APPOLLO TYRES LTD,COCHIN V. THE DCIT, COR.CIRCLE-1(1), KOCHI

ITTPA 743/COCH/2019

AI Insights

Apollo Tyres Ltd. appealed against the final assessment order for the Assessment Year 2015-16, which included various additions and disallowances made by the AO following the directions of the Dispute Resolution Panel (DRP). The main issues revolved around transfer pricing adjustments, disallowances of deductions related to research and development, gifts, investment promotion subsidies, and other specific expenditures. The Tribunal's decision addressed these issues by referencing previous cases and legal provisions, leading to a partial allowance of the appeal and remittance of several issues back to the AO for further examination.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 774393 (ITAT-COCHIN)
• Duration Of Justice: 5 year(s) 8 month(s) 19 day(s)
• Appeal Type: Income Tax (Transfer Pricing) Appeal
• Pronouncement Date: 12-09-2025
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Assessment Year: 2015-2016
• Appeal Filed On: 23-12-2019
• Other Referred Cases: Bell Ceramics Ltd. v. DCIT, Jay Engineering Works Ltd. v. CIT, CIT vs. Modi Industries Ltd. (No. 3), CIT v. Triveni Engineering and Industries Ltd., Prem Spinning and Weaving Mills Co. Ltd. v. CIT
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: SANJIT KUMAR DAS
• Assessee Lawyers: ABRAHAM JOSEPH MARKOS
• Keywords: Capital asset; Revenue expenditure; Transfer pricing; International transaction; Depreciation; Additional depreciation; Capital receipt; Gift; Capital expenditure; TDS
• Section: 143(3); 234B; 37; 115JB; 37(1); 80G; 32(1)(iia)

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH BEFORE SHRI INTURI RAMA RAO, AM AND SHRI RAHUL CHAUDHARY, JM IT(TP)A No. 743/Coch/2019 Assessment Year: 2015-16 Apollo Tyres Ltd. .......... Appellant 3rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [PAN: AAACA6990Q] vs. ACIT, Corporate Circle-1(1), Kochi ......... Respondent Assessee by: Shri Abraham Joseph Markos, Adv. Revenue by: Shri Sanjit Kumar Das, CIT-DR Date of Hearing: 20.08.2025 Date of Pronouncement: 12.09.2025 O R D E R Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the final assessment order dated 31.10.2019 passed u/s. 143(3) r.w.s. 144C(13) of Income Tax Act, 1961 (hereinafter \"the Act\") for Assessment Year (AY) 2015-16. 2. Brief facts of the case are that the appellant is a company incorporated under the provisions of Companies Act, 1956. It is engaged in the business of manufacture and sale of tyres, tubes and dealing in flaps. The return of income for AY 2015-16 was filed on Printed from counselvise.com 2 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. 28.11.2015 declaring income of Rs. 683,75,29,980/- and also reported book profit u/s. 115JB of Rs. 954,98,29,881/-. The return of income was revised on 30.11.2015 and 29.03.2017 declaring same income under normal provisions of Income Tax. However, the book profit was revised at Rs. 841,21,26,997/-. 3. The assessee company also reported the following international transactions from AE in from 3CEB: S.No. Description of Transaction Amount 1 Purchase of raw material 3,96,498 2 Purchase of tyres 11,78,07,170 3 Sale of Tyres 702,14,96,391 4 Purchase of semi finished goods 42,68,265 5 Purchase of capital goods 35,37,240 6 Receipt of royalty 7,38,35,968 7 Payment of royalty 88,57,029 8 Receipt of research and development services 48,86,68,487 9 Receipt of corporate manufacturing & quality services 6,69,61,400 10 Receipt of corporate marketing services 33,56,22,152 11 Receipt of corporate strategy services 13,26,51,811 12 Availing of Regional sales support services 5,58,33,335 13 Provision for corporate information technology services 5,21,19,012 15 Provision for corporate purchase services 26,17,095 16 Investment as membership contribution 40,48,500 17 Reimbursement of sales promotion expenses 3,00,71,815 18 Reimbursement of travel related 30,93,272 Printed from counselvise.com 3 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. expenses 19 Reimbursement of testing related expenses 64,36,685 20 Reimbursement of warranty related expenses 32,82,039 21 Reimbursement of professional expenses 42,17,224 22 Reimbursement of salary expenses 6,89,109 23 Recovery of miscellaneous administrative expenses 1,19,31,516 4. On noticing the international transactions, the AO referred the matter to the Transfer Pricing Officer (TPO) u/s. 92CA(1) of the Act for the purpose of benchmarking the above international transactions. The TPO vide order dated 31.10.2018 passed order u/s. 92CA(3) of the Act suggesting upward TP adjustment aggregating to Rs. 98,73,682/- in respect of the following segments: - a) Software segments of Rs. 77,94,492/- b) Recovery of expenses from AE of Rs. 20,79,900/- 5. On receipt of the TPO’s order, the AO passed draft assessment order u/s. 143(3) r.w.s. 144C(1) of the Act on 31.12.2018 proposing to make the following additions: - i. TP adjustment – Rs. 98,73,682/- ii. Disallowance of additional depreciation u/s. 32(1)(iia) of the Act on the ground that the plant and machinery was acquired and put to use during the previous year relevant to AY 2013- 14. Since the assets were put to use for less than 180 days, additional depreciation was allowed only at 10% as per second proviso to section 31 of the Act. Balance additional Printed from counselvise.com 4 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. depreciation cannot be allowed in subsequent AY, i.e. the year under consideration – Rs. 17,38,42,874/- iii. Disallowance of pre-operative expenditure details of which were extracted by the AO vide para 9 of the draft assessment order. These pre-operative expenditures were incurred during setting up of new plant at Chennai. In the books of account the appellant company had capitalised the pre-operative expenditure. However, in the return of income it is claimed as revenue expenditure placing reliance on the following decisions: - - Bell Ceramics Ltd. v. DCIT 2016 – TIOL-1688-HC-AHM- IT (Gujarat) - Jay Engineering Works Ltd. v. CIT 311 ITR 405 (Del) - CIT VS. Modi Industries Ltd. (No. 3) : 200 ITR 341 (Del) - CIT v. Triveni Engineering and Industries Ltd. 181 Taxman 5 (Del) - Prem Spinning and Weaving Mills Co. Ltd. v. CIT 98 ITR 20 - Kashiram Ramgopal v. CIT 36 Taxman 305 However, the AO was of the opinion that that these pre- operative expenditures should form part of cost of plant and machinery and buildings as envisaged u/s. 43(1) of the Act. Accordingly, disallowed the expenditure as revenue expenditure –Rs.2,76,59,291/- iv. Disallowance of excess claim of deduction u/s. 35(2AB). The appellant company made claim for deduction of Rs. 199,52,51,737/- u/s. 35(2AB) of the Act. The AO was of the opinion that only expenditure incurred on inhouse R&D facility approved by DSIR and certified by DSIR is alone is eligible for deduction u/s. 35(2AB) of the Act. Accordingly, the AO disallowed a sum of Rs. 96,86,53,065/-. v. The AO also made addition of Rs. 2,42,841/- on account of discrepancies in TDS reconciliation statement. Printed from counselvise.com 5 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. vi. The AO disallowed the year end provisions of Rs. 23,12,983/- on the ground that the expenditure is an unascertained liability. vii. Disallowance of gifts Rs. 1,31,95,872/- viii. Investment promotion subsidy Rs. 52,10,36,519/- ix. Disallowance out of 80IA Rs. 1,01,93,978/- x. Disallowance of deduction u/s. 80G Rs. 2,52,50,000/- xi. The AO also made several additions to the book profits returned u/s. 115JB of the Act. 6. On receipt of the draft assessment order, the appellant company filed objections before the Dispute Resolution Panel (DRP) contesting all the above additions. The DRP issued directions on 19.09.2019 confirming the TP adjustments and other additions except allowing additional depreciation following the Tribunal’s decision in assessee’s own case. On receipt of the directions from the DRP, the AO had passed the final assessment order dated 31.10.2019 passed u/s. 143(3) r.w.s. 144C(13) of the Act at a total income of Rs. 840,88,17,215/- after making the following additions: - Adjustment recommended by TPO 98,73,682 Disallowance of pre-operative expenditure 2,76,59,291 Disallowance of claim of deduction u/s. 35(2AB) 96,86,53,065 Difference out of TDS reconciliation 2,42,841 Disallowance of year end provisions 23,12,983 Disallowance of gifts 1,31,95,872 Disallowance of 80G 2,52,50,000 Addition of Investment Promotion Subsidy 52,10,36,519 Disallowance out of 80IA 1,01,93,978 Printed from counselvise.com 6 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. 7. Being aggrieved by the final assessment order the appellant is in appeal before this Tribunal in the present appeal raising the following grounds: “1. The assessment order passed u/s 143(3) r.w.s. 92CA(3) and sec. 144C(13) of the Income-tax Act, 1961 ('the Act') dated 31 October 2019, by the Assessing Officer ('AO') pursuant to the directions of the Dispute Resolution Panel ('DRP'), and the additions/disallowances made by the AO, are illegal and bad in law. 2. The additions/disallowances made are unsustainable, unjust, highly excessive and are not based on any material on record. Total income of the Appellant has been incorrectly and un-lawfully assessed under normal provisions of the Act at Rs. 840,88,17,220/-. The AO also incorrectly and un-lawfully assessed the Book Profits under sec. 115JB of the Act, at Rs. 893,57,19,040/-. 3. Regarding addition / disallowance of Rs. 2,76,59,291/- (Expenses for expansion of existing plant) a. The AO/DRP erred in law and on facts in making an addition/disallowance of Rs. 2,76,59,291/- without appreciating that the same represents an allowable revenue expenditure. Such expenses are incurred by the Appellant for the expansion of its existing business of manufacturing tyres and are revenue in nature. b. The AO/DRP erred in applying Section 43 and stating that expenses should be capitalized without appreciating that they have been incurred with a view to expand the manufacturing base, and that they are revenue in nature. The said expenses are not for setting-up a distinct / separate unit, but have been incurred only to expand the existing business of the Appellant. c. The AO/DRP erred in law and on the facts, in disallowing the expenditure without appreciating that all the pre- Printed from counselvise.com 7 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. conditions of claiming such expenses as business expense under the provisions of Income Tax Act, 1961 are satisfied and these expenses are deductible in computing the taxable income of the Appellant. d. Moreover, the AO has not disputed the facts submitted by the Appellant, and has not distinguished legal decisions relied upon by the Appellant while making the claim. The AO has only stated that the decision of Hon'ble ITAT in the Appellant's own case for prior years has not been accepted by the Revenue. e. That, without prejudice, the AO erred in not appreciating that the assets have actually been put to use and hence, erred in not granting depreciating (including additional depreciation & investment allowance u/s 32AC) on this expenditure. Moreover, the DRP erred in not adjudicating this alternative ground, even though all the facts, material and evidence necessary to adjudicate the ground, was placed before the DRP, during the course of the hearing. 4. Regarding disallowance of Rs. 96,86,53,065/- being deduction claimed under sec. 35(2AB) of the Act a. The AO/DRP erred in law and on facts, in disallowing the weighted deduction of Rs. 96,86,53,065/- as claimed by the Appellant under sec. 35(2AB) of the Act in respect of expenditure incurred by it for its in-house R&D facility. b. The AO/DRP erred in adopting a restrictive interpretation to the phrase \"in-house\" without appreciating that there is no embargo under sec. 35(2AB), which restricts the deductibility of an expenditure that is incurred at different premises, relatable to the \"in-house\" R& D activity. c. The AO/DRP failed to appreciate that all the requisite pre- conditions for 35(2AB) have been fulfilled by the Appellant, and 35(2AB) being a beneficial provision with a view to encourage in-house research and development, is applicable on the facts of the present case. Printed from counselvise.com 8 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. d. The AO failed to appreciate that Form 3CL is a mere procedural intimation and cannot form the basis to compute the deduction u/s 35(2AB). e. The DRP erred in not adjudicating the ground of 200% weighted deduction, even though all the facts, material and evidence necessary to adjudicate the ground, was placed before the DRP, during the course of the hearing. f. Without prejudice to the above, the A.O. erred in allowing only 100% deduction of R&D Capital Expenditure of Rs. 79.51 lakhs quantified by DSIR as against eligible weighted amount of 200% i.e. Rs. 159.02 lakhs thus resulting into excessive disallowance of R&D capital expense by Rs. 79.51 lakhs. g. Without prejudice to the above, the AO erred in not allowing depreciation including additional depreciation and deduction u/s 32AC amounting to INR 3,61,00,488/- on the total capital expenditure of INR 15,92,42,390/- (incl. INR 9,02,61,539/-on Building) incurred by the assessee company at its R&D centre at Chennai. 5. Regarding disallowance of expenditure on gifts of Rs. 1,31,95,872/- a. The AO has erred in disallowing the deduction claimed under sec. 37 of the Act, for Rs. 1,31,95,872/-, being expenditure incurred by the Appellant on gifts, without appreciating that the same was wholly and exclusively incurred for the purpose of business of the Appellant. b. The AO has also erred in law and on facts, in considering the expenditure on gifts, as personal in nature. 6. Regarding the disallowance for claim of Investment Promotion Subsidy of Rs. 52,10,36,519/- as capital subsidy a. The AO/DRP erred in law and on facts, in disallowing the claim of the Appellant, that the investment promotion subsidy amounting to Rs 52,10,36,519/- as received by it Printed from counselvise.com 9 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. for setting up a Tyre manufacturing plant in the state of Tamil Nadu, is a capital receipt. b. On the facts and circumstances of the case and in law, the AO erred in holding that the investment promotion subsidy is linked to production and therefore, a revenue receipt. 7. Regarding claim of deduction under sec. 80-1A of the Act, in respect of shortfall compensation received amounting to Rs 1,01,93,978/- a. The AO has erred in law and on facts, in reducing the deduction claimed under sec. 80-1A of the Act, by Rs. 1,01,93.978/-, being the amount of shortfall compensation received by the Appellant. b. The AO has erred in law and on facts, in holding that the said compensation received for shortfall in production of power, was not linked to power generation undertaking i.e windmill, and therefore, not eligible for deduction u/s 80- IA of the Act. 8. Regarding disallowance of deduction under Section 80G of Rs. 2,52,50,000/- a. The AO has erred in law and on the facts of the case, in not appreciating that CSR expenditure amounting to Rs. 5,05,00,000/- is eligible for deduction of 50% i.e. Rs. 2,52,50,000/- u/s 80G of the Act. b. The AO has erred in alleging that payment qualifies for deduction u/s 80G of the Act only when it is made voluntarily and the present payment for which sec. 80G deduction is claimed is towards CSR which is mandated by section 135 of Company Act, 2013 and not voluntary. c. The AO has erred in applying the ratio of amendment brought in section 37(1) by the Finance Act 2014 on deduction u/s 80G of the Act. The AO has erred in not appreciating that both the sections are mutually exclusive. 9. Regarding additions/adjustments made in computing 'book profits\" under sec. 115JB of the Act. Printed from counselvise.com 10 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. a. The AO has erred in law and on facts in adding back the subsidy of Rs. 52,10,36,519/-in computing the 'book profits' under sec. 115JB of the Act. b. The AO has erred in appreciating that the investment promotion subsidy received by it for setting up a Tyre manufacturing plant in the state of Tamil Nadu, is not an income and therefore, cannot be brought to tax under the Act even by virtue of the provisions of sec. 115JB of the Act. c. The AO has made the disallowance without mentioning the reason for such disallowance. 10. Regarding transfer pricing adjustment of Rs. 77,94,492/- (Corporate IT services) a. That the TPO/AO/DRP erred in not appreciating that the Transfer Pricing documentation is maintained as per the provisions of the Indian Transfer Pricing Law, and in the absence of any defect, the economic analysis undertaken by the Appellant should stand accepted. Moreover, the AO/DRP/TPO grossly erred by making a transfer pricing addition of Rs. 77,94,492/- to the income of the Appellant and erred in holding that the international transactions pertaining to provision of software development services do not satisfy the arm's length principle envisaged under the Act. b. That the TPO/AO/DRP erred in adopting and applying filters of current year data, companies having different financial year ending, service income < 1 cr, SWD is less than 75% of the total operating revenues, RPT more than 25%, export service income < than 75% of the sales and employee cost <25% of the turnover. Adoption of such filters is arbitrary and contrary to the provisions of the Act. c. The TPO/AO/DRP failed to appreciate that the comparables chosen by the TPO are not functionally comparable since they do not meet the Functions performed, assets used, risks assumed ('FAR') test as Printed from counselvise.com 11 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. envisaged under Rule 10B(2) of the Income Tax Rules, 1962 ('the Rules') and hence cannot be used for benchmarking the transaction. Hence, such comparables ought to be excluded from the final list of comparable companies. d. The TPO/AO/DRP erred in not appreciating that all the comparables chosen by the Appellant in its Transfer Pricing Documentation meet the FAR test, and as such are comparable to the Appellant. Hence, such comparables ought to be included in the final list of comparable companies. e. That the TPO/AO/DRP erred in not allowing the benefit of working capital adjustment and risk adjustment, to the Appellant, without appreciating that such an adjustment is warranted in terms of Rule 10B(3) of the Rules. 11. Regarding transfer pricing adjustment of Rs. 20,79,190/- (Recovery of Salary expenses) a. On the facts and in the circumstances of the case and in law, the Ld. AO/Ld. TPO grossly erred in not appreciating that the reimbursement of salary expenses of Rs 20,79,190/- to its associated enterprises ('AEs') is purely on cost to cost basis. Hence no mark-up was warranted. 12. Regarding deduction of Education Cess a. The AO/DRP erred in law and on facts, in not allowing the deduction of education cess amounting to Rs 6,76,91,546/- being cess on income tax. The AO/DRP erred in not appreciating that deduction of education cess is an allowable business expense u/s 37 r.w.s. 40a(ii) of the Income Tax Act, 1961. 13. Regarding deduction of unrealized foreign exchange gain a. The AO / DRP erred in law and on facts, in not allowing deduction of Rs 1,47,31,064/- being unrealized foreign exchange gain on capital assets pertaining to AY 14-15 & suo-moto included in return of income of AY 2015-16. The Printed from counselvise.com 12 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. AO/DRP erred in not appreciating the fact that the said amount has already been taxed in assessment concluded for AY 2014-15 thus leading to double taxation. 14. Regarding SEBI Penalty of Rs. 1,00,00,000/- a. The DRP erred in law and on facts in not allowing deduction of Rs. 1,00,00,000/-being penalty paid to SEBI which is an allowable business expense u/s 37 of the Income Tax Act, 1961. 15. Regarding Foreign Tax Credit of Rs. 11,10,869/- a. The AO erred in law and on facts in denying foreign tax credit of Rs 11,10,869/-being taxes deducted on income earned from source outside India and corresponding income offered to tax in return of income for subject assessment year. 16. The AO has erred in law and on facts, in not adjusting MAT credit carried forwarded from past years while determining the tax liability for the year under consideration Le. AY 2015-16. 17. The AO has erred in law and on facts in charging interest of Rs. 47,39,93,263/- u/s 234B of the Income Tax Act.” 8. The ground of appeal Nos. 1 & 2 are general in nature, requiring no adjudication. 9. The ground of appeal No. 3 challenges the disallowance of pre- operative expenditure. Similar issue had been decided by this Bench in assessee’s own case in ITA No. 609/Coch/2017 for AY 2013-14. For the detailed reasons given in para 8 of the said order, this issue stands allowed. In the result, this ground of appeal stands allowed. 10. The ground of appeal No. 4 challenges the disallowance of claim u/s. 35(2AB) of the Act. Similar issue is also decided by this Printed from counselvise.com 13 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. Bench in assessee’s on case in ITA No. 609/Coch/2017 for AY 2013-14. For the detailed reasons given paras10&11 of the said order, this ground stands partly allowed. 11. The ground of appeal No. 5 challenges disallowance of gift of Rs. 1,31,95,872/-. Similar issue was decided in ITA No. 690/Coch/2017 vide paras 18 & 19 of the order. For the detailed reasons given therein, this issue stands allowed. 12. The ground of appeal No.6 is with regard to the disallowance of claim of investment promotion subsidy of Rs. 52,10,36,519/- as capital receipt. During the previous year relevant to the assessment year under consideration, the appellant company received Rs. 51,10,36,519/- as investment promotion subsidy from the Government of Tamil Nadu. Similar issue came up for consideration before this Bench in ITA No. 575/Coch/2018 wherein this Bench held that the subsidy received is capital receipt and required to be reduced from the actual cost of the asset for the purpose of depreciation in terms of explanation 10 to section 43(1) of the Act. For the detailed reasons given therein vide paras 24 and 25 this issue stands partly allowed. 13. The ground of appeal No. 7 challenges disallowance of claim for deduction u/s. 80IA of Rs. 1,01,93,978/- in respect of compensation received from shortfall in production from the contractor. This issue came up for consideration before this Bench in Printed from counselvise.com 14 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. assessee’s own case in ITA No. 575/Coch/2018 for AY 2014-15, for the detailed reasons given therein vide para 28 this ground of appeal stands dismissed. 14. The ground of appeal No. 8 Challenges disallowance of claim for deduction of Rs. 2,52,50,000/-u/s. 80G of the Act. It is stated before the AO that during the previous year relevant to the assessment year under consideration the appellant company contributed a sum of Rs. 5,05,00,000/- to the institutions, trust approved under 80G of the Act. The same qualifies for deduction u/s. 80G of the Act. The issue is remitted back to the file of the AO to examine the claim afresh based on the material produced before him. This, this ground of appeal stands partly allowed for statistical purposes. 15. The ground appeal No. 9 challenges the additions/adjustments made to book profit for the purpose of computing tax liability u/s. 115JB of the Act. This issue came up for consideration before this Bench in assessee’s own case in ITA No. 575/Coch/2018 for AY 2014-15, for the detailed reasons given therein vide paras 31 &32 this ground of appeal stands dismissed. 30. The ground of appeal Nos. 10&11 challenges the addition on account of transfer pricing adjustment of Rs. 77,97,492/- in respect of Corporate IT Services and Rs. 20,79,180/- in respect of recovery of expenses from AE. The issues stand remitted back to the file of Printed from counselvise.com 15 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. the AO/TPO in terms of the passed by Tribunal on 10.01.2017 for AY 2011-12. 31. The grounds appeal Nos. 12, 16 & 17is dismissed as not pressed during the course of appeal. 16. The ground of appeal Nos. 13, 14 & 15 relating to addition on account of foreign exchange fluctuations, the disallowance of SEBI penalty of Rs. 1,00,00,000/- and foreign tax credit of Rs. 11,10,869/- are remitted to the file of AO for fresh examination of the issues in light of the submission made before us. In the result, the grounds of appeal partly allowed for statistical purposes. 17. In the result, the appeal filed by the assessee stands partly allowed for statistical purposes. Order pronounced in the open court on 12th September, 2025. Sd/- Sd/- (RAHUL CHAUDHARY) JUDICIAL MEMBER (INTURI RAMA RAO) ACCOUNTANT MEMBER Cochin, Dated:12th September, 2025 n.p. Printed from counselvise.com 16 IT(TP)A No. 743/Coch/2019 Apollo Tyres Ltd. Copy to: 1. The Appellant 2. The Respondent 3. The Pr. CIT concerned 4. The Sr. DR, ITAT, Cochin 5. Guard File By Order Assistant Registrar ITAT, Cochin Printed from counselvise.com "