M/S. AGARWAL TRANSPORT CORPORATION PVT. LTD., Indore V. THE DCIT 5(1), Indore

CO 41/IND/2014

• Counselvise Citation: [2015] 123 COUNSELVISE.COM (IT) 1747 (ITAT-INDORE)
• Duration Of Justice: 1 year(s) 4 month(s) 23 day(s)
• Appeal Type: Cross Objection
• Pronouncement Date: 01-12-2015
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2009-2010
• Appeal Filed On: 09-07-2014
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: R A VERMA
• Keywords: Question of law
• Section: 68

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE SHRI D.T. GARASIA, JUDICIAL MEMBER AND SHRI B.C.MEENA, ACCOUNTANT MEMBER I.T.A.NO. 356 /IND/2014 A.Y : 2009 - 10 DY. CIT, 5(1), INDORE VS. M/S. AGARWAL TRANSPORT CORPORATION PVT.LTD., APPELLANT RESPONDENT PAN NO. AAECA1502C C.O.N9O.41/IND/2014 (ARISING OUT OF I.T.A.NO.356/IND/2014 ) A.Y : 2009 - 10 M/S. AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. VS. DY. CIT, 5(1), INDORE APPELLANT RESPONDENT DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 2 2 DEPARTMENT BY : SHRI R. A. VERMA, DR ASSESSEE BY : SHRI AJAY T ULSIYAN , CA O R D E R PER D. T. GARASIA, J.M. APPEAL BY THE DEPARTMENT AND CROSS OBJECTION BY THE ASSESSEE ARE DIRECTED AGAINST THE ORDER OF LD. CIT( A)-II, INDORE, DATED 31.01.2014 FOR ASSESSMENT YEAR 2009-10. 2. THE BRIEF FACTS OF THE CASE ARE AS UNDER. THE ASSESSEE COMPANY IS ENGAGED IN THE BUSINESS OF TRANSPORTATION. THE RETURN OF INCOME FOR THIS ASSES SMENT YEAR WAS E-FILED ON 26.09.2009 DECLARING AN INCOME OF RS . 5,16,81,220/-. THE ASSESSMENT WAS COMPLETED U/S 143 (3) ON 26.12.2011 BY MAKING THE FOLLOWING ADDITIONS :- DATE OF HEARING : 12.10. 2015. DATE OF PRONOUNCEMENT : 01.12 .2015 DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 3 3 RETURNED TOTAL INCOME 5,16,81,220/- DISALLOWANCE OF INTEREST PAID TO LOAN CREDITORS 13, 66,932/- AD HOC DISALLOWANCE OUT OF REPAIRS MAINTENANCE EXP. 1,50,000/- AD HOC DISALLOWANCE OUT OF STAFF WELFARE EXPENSES 50,000/- AD HOC DISALLOWANCE OUT OF OFFICE GENERAL EXPENSES 1,50,000/- TOTAL INCOME ASSESSED RS. 5,33,98,152/- THE LD. CIT(A) VIDE ORDER DATED 31.01.2014 IN IT-89 0/11- 12/360 DECIDED THE APPEAL PARTLY IN FAVOUR OF THE A SSESSEE. THE LEARNED CIT(A) MAINTAINED A DISALLOWANCE OF RS. 3,0 0,000/- ON ACCOUNT OF INTEREST PAID TO M/S. OPTIMATE TEXTILES LIMITED. AGGRIEVED THE DEPARTMENT IS IN APPEAL AND THE ASSES SEE HAS FILED THE CROSS OBJECTIONS. GROUND NOS. 1, 2 & 3 : 3. THE FIRST THREE GROUNDS OF APPEAL ARE REGARDING TH E ESTIMATED DISALLOWANCE OF 1. RS.1,50,000/- OUT OF REPAIRS AND MAINTENANCE EXPENS ES 2. RS.50,000/- OUT OF STAFF WELFARE EXPENSES OF RS.2,9 2,215/- . 3. RS.1,50,000/- OUT OF OFFICE GENERAL EXPENSES. DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 4 4 4. THE AO FOUND THAT I N THE CASE OF REPAIR & MAINTENANCE EXPENSES, THE ASSESSEE COMPANY HAS INCURRED EXPENSE S OF RS 18,21,633/- UNDER THE HEAD REPAIR & MAINTENANCE EXP ENSES DURING THE YEAR UNDER ASSESSMENT. THESE EXPENSES IN CLUDE REPAIR AND MAINTENANCE OF VEHICLE AS WELL AS PLANT AND MACHINERY. DURING VERIFICATION OF THESE EXPENSES SO ME OF THE BILLS AND SUPPORTING VOUCHERS WERE NOT PRODUCED BY THE ASSESSEE. SOME OF THE EXPENSES HAVE BEEN PAID IN CA SH. CONSIDERING ALL THESE FACTS, THE AO MADE THE ADDITI ON OF RS. 1.50 LACS. 5. SIMILARLY, IN THE CASE OF DISALLOWANCE OF EXPENSES UNDER THE HEAD STAFF WELFARE EXPENSES, THE ASSESSEE COM PANY HAS INCURRED THE EXPENSES OF RS 2,92,215/- UNDER THE H EAD STAFF WELFARE EXPENSES DURING THE YEAR. ON VERIFICATION OF THESE EXPENSES ON TEST CHECK BASIS, THE AO NOTICED THAT S OME OF THE VOUCHERS WERE SELF-PREPARED AND THE PERSONAL ELEMEN T OF USE OF THESE EXPENSES BY THE DIRECTORS AND EMPLOYEES OF TH E COMPANY CANNOT BE RULED OUT LOOKING TO THE NATURE OF BUSINE SS. THE AO DISALLOWED RS. 50,000/- OUT OF STAFF WELFARE EXPEN SES. 6. REGARDING DISALLOWANCE OF EXPENSES UNDER THE HEAD DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 5 5 OFFICE GENERAL EXPENSES, THE AO OBSERVED THAT THE ASSESSEE COMPANY HAS INCURRED EXPENSES OF RS 17,54,658/- UND ER THE HEAD OFFICE GENERAL EXPENSES. ON VERIFICATION OF TH ESE EXPENSES ON TEST BASIS, THE AO FOUND THAT BILLS AND VOUCHERS FOR SUPPORTING OF SOME OF THE EXPENSES WERE MISSING. CA SH PAYMENTS TO THE PARTIES WERE ALSO MADE ON SOME INST ANCES. THE AO DISALLOWED RS. 1,50,000/- ON LUMP SUM BASIS OUT OF OFFICE AND GENERAL EXPENSES. 7. THE MATTER CARRIED TO THE LD. CIT(A) AND THE LD. C IT(A) DELETED ALL THE ABOVE DISALLOWANCES BY OBSERVING AS UNDER :- THE REASONS FOR MAKING THESE DISALLOWANCES BY THE ASSESSING OFFICER ARE THAT SOME OF THE VOUCHERS WER E SELF PREPARED AND THE PERSONAL ELEMENT OF USE OF THESE EXPENSES. THE ASSESSEE HAS MADE COMMON SUBMISS IONS IN THIS BEHALF AND RELIED ON THE DECISION OF HON'BLE I.T.A. T., PUNE BENCH IN THE CASE OF LAVRIDS KNUDSEN MASKINFABRIK (INDIA) LIMITED VS. ADDL. CIT, 102 TTJ 88. MY ATTENTION IS ALSO DRAWN TO THE CIT(A) ORDER IN T HE APPELLANTS OWN CASE IN ASSESSMENT YEAR 2005-06 DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 6 6 WHERE OFFICE GENERAL AND REPAIRS AND MAINTENANCE EXPENSE WERE DELETED. THE ISSUE IS CONSIDERED. THE AO HAS N OT GIVEN ANY SPECIFIC INSTANCE WHERE THE EXPENSES ARE NOT SUPPOR TED BY VOUCHERS/BILLS. WHEN THE APPELLANT WAS MAINTAINI NG REGULAR BOOKS OF ACCOUNTS AND WAS ALSO SUBJECTED TO AUDIT THE AO AFTER EXAMINING THE SAME ON TEST CHECK BASIS SHOULD HAVE GIVEN SOME INSTANCES TO SUPPORT H IS FINDINGS. THE NATURE OF EXPENSES ALSO SHOULD HAVE B EEN CONSIDERED BY THE ASSESSING OFFICER. THE APPELLANT HAS ALSO INVITED MY ATTE NTION TO THE FACT THAT SIMILAR AD HOC DISALLOWANCES WERE MADE IN THE APPELLANTS OWN CASE FOR ASSESSMENT YEAR 2005-06 WHICH HAVE BEEN DELETED BY MY PREDECESSOR. THE SAID RELIEF GIVEN BY MY PREDECESSOR HAS ALSO BEEN ENDORS ED BY THE HON'BLE I.T.A.T. INDORE BENCH IN THE APPELLA NTS OWN CASE IN I.T.A.NO. 151/IND/2009 DATED 31.10.2011 REPORTED IN 18 ITJ 717. IN VIEW OF THE ABOVE DISCUSSIONS, THE AD HOC DISALLOWANCES MADE BY THE ASSESSING OFFICER ARE HER EBY DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 7 7 DELETED. THESE GROUNDS ARE ALLOWED. 8. THE LD. DR RELIED ON THE ORDER OF THE A.O. 9. THE LD. AUTHORIZED REPRESENTATIVE SUBMITTED THAT TH E MAIN REASON CITED FOR THESE DISALLOWANCES IS THAT S OME OF THE BILLS AND VOUCHERS WERE NOT PRODUCED AND WERE SELF PREPARED. SOME OF THESE EXPENSES HAVE BEEN MADE IN CASH, THE PERSONAL ELEMENT OF USE OF THESE EXPENSES BY THE DIRECTORS A ND EMPLOYEES OF THE COMPANY CANNOT BE RULED OUT LOOKING TO THE N ATURE OF BUSINESS. HOWEVER, NO SPECIFIC INSTANCE HAS BEEN PO INTED OUT BY THE AO. IT WAS FURTHER CONTENDED THAT THAT SIMILAR AD-HOC DISALLOWANCES MADE IN THE ASSESSEES OWN CASE FOR A SSESSMENT YEAR 2005-06 WERE DELETED BY THE LD. CIT(A) AND TH E SAID RELIEF HAS ALSO BEEN ENDORSED BY THE HONBLE ITAT INDORE B ENCH IN THE ASSESSEES OWN CASE IN ITA NO 151/IND/2009 DATED 31 .10.2011. THE LD. AUTHORIZED REPRESENTATIVE FURTHER CONTENDED THAT THE ASSESSEE IS MAINTAINING REGULAR BOOKS OF ACCOUNTS W HICH IS SUBJECTED TO AUDIT AND TAX AUDIT. THERE IS NO ADVER SE QUALIFICATION BY THE AUDITORS. ANY PERSONAL EXPENS ES DEBITED TO THE PROFIT & LOSS ACCOUNT WOULD HAVE BEEN REPORTED IN THE TAX DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 8 8 AUDIT REPORT. THE AO HAS SATISFIED HIMSELF ABOUT TH E BOOKS AND SUPPORTING BY TEST CHECKING THE SAME. THERE IS FAIL URE TO CONSIDER THE NATURE OF EXPENSES AS SOME TIMES, THEY ARE REQUIRED TO BE PAID IN CASH. THERE ARE NO SPECIFIC INSTANCES CITED BY THE ASSESSING OFFICER WHERE HE FELT DISSATISFIED . 10. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PAR TIES. WE FIND THAT THE REGULAR BOOKS OF ACCOUNT ARE MAINT AINED BY THE ASSESSEE AND THE AO HAS NOT GIVEN ANY SPECIFIC INST ANCE WHERE THE EXPENSES ARE NOT SUPPORTED BY VOUCHERS/BILLS. W E ALSO FIND THAT SIMILAR AD-HOC DISALLOWANCES MADE IN THE ASSES SEES OWN CASE FOR ASSESSMENT YEAR 2005- 06 WERE DELETED BY THE LD. CIT(A) AND THE SAID RELIEF HAS ALSO BEEN ENDORSED BY THE H ONBLE ITAT INDORE BENCH IN THE ASSESSEES OWN CASE IN ITA NO 151/IND/2009 DATED 31.10.2011. THE LD. DR COULD NOT BRING ANYTHING CONTRARY TO THE FINDING OF THE LD. CIT(A). WE UPHOLD THE ACTION OF THE LD. CIT(A). OUR INTERFERENCE IS NOT R EQUIRED. GROUND NOS. 1, 2 & 3 ARE REJECTED. 11. THE FOURTH GROUND OF APPEAL IS REGARDING THE RESTRICTING THE DISALLOWANCE OF INTEREST OF RS. 13, 66,932/- PAID/ PROVIDED ON UNSECURED LOAN TAKEN FROM SOME PARTIES IN EARLIER DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 9 9 YEARS TO RS. 3,00,000/ - BY THE LD. CIT(A) . 12. THE AO LOOKING TO THE FACT THAT THE LOAN CREDITORS WERE FOUND INGENUINE LENDERS IN OTHER CASES, INTEREST PA ID TO THEM BY THE ASSESSEE CANNOT BE HELD TO BE GENUINE AND DISAL LOWED THE INTEREST AMOUNTING TO RS. 13,66,932/- AND ADDED TO THE TOTAL INCOME OF THE ASSESSEE. 13. THE DETAILS OF THE DISALLOWANCE OF INTEREST ARE AS UNDER :- S.NO. NAME OF THE CREDITOR INTEREST PAID DURING THE YEAR NAME OF THE ASSESSEE IN WHICH ADDITION WAS MADE U/S 68 REMARK 1 PARADISE GARMENT PVT. LTD. 6,00,000 AGRAWAL COAL A.Y. 2008-09 ADDL CIT R-5, INDORE 2 UNNO INDUSTRIES LTD. 2,16,000 KARAN MITTAL AY 2007-08 ACIT 5(1), INDORE 3 MOTIKA FINANCE LTD. 2,50,932 KARAN MITTAL AY 2007-08 ACIT 5(1), INDORE 4 OPTIMATE TEXTILE LTD. 3,00,000 OWN CASE AY 2005- 06 ADDL CIT- 5, INDORE. 13,66,932 DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 10 10 14. THE MATTER CARRIED TO THE LD. CIT(A) AND THE LD. C IT(A) HAS DELETED THE DISALLOWANCE OF INTEREST OF RS. 10, 66,932/- PAID/PROVIDED TO PARTIES AT S. NO. 1 TO 3 BUT UPHEL D THE ADDITION OF RS. 3,00,000/- ON ACCOUNT OF INTEREST PAID TO OP TIMATE TEXTILE LIMITED. THE LD. CIT(A) OBSERVED THAT THE SIMILAR D ISALLOWANCES OF INTEREST MADE IN THE ASSESSEES OWN CASE, IN THE IMMEDIATELY PRECEDING YEAR I.E. AY 2008-09, ON THE SAME PREMISE AND ON THE IDENTICAL FACTS AND CIRCUMSTANCES OF THE CASE, WHIC H WERE DELETED BY THE LD CIT(A) AND THE SAID ORDER HAS ALS O BEEN APPROVED BY THE HONBLE ITAT INDORE BENCH IN THE AS SESSEES OWN CASE AND THE ACTION OF THE LD CIT(A) OF DELETIN G THE DISALLOWANCES OF INTEREST HAS BEEN ENDORSED BY THE HONBLE ITAT STATING THAT SINCE NO ADDITION HAS BEEN MADE U/S 68 , IN THE ASSESSEES OWN CASE, INTEREST CANNOT BE DISALLOWED. SO TO THE EXTENT OF INTEREST DISALLOWANCE OF RS. 10,66,932/-, RELATED TO FIRST THREE PARTIES IS DELETED AND THE PRESENT CASE IS COVERED BY THE ORDER OF THE HONBLE TRIBUNAL, INDORE BENCH IN FAVOUR OF THE ASSESSEE. 15. THE LD. DR RELIED ON THE ORDER OF THE AO. 16. THE LD. AUTHORIZED REPRESENTATIVE REITERATED THE DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 11 11 SUBMISSIONS CONTENDING THAT IN THE IMMEDIATELY PRECEDING YEAR I.E. AY 2008-09, ON THE SAME PREMISE AND ON THE IDE NTICAL FACTS AND CIRCUMSTANCES OF THE CASE, WHICH WERE DELETED B Y THE LD CIT(A) AND THE SAID ORDER HAS ALSO BEEN APPROVED BY THE HONBLE ITAT INDORE BENCH IN THE ASSESSEES OWN CASE AND TH E ACTION OF THE LD CIT(A) OF DELETING THE DISALLOWANCES OF INTE REST HAS BEEN ENDORSED BY THE HONBLE ITAT STATING THAT SINCE NO ADDITION HAS BEEN MADE U/S 68, IN THE ASSESSEES OWN CASE, INTER EST CANNOT BE DISALLOWED. 17. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PAR TIES. WE FIND THAT LD. DR COULD NOT BRING ANYTHING CONTRA RY TO THE FINDING OF THE LD. CIT(A). WE UPHOLD THE ACTION O F THE LD. CIT(A). OUR INTERFERENCE IS NOT REQUIRED. 18. AS REGARDS THE DISALLOWANCE OF INTEREST PAYMENT OF RS. 3,00,000/- TO OPTIMATE TEXTILE INDUSTRIES, THE LD. CIT(A) OBSERVED THAT THE SAID COMPANY WAS FOUND TO BE A BO GUS COMPANY IN THE ASSESSMENT PROCEEDINGS OF ASSESSMENT YEAR 2005-06 IN THE ASSESSEES OWN CASE. THE ORDER OF TH E AO WAS CONFIRMED BY THE LD. CIT(A) AND FURTHER BY THE I.T. A.T., INDORE BENCH. SINCE THE VERY EXISTENCE OF OPTIMATE TEXTILE INDUSTRIES DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 12 12 HAS BEEN DOUBTED AND PROVED TO BE BOGUS, THE A O WAS JUSTIFIED IN DISALLOWING THE INTEREST PAID TO OPTIMATE TEXTIL E INDUSTRIES. THE ASSESSEE HAS SUBMITTED TO THE LD. CIT(A) THAT T HE HON'BLE M.P.HIGH COURT HAS ADMITTED THE APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER OF THE HON'BLE I.T.A.T. HOWEVER, THE STATUS AS OF NOW IS THAT THE SAID LOAN CREDITOR HAS BEEN ADJU DGED AS NON- EXISTING BY THE HON'BLE I.T.A.T. AND THE MATTER HAS BEEN DECIDED AGAINST THE ASSESSEE. THUS, THE DISALLOWANCE OF RS. 3,00,000/- PAID TO OPTIMATE TEXTILE INDUSTRIES WAS UPHELD AND REJECTED. CONSEQUENTLY, THE GROUND NO. 4 IS ALLOWED IN PART. CROSS OBJECTION NO.41/IND/2014 : 19. THE ASSESSEE HAS TAKEN THE FOLLOWING GROUND IN CROS S OBJECTION :- THAT THE LD. CIT(A) ERRED IN UPHOLDIN G THE DISALLOWANCE MADE BY THE ASSESSING OFFICER OF RS. 3,00,000/- OU T OF INTEREST PAID ON UNSECURED LOAN. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE SAID INTEREST EXPENDITURE HAS BEEN PROPERLY INCURRED BY THE APPEL LANT ON THE UNSECURED LOAN FOR THE PURPOSE OF BUSINESS. HENCE, IT IS PRAYED THAT THE SAME MAY VERY KINDLY B E DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 13 13 ALLOWED TO THE RESPONDENT. 20. THE LD. DR RELIED ON THE ORDERS OF THE AUTHORITIES BELOW. 21. THE LD. COUNSEL FOR THE ASSESSEE CONTENDED BEFORE US THAT THE INTEREST DISALLOWANCE OF THIS COMPANY IS T HE SOLITARY GROUND OF ASSESSEES CROSS OBJECTION. THE DISALLOWA NCE IS BASED ON THE FINDINGS IN THE RESPONDENTS OWN CASE FOR AY 2005-06. EXTENSIVE DOCUMENTARY EVIDENCE WAS FILED IN THAT CA SE ALSO TO PROVE THE IDENTITY, CREDITWORTHINESS AND GENUINENES S OF TRANSACTION WITH OPTIMATES TEXTILE INDUSTRIES. HOWE VER, THE ISSUE HAS BEEN DECIDED AGAINST THE ASSESSEE IN THAT YEAR AND ALSO CONFIRMED BY THE HONBLE ITAT INDORE BENCH. T HE MATTER IS BEFORE THE HONBLE M.P. HIGH COURT WHERE A SUBSTANT IAL QUESTION OF LAW HAS BEEN ADMITTED FOR HEARING. 22. WE HAVE HEARD THE BOTH THE PARTIES. SINCE THE MATTE R IS SUB JUDICE IN THE HON'BLE MADHYA PRADESH HIGH COURT , THE CROSS OBJECTION FILED BY THE ASSESSEE IS DISMISSED. 23. IN THE RESULT, THE DEPARTMENTAL APPEAL IS PARTLY AL LOWED AND CROSS OBJECTION FILED BY THE ASSESSEE IS DISMIS SED. THIS ORDER HAS BEEN PRONOUNCED IN THE OPEN COURT ON 01 ST DY. CIT,5(1), INDORE VS . AGARWAL TRANSPORT CORPORATION PVT.LTD., INDORE. I.T.A.NO. 356/IND/2014 AND C.O.NO. 41/IND/2014 A. Y. 2009-10 14 14 DEC EMBER, 2015. SD/- (B. C. MEENA) ACCOUNTANT MEMBER SD/- ( D.T.GARASIA) JUDICIAL MEMBER DATED : 1 ST DECEMBER, 2015. CPU* 923