THE DCIT, Ratlam V. M/S. RATLAM STRAWBOARD MILLS PVT. LTD., Ratlam

ITA 100/IND/2016

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 5326 (ITAT-INDORE)
• Duration Of Justice: 10 month(s) 5 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 15-12-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Next Hearing Date: 05-12-2016
• Assessment Year: 2011-2012
• Appeal Filed On: 09-02-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: MOHD JAVED SR DR DH DH DH DH
• Keywords: Cost of acquisition; Fair market value; Valuation report; Revised return
• Section: 143(3); 142(1)

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE .., .., % BEFORE SHRI D.T. GARASIA, JUDICIAL MEMBER AND SHRI O.P. MEENA, ACCOUNTANT MEMBER DY. CIT, RATLAM VS. RATLAM STRAWBOARD MILLS PRIVATE LIMITED, 1,MHOW NEEMUCH ROAD, RATLAM. .. ./ PAN: AABCT8665Q / APPELLANT / RESPONDENT RATLAM STRAWBOARD MILLS PRIVATE LIMITED, 1,MHOW NEEMUCH ROAD, RATLAM. .. ./ PAN: AABCT8665Q VS. DY. CIT, RATLAM IZR;K{KSIDRKZ IZR;K{KSIDRKZ IZR;K{KSIDRKZ IZR;K{KSIDRKZ / CROSS OBJECTOR / RESPONDENT FOHKKX FOHKKX FOHKKX FOHKKX / DEPARTMENT BY SHRI MOHD. JAVED, SR. DR FU/KZKFJRH DH FU/KZKFJRH DH FU/KZKFJRH DH FU/KZKFJRH DH / ASSESSEE BY SHRI MANISH DAFARIA, C.A. .. . / I.T.A. NO.100/IND/2016 / ASSESSMENT YEAR: 2011-12 IZR;K{KS IZR;K{KS IZR;K{KS IZR;K{KSI LA0 I LA0 I LA0 I LA0 A A A A C.O.NO. 12/IND/2016 (ARISING OUT OF .. ./ I.T.A. NO.100/IND/2016) / ASSESSMENT YEAR: 2011-12 I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 2 OF 13 DATE OF HEARING 05.12.2016 # DATE OF PRONOUNCEMENT 15.12.2016 / O R D E R PER O.P. MEENA, ACCOUTANT MEMEBR. APPEAL FILED BY THE REVENUE AND ASSESSEE ARE DIRECT ED AGAINST THE ORDER OF LD. COMMISSIONER OF INCOME-TAX (APPEALS),UJJAIN [HEREINAFTER REFERRED TO AS THE CI T(A)] DATED 20.11.2015 AND PERTAINS TO ASSESSMENT YEAR 2011-12 AS AGAINST APPEAL DECIDED IN ASSESSMENT ORDER PASSED U/S 143(3) OF THE ACT DATED 20.03.2014 OF DY. CIT, RAT LAM [HEREINAFTER REFERRED TO AS THE AO]. 2. GROUND NOS. 1 & 2 RELATE TO DELETION OF ADDITION OF RS. 83,13,012/- BY ESTIMATING THE FAIR MARKET VALUE OF LAND ON THE BASIS OF AVERAGE VALUE DETERMINED BY THE AVO A ND REGISTERED VALUER AS ON 01.04.1981, WHILE THE AVO HA S MADE VALUATION ON THE BASIS OF AVERAGE OF SIX PROPERTIES OF NEARBY AREAS AND ALSO INCLUDED THE PROPERTIES ON THE BASIS OF WHICH REGISTERED VALUER HAS MADE VALUATION, AS SUCH AGAIN MAKING I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 3 OF 13 AVERAGE OF RATES ADOPTED BY AVO AND REGISTERED VALU E IS NOT JUSTIFIED AND AS PER GROUND NO. 3, THE LD. CIT(A) I S NOT JUSTIFIED IN ALLOWING RELIEF TO THE ASSESSEE BY MISPLACING REL IANCE ON VARIOUS DECISIONS IN WHICH IT HAS BEEN HELD TO ADOPT PWD RATES INSTEAD OF CPWD RATES FOR VALUATION OF COST O F CONSTRUCTION, WHEREAS IN THE PRESENT CASE, THE VALUA TION HAS BEEN MADE FOR THE LAND ON WHICH NO SEPARATE RATES OF CPWD OR PWD ARE PRESCRIBED. SINCE THE ABOVE GROUNDS OF APPE AL ARE INTERCONNECTED AND REVOLVE AROUND THE SINGLE ISSUE OF ALLOWING RELIEF OF RS. 83,13,012/- BY ADOPTING AVERAGE RATE IN VALUATION, HENCE, THESE ARE BEING CONSIDERED TOGETHER. 3. BRIEFLY STATED, THE FACTS OF THE CASE ARE THAT THE ASSESSEE COMPANY HAS SHOWN INCOME FROM WEIGH BRIDGE, JOB WORK BY LATHE MACHINE, BESIDES THE ASSESSEE HAS ALSO SHOWN RENTAL INCOME FROM ITS GODOWN AND INCOME FROM OTHER SOURCES. RETURN OF INCOME WAS FILED ON 28.09.2011 SHOWING TOTA L INCOME AT RS. 7,31,640/-. SUBSEQUENTLY, THE SAID RE TURN WAS REVISED ON 28.03.2013 DECLARING TOTAL INCOME AT RS. 17,27,440/-. DURING THE YEAR UNDER CONSIDERATION , THE I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 4 OF 13 ASSESSEE COMPANY HAS SOLD ITS LAND SITUATED AT KHAS ARA NO.313 (3.70 HECTARE FROM TOTAL RAKBA 78.730 HECTAR E) OF MUNICIPAL CORPORATION NO. 39 DATED 03.01.2008, PATWA RI HALKA NO.25, REVENUE INSPECTOR ZONE NO.2, RATLAM (M P) AND HAS SHOWN LONG TERM CAPITAL GAIN LOSS OF RS. 6,45,01 2/- IN ITS ORIGINAL RETURN OF INCOME, WHICH WAS SUBSEQUENTLY REV ISED AT RS. 10,78,138/- BY FILING REVISED RETURN ON 26.03.2 013. ON EXAMINATION OF THE DETAILS OF LONG TERM CAPITAL GAI N, THE AO NOTED THAT THE ASSESSEE HAS SHOWN FAIR MARKET VALUE OF LAND SOLD AS ON 01.04.1981 @ RS. 5/- PER SQ.FT. IN THE R EVISED RETURN OF INCOME, THE LONG TERM CAPITAL GAIN WAS RE -CALCULATED BY THE ASSESSEE BY ADOPTING THE FAIR MARKET VALUE O F THE LAND SOLD AS ON 01.04.1981 @ RS. 25/-PER SQ.FT. THUS, TH ERE WAS CONSIDERABLE DIFFERENCE IN THE FAIR MARKET VALUE OF THE LAND SOLD DECLARED BY THE ASSESSEE COMPANY IN THE ORIGIN AL RETURN OF INCOME AS COMPARED TO THE FAIR MARKET VALUE SHOWN IN REVISED RETURN OF INCOME. IN VIEW OF THESE FACTS, TH E AO REFERRED THE CASE TO VALUATION OFFICER OF INCOME TA X DEPARTMENT AS PER THE PROVISIONS OF SECTION 55A OF THE I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 5 OF 13 INCOME-TAX ACT, 1961, FOR DETERMINING THE FAIR MARK ET VALUE OF THE LAND SHOWN AS ON 01.04.1981.THE VALUATION OFFICE R ( IN SHORT AVO) VIDE HIS VALUATION REPORT DATED 06.03.20 14 DETERMINED THE FAIR MARKET VALUE OF THE LAND SOLD A T RS. 56,16,600/- AS ON 01.04.1981. ON THE BASIS OF AVOS REPORT, THE AO CONSIDERED THE FAIR MARKET VALUE AT RS. 56,1 6,600/- AND CALCULATED THE INDEX COST OF ACQUISITION OF THE PROPERTY FOR FINANCIAL YEAR 2010-11 AT RS. 3,99,34,026/- (RS. 56 ,16,600 X 711/100) AND AFTER REDUCING THE SAME FROM SALE CONS IDERATION DECLARED BY THE ASSESSEE AT RS. 7,17,78,200/- WORKED OUT LONG TERM CAPITAL GAIN AT RS. 3,18,44,174/-. THEREAFTER, THE AO SUPPLIED THE COPY OF VALUATION REPORT TO THE ASSESS EE AND ASKED TO EXPLAIN AS TO WHY THE LONG TERM CAPITAL GAI N SHOULD NOT BE CONSIDERED AT RS. 3,18,44,174/- VIDE HIS NO TICE U/S 142(1) DATED 10.03.2014. THE ASSESSEE REPLIED VIDE HIS REPLY DATED 14.03.2014 WHICH HAS BEEN REPRODUCED BY THE AO IN THE BODY OF ASSESSMENT ORDER AT PAGE 4. IT WAS SUBMITTED BY THE ASSESSEE THAT THE TOTAL LAND SOLD WAS AT 397750 SQ. FT. OF WHICH FAIR MARKET PRICE WAS CONSIDERED BY THE ASSESSEE AT RS. I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 6 OF 13 99,43,750/- AND AFTER COMPUTING THE INDEX COST DURI NG THE FINANCIAL YEAR, THE TOTAL COST WAS WORKED OUT AT RS. 7,07,00,062/- AND LONG TERM CAPITAL GAIN WAS COMPUTE D AT RS. 10,78,138/-. IT WAS ALSO SUBMITTED THAT THE REGISTE RED VALUER OF THE ASSESSEE VIDE HIS REPORT DATED 1.07.2013, HA S DETERMINED THE FAIR MARKET VALUE OF THE LAND SOLD A T RS. 79,55,000/- AS ON 01.04.1981. IT WAS CONTENDED THAT THE AVO CONSIDERED SALE DEED OF RS. 6/- PER SQ.FT. FOR VERY SMALL PLOT AND LAND, WHEREAS THE ASSESSEES LAND WAS COMMERCIAL LAND USED FOR RAW MATERIAL STOCK AND THE AVO HAS ALSO CON SIDERED LOWEST PRICE SALE-DEED AS AGAINST HIGHER PRICE LAND WAS SOLD DURING THE ASSESSMENT YEAR 1981-82. HOWEVER, THIS CONTENTION WAS NOT FOUND ACCEPTABLE BY THE AO ON THE GROUND THAT THE AVO HAS DETERMINED THE AVERAGE COST OF SIX CASES OF SALE OF LAND INSTANCES AT RS. 202.40 PER SQ.MTR. AN D TREATING THE LAND OF THE ASSESSEE COMPANY AS UNDEVELOPED LAN D. THE RATE WAS FURTHER REDUCED TO 75% OF RS. 202.40 TO RS. 151.80 PER SQ.MTR. SINCE THE AVO HAS CALCULATED THE FAIR M ARKET VALUE ON THE BASIS OF SIX SALE INSTANCES PERTAINING TO TH AT PARTICULAR I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 7 OF 13 LOCALITY AND NEARBY AREAS. ACCORDINGLY, THE CLAIM O F THE ASSESSEE WAS REJECTED AND THE LONG TERM CAPITAL GAIN WAS DETERMINED AT RS. 3,18,44,174/-. 4. BEING AGGRIEVED, THE ASSESSEE HAS FILED APPEAL BEFO RE THE CIT(A). 5. THE LD. CIT(A) NOTED THAT THE AVO ADOPTED THE FAIR MARKET VALUE OF THE LAND AT RS. 151.80 PER SQ.MTR A S ON 01.04.1981, WHEREAS THE REGISTERED VALUER OF THE ASS ESSEE HAS CONSIDERED RS. 215/- PER SQ.MTR. THE AVO ADOPTED CP WD RATE, WHEREAS AS PER VARIOUS JUDICIAL PRONOUNCEMENTS , THE LD. CIT(A) HAS MADE A REMARK THAT IT WILL BE APPROPRIATE TO APPLY PWD RATE INSTEAD OF CPWD RATES WHILE VALUING PROPERT Y. THE LD. CIT(A) HAS ALSO NOTED THAT THE ASSESSEE HAS NOT MAINTAINED PROPER ACCOUNTS AND THERE IS A VAST DIFFERENCE BETWE EN FAIR MARKET VALUE ADOPTED BY THE ASSESSEE AND FAIR MARKE T VALUE ADOPTED BY THE AVO, WHICH IS FOUND TO BE EXCESSIVE, IN THE LIGHT OF DECISION OF I.T.A.T. IN THE CASE OF ITO VS . RAM AVTAR AGRAWAL, (2006) 5 ITJ 342. THE LD. CIT(A) FURTHER NO TED THAT ADOPTION OF RATE IS BASED ON SALE DEED CONSIDERED F OR PLOTS FOR I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 8 OF 13 VALUATION IS OF SIMILAR LOCATION. THE PLOT NO.1 ON THE BASIS OF WHICH THE RATE IS TAKEN IS CONVERTED FOR INDUSTRIAL PURPOSE AND PLOT NO.2 IS USED FOR PETROL PUMP. THE AVO HAS TAKE N SALE INSTANCES OF PLOTS USED FOR COMMERCIAL AND NON-AGRI CULTURE CONVERTED LAND FOR INDUSTRIAL USE. THE SIZE OF THE PLOTS ON THE BASIS OF WHICH THE AVO RELIED ARE NOT OF SAME SIZE A S OF THE ASSESSEE. THEREFORE, THE LD. CIT(A) WAS OF THE VIEW THAT THE VALUE ARRIVED AT BY THE AVO IS ON ESTIMATED BASIS AND SIMILARLY VALUATION DONE BY THE REGISTERED VALUER OF THE ASSESSEE IS ALSO ON ESTIMATED BASIS. BOTH THE PERSO NS HAVE ESTIMATED THE FAIR MARKET VALUE OF LAND ON GUESS WOR K. THEREFORE, THE LD. CIT(A) CONSIDERED IT APPROPRIATE TO TAKE THE AVERAGE OF BOTH THE VALUES, AS DETERMINED BY THE A VO AND REGISTERED VALUER, WHICH WORKED OUT TO RS. 183.40 PER SQ.MTR ( RS. 215/- + RS. 151.80 2 ). ACCORDINGLY, FAIR M ARKET VALUE AS ON 01.04.1981 WAS COMPUTED AT RS. 67,85,800/- INS TEAD OF RS. 56,16,600/- CONSIDERED BY THE AVO AND ,ACCORDI NGLY, HE COMPUTED THE INDEXED COST OF THE PROPERTY AT RS. 4,82,47,038/- AND AFTER ALLOWING DEDUCTION ON THE SA LE I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 9 OF 13 CONSIDERATION OF RS. 7,17,78,200/-, LONG TERM CAPIT AL GAIN WAS DETERMINED AT RS. 2,35,31,162/- AS AGAINST RS. 3,18 ,44,174/- COMPUTED BY THE AO RESULTING IN RELIEF OF RS. 83,13 ,012/- 6. AGGRIEVED WITH THE ORDER OF THE LD. CIT(A), THE REVE NUE HAS FILED THIS APPEAL BEFORE US AND THE ASSESSEE HA S ALSO FILED CROSS OBJECTION BEFORE US. 7. THE LD. SENIOR DEPARTMENTAL REPRESENTATIVE SUBMITT ED THAT THE AVO HAS ADOPTED THE FAIR MARKET VALUE ON T HE BASIS OF SIX SALE INSTANCES PERTAINING TO THAT LOCALITY ON T HE BASIS OF WHICH THE AVO HAS WORKED OUT 202.40 SQ.MTR. SINCE THE PRESENT LAND WAS UNDER-DEVELOPED LAND, THE AVO HAS F URTHER REDUCED IT TO 75% AT RS. 151.80 PER SQ.MTR. WHILE WO RKING OUT AVERAGE RATE, THE AVO CONSIDERED SALE INSTANCES, WHI CH WERE SHOWN AS AVERAGE COST AT RS. 70.95 PER SQ.MTR. TO RS . 334.47 PER SQ.MTR. THEREFORE, THE VALUE ADOPTED BY THE AV O IS BASED ON TECHNICAL EXPERTS ADVICE, HENCE NEEDS TO BE ACCE PTED. HOWEVER, THE LD. CIT(A) HAS CONSIDERED THE RATE OF REGISTERED VALUER OF THE ASSESSEE AND AFTER MAKING THE AVERAGE OF BOTH THE VALUATION REPORTS, ESTIMATED THE COST RATE AT R S. 183.40 I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 10 OF 13 PER SQ.MTR., WHICH IS ALSO AGAIN ON THE ESTIMATE. TH EREFORE, THE FINDINGS OF THE AO WERE BASED ON THE VALUATION REPOR T OF THE DEPARTMENT AND IT SHOULD HAVE BEEN UPHELD. IT WAS AL SO SUBMITTED THAT THE OBJECTION OF THE ASSESSEE WAS ALS O DULY CONSIDERED BY THE AVO IN ITS VALUATION REPORT AND VALUATION HAS BEEN ARRIVED AT AFTER CONSIDERING THE SAID OBJE CTION AND ALSO CONSIDERED THE SALE INSTANCES OF THE REGISTERE D VALUER OF THE ASSESSEE, WHILE DETERMINING THE FAIR MARKET VALU E OF THE PROPERTY UNDER CONSIDERATION. 8. ON THE OTHER HAND, THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE ASSESSEE HAS INITIALLY ADOPTED F AIR MARKET VALUE RATE AT RS. 268.25 PER SQ.MTR. AND CONSIDERED THE FAIR MARKET VALUE AT RS. 99,43,750/-. HOWEVER, AFTER OB TAINING A REPORT FROM THE REGISTERED VALUER, THE RATE WAS ADO PTED AT RS. 215/- PER SQ.MGTR. AND FAIR MARKET VALUE AS ON 01.0 4.1981 WAS WORKED OUT AT RS. 79,55,000/-, WHEREAS THE AO HAS COMPUTED THE RATE AT RS. 151.80 PER SQ.MTR., WHEREAS THE LD. CIT(A) HAS CONSIDERED IT TO RS. 183.40 PER SQ.MTR. IT WAS ALSO SUBMITTED THAT THE ASSESSEE HAS ALSO SUBMITTED TWO M ORE SALE I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 11 OF 13 INSTANCES, WHEREIN THE COST PER SQ.MTR. WAS AT RS. 26 9.05 PER SQ.MTR. AND RS. 245.88 PER SQ.MTR., BUT THE AVO HAS NOT CONSIDERED THE SAME FOR WORKING OUT AVERAGE RATE OF PROPERTY. IT WAS ALSO CONTENDED THAT THE AVO HAS CONSIDERED TH E LAND SOLD AS UNDEVELOPED LAND, WHEREAS THIS LAND WAS BEING USED FOR THE PURPOSE OF FACTORY OF THE ASSESSEE AS ON 01 .04.1981. ACCORDINGLY, THE 25 % REDUCTION AFTER WORKING OUT AV ERAGE RATE OF RS. 215/- PER SQ.MTR. IS NOT WARRANTED. THE LD. C IT(A) HAS PARTIALLY ATTEMPTED TO IMPROVE UPON THE ESTIMATE OF AVO BY AVERAGING IT OUT WITH VALUE TAKEN BY THE REGISTERED VALUER. HENCE, VALUATION ADOPTED BY THE LD. CIT(A) ALSO RE NDERS ITSELF INAPPROPRIATE. 9. WE HAVE HEARD THE RIVAL SUBMISSIONS AND HAVE PERUSED THE MATERIAL AVAILABLE ON RECORD. WE FIND T HAT THE REGISTERED VALUER OF THE ASSESSEE HAS CONSIDERED TH E MARKET VALUE OF THE LAND AS ON 1.4.1981 AT RS. 215/- PER S Q.MTR. ON THE BASIS OF SOME SALE INSTANCES OF THE NEARBY AREA S OF RELEVANT PERIOD, WHEREAS DEPARTMENTAL VALUATION OFFI CER HAS CONSIDERED THE MARKET VALUE OF LAND AT RS. 151.80 PER SQ.MTR. I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 12 OF 13 ON THE BASIS OF SIX SALE INSTANCES IN THE LOCALITY DURING THE PERIOD RELEVANT TO THE SALE OF THE ASSESSEE. WE ALS O NOTICED THAT THE LD. CIT(A) HAS ADOPTED AVERAGE VALUE OF TH E MARKET VALUE ADOPTED BY THE REGISTERED VALUER OF THE ASSE SSEE AND A.V.O. OF THE DEPARTMENT AT RS. 183.40 PER SQ.MTR. ( RS. 215/- + RS. 151.80 / 2 ). WE FIND FROM THE SALE INSTANCES CONSIDERED BY THE REGISTERED VALUER AS WELL AS AVO THAT THERE IS VAST DIFFERENCE IN THE SALE RATE OF THE LAND DURING THE PERIOD. THEREFORE, WE ARE OF THE CONSIDERED OPINION THAT TH E AVERAGE METHOD ADOPTED BY THE AVO OF THE ASSESSEE ARE THE BEST METHOD FOR MAKING THE ESTIMATE OF FAIR MARKET VALUE AS ON 01.04.1981. SINCE THE LD. CIT(A) HAS FURTHER DETERM INED THE MARKET VALUE AT RS. 183.40 PER SQ.MTR, ON THE BASIS OF AVERAGE RATE ADOPTED BY THE AVO AND REGISTERED VALUER OF T HE ASSESSEE, IN OUR CONSIDERED OPINION, WHERE AN ESTIMA TE IS TO BE MADE, THE AVERAGE RATE ADOPTED IS BEST POSSIBLE WAY, THEREFORE, WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF THE LD. CIT(A). ACCORDINGLY, THE FAIR MARKET VALUE WORKED OUT BY CON SIDERING AT RS. 183.40 PER SQ.MTR BY THE LD. CIT(A) APPEARS TO BE I.T.A.NO. 100/IND/2016 A.Y.2011-12 C.O.12/IND/2016 RATLAM STRAWBOARD MILLS, RATLAM PAGE 13 OF 13 REASONABLE. THEREFORE, WE ALSO CONCUR WITH THE SAME. ACCORDINGLY, THE APPEAL OF THE REVENUE AS WELL AS C ROSS OBJECTION OF THE ASSESSEE ARE, THEREFORE, TREATED A S DISMISSED. THE FINDINGS OF THE CIT(A) ARE UPHELD. 10. IN THE RESULT, THE APPEAL OF THE REVENUE AND CROSS OBJECTION FILED BY THE ASSESSEE ARE DISMISSED. THE ORDER HAS BEEN PRONOUNCED IN OPEN COUR T ON THE 15 TH DECEMBER, 2016. SD/- (..) (D.T.GARASIA) JUDICIAL MEMBER SD/- (..) (O.P.MEENA) ACCOUNTANT MEMBER * / DATED : 15 TH DECEMBER, 2016. CPU*