through CASS. Statutory notices u/s 143(2) and 142(1) were issued by the Assessing Officer from time to time to the assessee, but there was no compliance on the part of the assessee. Assessing Officer issued notice u/s. 133(6) to the Bank wherein demonetized currency were deposited, calling for details of deposits of demonetized currency and bank statement. In compliance, the bank submitted the details to the Assessing Officer. The Assessing Officer ,in the absence of ITA No. 139/Agr/2023 6 compliance by the assessee, issued SCN u/s 144 to the assessee, dated 14.11.2019, but again there was no compliance by the assessee. The AO proceeded to frame best judgment assessment u/s. 144 of the Act. Assessing Officer observed from the bank account statement and the details furnished by the Branch Manager of Union Bank, Railway Road, Kasganj that cash of Rs.2,50,000/-, Rs. 2,50,000/- and 1,27,500 were deposited on 10.11.2016, 13.11.2016 and 29.11.2016 in demonetized currency of Rs.500/- and Rs.1000/- in the bank account No. 384601010011133. The Assessing Officer further observed that there has been cash deposit of Rs.45,000/- and Rs.39,000/- on 12.11.2016 and 11.11.2016 in the other bank account No. 384602010945067 maintained by the assesseewith Union Bank, Railway Road, Kasganj. In the absence of any reply from the assessee, the Assessing Officer made addition of Rs.7,11,500/- being cash deposit in the bank accounts(both the above bank accounts) during the demonetization period treating the same as unexplained money of the assessee u/s. 69A of the Act. ITA No. 139/Agr/2023 7 4.2 Further, on perusal of the bank statement of the aforesaid bank accounts, Assessing Officer observed that an amount of Rs.62,22,636/- was depositedthrough cash or credit entries in the aforesaid bank accounts during the year under consideration apart fromdeposits in demonetized currency. The assessee did not offer any explanation during the assessment proceedings and in the absence of any explanation from the assessee. The AO computed income of the assessee by applying profit rate of 8% of said deposits in bank account to the tune of Rs.62,22,636/- as gross turnover of the assessee, and income of Rs.4,97,810/- was computed in the hands of the assessee. 5. Being aggrieved, the assessee filed first appeal with ld. CIT(A). Assessee participated in the appellate proceedings before the ld. CIT(Appeals), and submitted that the assessee has nothing to do with the bank account in the name of M/s Anurag Kumar Neeraj Kumar bearing account No.384601010011133 and the cash deposited in that account does not belong to the assessee. The ld. CIT(Appeals) treated the said account as the joint account of Shri Neeraj Kumar and Anurag Kumar Maheshwari(assessee). Ld. CIT(Appeals) ITA No. 139/Agr/2023 8 rejected the contention of the assessee that the assessee has nothing to do with this bank account and relied upon copy of pay-in- slips of the bank through which the cash was deposited in the bank account in the name of Anurag Kumar Neeraj Kumar. Said Pay-in- slips carried the PAN of Shri Anurag Kumar(Assessee) and bearing his signature. The ld. CIT(A) dismissed the appeal of the assessee, on both the grounds, viz., deposit of cash of Rs.7,11,500/- during the demonetization period and also treating the other cash/credit entries in the said bank accounts of Rs.62,22,636/- as turnover of the assessee and computing income u/s. 44AD @ 8% of gross turnover. 6.Still Aggrieved, the assessee has filed second appeal before the Tribunal. Shri Pankaj Gargh, Advocate appeared on behalf of the assessee and drew our attention to the written synopsis filed by him along with paper book containing 71 pages. The said paper book carries certification that documents vide S. No. 1 to 9 were filed before ld. CIT(A), while particulars were also given for documents at S.no 10 to 12. Both the paper book and synopsis filed by the assessee are placed on record in file. It is the say of the ld. Counsel that the assesseehas filed its return of income on 16th March, 2018, ITA No. 139/Agr/2023 9 declaring income of Rs.2,84,600/- for the impugned assessment year.Income-tax Return of the assesseeis also placed at page 8 to 12 of the paper book, in which the assessee has shown that there is cash deposit of Rs.84,000/- during the demonetization period in the bank account No. 384602010945067 maintained with UBI. There was also cash deposit of Rs. 49,000/- during demonetisation period in bank account number 32336353163 with SBI. It was submitted that the case was selected by Revenue for framing limited scrutiny through CASS .Ld. Counsel submitted that the assessee is having Saving Bank Account No. 384602010945067 with Union Bank of India,and the assessee has duly deposited Rs.84,000/- in cash in the said bank account. Copy of the said bank account statement for the entire year is placed on record in page 32 to 36 of the paper book, and my attention was drawn to cash deposits on 11.11.2016 of Rs. 39,000/- and on 12.11.2016 of Rs. 45,000/- . It was submitted that assessee’s brother Shri Neeraj Kumar is carrying on business in the proprietorship concern namely M/s. Anuraj Kumar Neeraj Kumar ,and is regularly assessed to tax. It was submitted that the brother of the assesseenamely Mr. Neeraj Kumar has filed his return of income on ITA No. 139/Agr/2023 10 19.03.2018 for the impugned assessment year under PAN COJPK5927B. Copy of acknowledgement of said income-tax return is placed in page 13 of the paper book ,along with computation of income at page No. 14-15 and copy of return of income is placed at page No. 16 to 21 of the paper book(acknowledgement number 462582500190318) . It was submitted that the brother of the assesseeShri Neeraj Kumar has declared gross turnover of Rs.50,88,200/- in the return of income filed with Revenue, and availed the presumptive scheme of taxation u/s. 44AD and applied the profit rate of 8% to compute the income chargeable to tax, and paid taxes accordingly. It was submitted that the assesseeis assisting his brother in his business and from time to time deposits the cash generated out of sale proceeds of his brother’s business, namely M/s. Anurag Kumar Neeraj Kumar in the current account No. 384601010011133 with Union Bank of India, Railway Road, Kasganj and the bank account is in the name of M/s. Anurag Kumar Neeraj Kumar. My attention was also drawn to the GST registration which is placed in paper book page No. 22 to 24 having GST Identification No. 09COJPK5927B1ZV, in which the trade name is reflected as Anurag ITA No. 139/Agr/2023 11 Kumar Neeraj Kumar and the name of the proprietor is Neeraj Kumar, although the said registration is effective from 01.07.2017( presently we are seized of assessment year 2017-18) . It was submitted by ld. Counsel that the main reason for making addition is that the bank account is in the name of Anurag Kumar Neeraj Kumar and in the pay-in-slips for cash deposited by the assessee in the said bank account, there was PAN of the assessee and signature of the assessee. It was submitted that the assessee is not denying that the assessee did not deposit the said cash in the bank account, and it was submitted that Shri Neeraj Kumar is the real brother of the assessee , and the assessee did deposited the said cash in the bank account which were from the sale proceeds collected from business carried on by the brother of the assessee. Certificate dated 06.10.2022 from the bank namelyUnion Bank of India , Railway Road, Kasganj Branch, Kasganjin original is produced by the ld. Counsel for the assessee, which is placed in the paper book at page No. 31 , which clearly states that Shri Neeraj Kumar is the running the current account No. 384601010011133 since 27th September, 2022, and the said current account is in the name of M/s Anurag ITA No. 139/Agr/2023 12 Kumar Neeraj Kumar having prop. Mr. Neeraj Kumar. The said bank account is active and running in Union Bank of India, Kasganj.The copy of bank certificate dated 06.10.2022 issued by Union Bank of India, Kasganj Branch, Railway Road ,Kasganj, is reproduced hereunder: ITA No. 139/Agr/2023 13 ITA No. 139/Agr/2023 14 Thus, it was submitted that it was a case of mistaken identity and the additions have wrongly been made in the hands of the assessee and the department ought to have proceeded against said Shri Neeraj Kumar, rather than against the assessee. So far as the deposit of Rs.84,000/- is concerned, it was submitted that it was small deposit during the demonetization period in the bank account No. 384602010945067 with Union Bank of India, Railway Road ,Kasganj. It was pointed out that as per SOP dated 21.02.2017, issued by CBDT, no addition could be made as cash deposited in the bank account is below Rs.2,50,000/- and the assessee was not having any business income. It was submitted that this cash deposit of Rs. 84,000/- is duly owned by and accounted for by the assessee in his return of income filed with the Revenue, declaring income of Rs. 2,84,600/-.The said cash deposit was duly reflected in the ITR filed. Thus, it was prayed that the additions as were made by the AO and sustained by ld. CIT(A) ought to be deleted. 6.2 Learned Sr. DR, on the other hand, submitted that during the assessment proceedings, the assessee did not comply with the ITA No. 139/Agr/2023 15 directions of the Assessing Officer and no response/reply was filed. Ld. Sr. DR also submitted that the matter can be restored back for verification by the authorities below. 7. I have considered the rival submissions and perused the material on record. I have observed that the assessee duly filed its return of income on 16.03.2018 declaring income of Rs.2,84,600/-. Case was selected by Revenue for framing limited scrutiny under CASS. Statutory notices including SCN were issued by the AO during assessment proceedings u/s 143(2), 142(1) and 144, but there was no compliance on the part of the assessee . I have also observed that the Assessing Officer called for the information directly from the Branch Manager of the bank, and the bank supplied bank statements and details of the demonetized currency deposited in the bank account. The AO observed that in current account No.384601010011133 with Union Bank of India, Railway Road, Kasganj, in which demonetized currency of Rs. 500/- and 1000/- were deposited in cash on 10.11.2016, 13.11.2016 and 29.11.2016 of Rs.2,50,000/-, Rs.2,50,000/- and Rs.1,27,500/- by the assessee as the pay-in slips bore the PAN and signatures of the ITA No. 139/Agr/2023 16 assesseealthough the said bank account was in the name of Anurag Kumar Neeraj Kumar. There was another bank account bearing No.384602010945067 maintained by the assesseewith Union Bank of India, Railway Road, Kasganj, wherein cash of Rs.45,000/- and Rs. 39,000/- was deposited on 12.11.2016 and 11.11.2016 in demonetized currency. Thus, the AO made the additions to the income of the assessee to the tune of Rs.7,11,500/- in the hands of the assessee u/s. 69A of the Act. Further, there was deposit of Rs.62,22,636/- of cash/credit entries in the aforesaid bank accounts. There was no explanation forthcoming from the assessee to several notices including SCN issued by the AO. This also led the Assessing Officer to compute income of the assessee by applying profit rate of 8% on the turnover of Rs.62,22,636/- , which led to additions to the tune of Rs. 4,97,810/- in the hands of the assessee. The assessee filed first appeal with ld. CIT(A) and in the first appeal the assessee duly explained that the said bank account bearing No.384601010011133was in the name of M/s. Anurag Kumar Neeraj Kumar, which is a proprietorship concern of Mr. Neeraj Kumar under PAN – COJPK5927B. It is explained by the assessee that said Mr. ITA No. 139/Agr/2023 17 Neeraj Kumar is brother of the assessee, and the assessee assists his brother in the business. The assessee has also produced bank certificate in original from Union Bank of India, Kasganj, in which it is clearly stated that Shri Neeraj Kumar is the proprietor of the said bank account bearing number 384601010011133, and the said bank account is running since 27.09.2002. The said bank certificate in original is placed in paper book at page 31, and is reproduced in this order also. The assessee has duly produced bank statement of the said bank account no. 3846010011133 in which the cash was deposited. Assessee has also placed on record GST registration effective from 01.07.2017, in which it is clearly mentioned that the trade name of M/s. Anurag Kumar Neeraj Kumar is the proprietary concern, of which Mr. Neeraj Kumar is the proprietor(although this is not relevant for us as we are concerned with assessment year 2017- 18). The assessee has produced Income-tax return of Shri Neeraj Kumar in which he has declared gross turnover of Rs.50,88,200/- declaring profit @ 8% u/s. 44AD of the Act availing presumptive scheme of taxation. Shri Neeraj Kumar is showing three bank accounts in return of income filed with Revenue, out of which one ITA No. 139/Agr/2023 18 bank account is with Union Bank of India bearing No. 384601010011133, in which aforesaid cash stood deposited. Shri Neeraj Kumar is stated to be brother of Shri Anurag Kumar as stated by the ld. Counsel for the assessee before the Bench and it is stated that the assessee occasionally deposits the cash arising out of sale proceeds of the concern, M/s. Anurag Kumar Neeraj Kumar(Prop. Mr. Neeraj Kumar) in the said bank account as the assessee is assisting his brother in its business, wherein inadvertently he has given his PAN instead of giving PAN of said concern Anurag Kumar Neeraj Kumar while depositing cash. Thus, in my view the assessee has satisfactorily explained that the said bank account maintained with Union Bank of India ,Raliway Road, Kasganj bearing number 384601010011133 belongs to Shri Neeraj Kumar, proprietor of Anurag Kumar Neeraj Kumar and if the department wanted to proceed, it ought to have proceeded against Neeraj Kumar by invoking provisions of Section 143(2) and / or 148 , instead of assessee. It is not the case that Neeraj Kumar has not owned the transactions rather it is claimed that he availed presumptive scheme of taxation u/s 44AD declaring gross turnover of Rs. 50,88,200 and ITA No. 139/Agr/2023 19 paying tax by computing income @8% u/s 44AD. The Revenue ought to have proceeded against said Mr. Neeraj Kumar by invoking 143(2) and/or Section 148. It was incumbent upon the authorities below to have issued summons to Mr. Neeraj Kumar u/s. 131 or ought to have made enquiries u/s. 133(6) with said Neeraj Kumar, to unravel complete truth. It is true that the assessee did not participated in the assessment proceedings, but the assessee duly participated in appellate proceedings conducted by ld. CIT(A). The powers of ld. CIT(Appeals) are co-terminus with the powers of the Assessing Officer including power of enhancement. It is also explained by the ld. Counsel for the assessee that no proceedings have been initiated u/s. 143(2) or 147 against said Neeraj Kumar and his return of income has been accepted by Revenue. In these circumstances. It is only in the case when said Mr. Neeraj Kumar disown the aforesaid transactions, the Revenue could have proceeded against the assessee. I do not find any merit in the addition of Rs.6,27,500/- being made in the hands of the assessee on account of cash deposited on 10.11.2016, 13.11.2016 and 29.11.2016 in the demonetization currency of Rs.500/- and Rs.1000/- in the bank ITA No. 139/Agr/2023 20 account No.384601010011133 maintained with Union Bank of India, Railway Road, Kasganj, as the said bank account belongs to Mr. Neeraj Kumar, proprietor of Anurag Kumar Neeraj Kumar.The Revenue has also not filed any C.O. with ITAT, thus, the Revenue is not aggrieved with the appellate order passed by ld. CIT(A). This addition as was made by the AO and later sustained by ld. CIT(A) is not sustainable and directed to be deleted.I order accordingly. 7.2 So far as the assessee is concerned, it has maintained bank account No.384602010945067 with Union Bank of India, Kasganj. I have perused the said bank account and there are cash deposits of Rs.84,000/- on 11.11.2016, 12.11.2016 during demonetization period, and apart from it there are some other deposits during the year, which in total are not exceeding Rs.50,000/-. The assessee has also deposited in cash an amount of Rs. 49,000/- during demonetization period in bank account maintained with SBI bearing account number 32336353163. The assessee has owned up these cash deposits, and declaration has also been made in ITR filed with Revenue. The assessee has already declared income of Rs.2,84,600/- in the return of income filed with the department. Under ITA No. 139/Agr/2023 21 these facts and circumstances. There is no such adverse finding by the authorities below that the said cash deposits are not accounted for by the assessee. I do not find any merit in the addition being made in the hands of the assessee.I,therefore, order deletion of the additions of Rs. 84,000/- made by the AO as income in the hands of the assessee which was later sustained by ld. CIT(A). I order accordingly. 7.3 Similarly, I do not find any merit in making addition of Rs.4,97,810/- in the hands of the assessee on account of presumptive scheme of taxation u/s 44AD, as the said deposits are also in the bank account of Neeraj Kumar namely Anurag Kumar Neeraj Kumar ,and the said bank account is owned by Shri Neeraj Kumar. If the department wanted to proceed , It ought to have proceeded against Mr. Neeraj Kumar, wherein department could have invoked provisions of Section 143(2) and/or Section 148. The department also did not find it relevant to issue summons u/s 131 or make enquiry u/s 133(6) with said Mr. Neeraj Kumar. It is true that the assessee did not participated in the assessment proceedings, but the assessee duly participated in appellate proceedings conducted by ld. ITA No. 139/Agr/2023 22 CIT(A). The power of ld. CIT(A) are co-terminus with the powers of the AO.It is not the case of the Revenue that the said Mr. Neeraj Kumar did not own the said deposits in the bank account. The Revenue has also not filed any C.O. with ITAT, thus, the Revenue is not aggrieved with the appellate order passed by ld. CIT(A). The Assessing Officer is directed to delete the additions in the hands of the assessee. 7.4 Accordingly as discussed in Para 7.1 to 7.3, ground No. 2 to 5 stand allowed. 7.5. Ground No. 1 & 6 are general in nature and do not require specific adjudication. 8. In the result, appeal filed by the assessee stands allowed. Order pronounced in the open court on 29/11/2024. (RAMIT KOCHAR) ACCOUNTANT MEMBER Dated: 29/11/2024 *aks/- "