DEPUTY COMMISSIONER OF INCOME TAX, Jaipur V. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD., Jaipur

ITA 1011/JPR/2017

• Counselvise Citation: [2018] 126 COUNSELVISE.COM (IT) 2062 (ITAT-JAIPUR)
• Duration Of Justice: 2 month(s) 6 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-02-2018
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2005-2006
• Appeal Filed On: 21-12-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: P C PARWAL CA DHK
• Section: 43B

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR JH FOT; IKY JKO] U;KF;D LNL; ,OA JH HKKXPAN] YS[KK LNL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM & SHRI BHAGCHAND, A M VK;DJ VIHY LA-@ ITA NO. 978 TO 980/JP/2017 & 1011/JP/2017 FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2002-03 TO 2005-06 DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6, JAIPUR. CUKE VS. M/S RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD., VIDYUT BHAWAN, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AABCR 8312 A VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT JKTLO DH VKSJ LS@ REVENUE BY : SMT. RICHA KHODA (CIT) FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI P.C. PARWAL (CA) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 27/02/2018 MN?KKS'K.KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 27/02/2018 VKNS'K@ ORDER PER: BENCH ITA NO. 978 TO 980/JP/2017 FILED BY THE REVENUE EM ANATES FROM THE SEPARATE ORDERS OF THE LD. CIT(A), BIKANER DATED 30/08/2017 AND ITA NO. 1011/JP/2017 ALSO FILED BY THE REVENUE EMANATES FROM THE ORDER OF THE LD. CIT(A), BIKANER DATED 29/09/2017 FOR THE A.Y S. 2002-03 TO 2005- 06. IN ALL THESE APPEALS, THE REVENUE HAS TAKEN FOL LOWING GROUNDS OF APPEAL: ITA 978 TO 980 & 1011/JP/2017_ DCIT VS. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD. 2 GROUNDS OF ITA NO. 978/JP/2017 (I) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF TH E CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION O F RS. 16,09,72,970/- MADE BY THE AO FOR DEPOSITING THE EMPLOYEES CONTRI BUTION TO PF & ESI BEYOND THE PRESCRIBED TIME LIMIT PROVIDED IN RE SPECTIVE ACTS. (II) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF T HE CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN HOLDING THAT EMPLOYEES CONTRIBUTION TO PF & ESI ARE GOVERNED BY THE PROVISION OF SECTION 43B A ND NOT BY SECTION 36(1)(VA) R.W.S. 2(24)(X) OF THE I.T. ACT. GROUNDS OF ITA NO. 979/JP/2017 (I) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF TH E CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION O F RS. 9,82,06,710/- MADE BY THE AO FOR DEPOSITING THE EMPLOYEES CONTRI BUTION TO PF & ESI BEYOND THE PRESCRIBED TIME LIMIT PROVIDED IN RE SPECTIVE ACTS. (II) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF T HE CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN HOLDING THAT EMPLOYEES CONTRIBUTION TO PF & ESI ARE GOVERNED BY THE PROVISION OF SECTION 43B A ND NOT BY SECTION 36(1)(VA) R.W.S. 2(24)(X) OF THE I.T. ACT. GROUNDS OF ITA NO. 980/JP/2017 (I) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF TH E CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION O F RS. 10,68,39,650/- MADE BY THE AO FOR DEPOSITING THE EMPLOYEES CONTRI BUTION TO PF & ESI BEYOND THE PRESCRIBED TIME LIMIT PROVIDED IN RE SPECTIVE ACTS. (II) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF T HE CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN HOLDING THAT EMPLOYEES CONTRIBUTION TO PF & ESI ARE GOVERNED BY THE PROVISION OF SECTION 43B AND NOT BY SECTION 36(1)(VA) R.W.S. 2(24)(X) OF THE I.T. ACT. (III) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF THE CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION O F RS. 31,99,182/- MADE ON ACCOUNT OF PRIOR PERIOD EXPENSES WITHOUT AP PRECIATING THE FACT THAT THE ASSESSEE HAS FAILED TO PRODUCE BILLS AND VOUCHERS AMOUNTING TO RS. 31,99,182/- OUT OF RS. 8,74,66,348 /- AND THAT ITA 978 TO 980 & 1011/JP/2017_ DCIT VS. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD. 3 DISPUTE IS NOT WITH REGARD TO YEAR OF ADMISSIBILITY BUT NON VERIFIABLE IS NATURE OF EXPENDITURE. GROUNDS OF ITA NO. 1011/JP/2017 (I) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF TH E CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION O F RS. 11,44,36,494/- MADE BY THE AO FOR DEPOSITING THE EMPLOYEES CONTRI BUTION TO PF & ESI BEYOND THE PRESCRIBED TIME LIMIT PROVIDED IN RE SPECTIVE ACTS. (II) WHETHER ON THE FACTS IN THE CIRCUMSTANCES OF T HE CASE AND IN LAW THE ID. CIT(A) WAS JUSTIFIED IN HOLDING THAT EMPLOYEES CONTRIBUTION TO PF & ESI ARE GOVERNED BY THE PROVISION OF SECTION 43B A ND NOT BY SECTION 36(1)(VA) R.W.S. 2(24)(X) OF THE I.T. ACT. 2. GROUNDS NO. (I) AND (II) OF ALL THESE APPEALS AR E COMMON AND AGAINST DELETING THE ADDITION MADE BY THE ASSESSING OFFICER ON ACCOUNT OF DEPOSITING THE EMPLOYEES CONTRIBUTION TO PF & E SI BEYOND THE PRESCRIBED TIME LIMIT PROVIDED IN THE RESPECTIVE AC TS. IT IS OBJECTED BY THE REVENUE THAT THE LD. CIT(A) WAS NOT JUSTIFIED IN HOLDING THAT THE EMPLOYEES CONTRIBUTION TO PF AND ESI ARE GOVERNED BY THE PROVISIONS OF SECTION 43B AND NO BY SECTION 36(1)(VA) R.W.S. 2(24 )(X) OF THE INCOME TAX ACT, 1961 (IN SHORT THE ACT). THE LD. CIT(A) HAS G RANTED THE RELIEF TO THE ASSESSEE BY HOLDING AS UNDER: 2.3 I HAVE CONSIDERED THE FACTS OF THE CASE AND TH E SUBMISSIONS MADE. IT IS SEEN THAT THE ASSESSEE HAS DEPOSITED THE CONTRIBUTI ON TOWARDS CPF, GPF, EPF AND ESI BEFORE THE DUE DATE OF FILING OF T HE INCOME TAX RETURN. THE DECISION OF RAJASTHAN HIGH COURT RELIED BY THE LD. AR SUPPORTS THE CASE OF THE APPELLANT WHEREIN IT IS HELD THAT IF EM PLOYEES CONTRIBUTION TOWARDS PF, IF PAID AFTER THE DUE DATE UNDER THE RE SPECTIVE ACTS BUT ITA 978 TO 980 & 1011/JP/2017_ DCIT VS. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD. 4 BEFORE FILING OF RETURN OF INCOME U/S 139(1), CANNO T BE DISALLOWED U/S 43B OR U/S 36(1)(VA) OF THE ACT. DURING THE COURSE OF APPELLATE PROCEEDINGS, THE APPELLANT SUBMITTED THAT ESI & PF WERE DEPOSITED WITH IN THE FINANCIAL YEAR AND HENCE DEDUCTION COUL D NOT BE DENIED IN VIEW OF DECISIONS OF VARIOUS COURTS, RATIO OF WHICH HAVE HELD THAT PAYMENT OF ESI AND PF BEFORE THE DUE DATE OF FILING OF RETURN OF INCOME IS AN ALLOWABLE DEDUCTION. ON OVERALL APPRECIATION OF THE FACTS, I TEND TO AGREE WITH THE APPELLANTS CLAIM. THE HON'BLE SU PREME COURT IN CASE OF CIT VS. ALOM EXTRUSIONS LTD. REPORTED IN 319 ITR 306 HELD THAT OMISSION OF SECOND PROVISO TO SEC 43B AND THE AMEND MENT OF FIRST PROVISO BY FINANCE ACT, 2003, BRINGING ABOUT UNIFOR MITY IN PAYMENT OF TAX, DUTY, CESS AND FEE ON ONE HAND AND CONTRIBUTIO N TO EMPLOYEES WELFARE FUNDS ON THE OTHER, ARE CURATIVE IN NATURE, AND THUS, EFFECTIVE RETROSPECTIVELY W.E.F. 1-4-88 I.E. THE DATE OF INSE RTION OF FIRST PROVISO. IT WAS FURTHER HELD THAT WHERE PROVIDENT FUND AND EMPL OYEES STATE INSURANCE CONTRIBUTION WERE PAID BY THE ASSESSEE BE FORE FILING OF THE RETURN AND PROOF OF PAYMENT WAS SUBMITTED BEFORE TH E ASSESSING OFFICER, THE AMOUNTS WERE DEDUCTIBLE AS DEDUCTION. THE HON'BLE DELHI HIGH COURT IN CASE OF CIT VS. AI MIL LTD & ORS. REPORTED IN 321 ITR 508 HELD AS UNDER: AS SOON AS EMPLOYEES CONTRIBUTION TOWARDS PF OR ES I IS RECEIVED BY THE ASSESSEE BY WAY OF DEDUCTION OR OTHERWISE FROM THE SALARY/ WAGES OF THE EMPLOYEES, IT WILL BE TREATED AS INCOME AT THE HA NDS OF THE ASSESSEE. IT CLEARLY FOLLOWS THERE FROM THAT IF THE ASSESSEE DOE S NOT DEPOSIT THIS CONTRIBUTION WITH PF/ESI AUTHORITIES, IT WILL BE TA X AS INCOME AT THE HANDS OF THE ASSESSEE. HOWEVER, ON MAKING DEPOSIT WITH TH E CONCERNED AUTHORITIES, THE ASSESSEE BECOMES ENTITLED TO DEDUC TION UNDER THE PROVISIONS OF S. 36(1)(VA). SEC. 43B(B), HOWEVER, S TIPULATES THAT SUCH DEDUCTION WOULD BE PERMISSIBLE ONLY ON ACTUAL PAYME NTS. THIS IS THE SCHEME OF THE ACT FOR MAKING AN ASSESSEE ENTITLED T O GET DEDUCTION FROM INCOME INSOFAR AS EMPLOYEES CONTRIBUTION IS CONCER NED. DELETION OF THE SECOND PROVISO HAS BEEN TREATED AS RETROSPECTIVE IN NATURE AND WOULD NOT APPLY AT ALL. THE CASE IS TO BE GOVERNED WITH THE A PPLICATION OF THE FIRST PROVISO. IF THE EMPLOYEES' CONTRIBUTION IS NOT DEPO SITED BY THE DUE DATE ITA 978 TO 980 & 1011/JP/2017_ DCIT VS. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD. 5 PRESCRIBED UNDER THE RELEVANT ACTS AND IS DEPOSITED LATE, THE EMPLOYER NOT ONLY PAYS INTEREST ON DELAYED PAYMENT BUT CAN INCUR PENALTIES ALSO, FOR WHICH SPECIFIC PROVISION ARE MADE IN THE PROVIDENT FUND ACT AS WELL AS THE ESI ACT. THEREFORE, THE ACTS PERMIT THE EMPLOYER TO MAKE THE DEPOSIT WITH SOME DELAYS, SUBJECT TO THE AFORESAID CONSEQUENCES. INSOFAR AS THE I T ACT IS CONCERNED, THE ASSESSEE CAN GET THE BENEFIT IF T HE ACTUAL PAYMENT IS MADE BEFORE THE RETURN IS FILED. - CIT VS. VINAY CE MENT LTD. (2007) 213 CTR (SC) 268, CIT VS. DHARMENDRA SHARMA (2007) 213 CTR (DEL) 609 : (2008) 297 ITR 320 (DEL) AND CIT VS. P. M. ELECTRONICS LTD . (2008) 220 CTR (DEL) 635: (2008) 15 DTR (DEL) 258 FOLLOWED.' APART FROM THE ABOVE DECISIONS, THE FOLLOWING DECIS IONS ARE ALSO APPLICABLE ON THE ISSUE AT HAND:- I. DY CIT VS. ORBIT RESORTS (P) LTD (48 SOT 23 (UR O) II. ACIT VS. RANABAXY LABORATORIES LTD. (2011) 7 I TR (TRIB) 161 (DLH) III. ACIT VS. M/S. ANIL SPECIAL STEEL INDUSTRIES LT D. (DECISION OF JAIPUR BENCH IN ITA NO. 1100/JP/2011) FROM THE ABOVE DECISIONS, IT IS CLEAR THAT PAYMENT OR CONTRIBUTION MADE TO THE PROVIDENT FUND AUTHORITY ANY TIME BEFOR E FILING OF THE RETURN FOR THE YEAR IN WHICH THE LIABILITY TO PAY A CCRUED IS AN ALLOWABLE EXPENDITURE. LIKEWISE, IN THE PRESENT CASE, THE EMP LOYEES CONTRIBUTION WAS DEPOSITED BY THE APPELLANT BEFORE DUE DATE FOR FILING OF RETURN OF INCOME, THEREFORE, IN VIEW OF THE DECISION OF THE H ON'BLE SUPREME. COURT IN THE CASE OF CIT VS. ALOM EXTRUSIONS LTD (S UPRA) AND DECISION OF THE HONBLE DELHI HIGH COURT IN THE CASE OF CIT VS. AIMIL LTD & ORS (SUPRA), THE PAYMENTS MADE BEFORE DUE DATE FOR FILI NG OF RETURN OF INCOME ARE ALLOWABLE. THE AO IS DIRECTED TO VERIFY THE DATES OF PAYMENT OF EMPLOYEES CONTRIBUTION TOWARDS PF AND E SI AND DELETE THE ADDITION MADE ON THIS ACCOUNT IF THE PAYMENTS HAVE BEEN MADE BEFORE THE DUE DATE OF FILING OF RETURN OF INCOME BY THE A PPELLANT. CONSIDERING ITA 978 TO 980 & 1011/JP/2017_ DCIT VS. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD. 6 THE FACTUAL AND LEGAL POSITION AS DISCUSSED ABOVE, THE AO IS DIRECTED TO VERIFY AND ALLOW AS PER LAW. THIS GROUND OF APPEAL IS ALLOWED. SIMILAR IDENTICAL FINDINGS HAS ALSO BEEN GIVEN BY T HE LD. CIT(A) IN THE OTHER APPEALS. 3. THE BENCH HAVE HEARD BOTH THE SIDES ON THIS ISSUE . SINCE THIS ISSUE IS COVERED BY THE DECISION OF THE HONBLE JUR ISDICTIONAL HIGH COURT ON WHICH THE LD. CIT(A) HAS RELIED TO GRANT RELIEF TO THE ASSESSEE, THEREFORE, WE SUSTAIN THE ORDER OF THE LD. CIT(A) ON THIS ISSUE AND DISMISSED THE GROUNDS NO. (I) AND (II) OF ALL THESE APPEALS. 4. IN THE GROUND NO. (III) OF ITA NO. 980/JP/2017, THE ISSUE INVOLVED IS DELETING THE ADDITION OF RS. 31,99,182/- MADE ON ACCOUNT OF PRIOR PERIOD EXPENSES. THE LD. CIT(A) HAS GRANTED RELIEF TO THE ASSESSEE BY HOLDING AS UNDER: 5.2. I HAVE CONSIDERED THE FACTS OF THE CASE AND T HE SUBMISSION MADE. THE FACTS THAT EMERGE THEREFROM ARE THAT THE ASSESSEE C OMPANY HAS ITS UNITS SPREAD AT VARIOUS PLACES IN THE STATE OF RAJA STHAN AND LOOKING TO THE VOLUME OF THE TRANSACTIONS AND THE ACTIVITY INVOLVED, SOME EXPENSES REMAIN UNADJUSTED FOR WANT OF NECESSARY AP PROVAL. THE EXPENSES HAVE BEEN INCURRED AND THEIR GENUINENESS H AS NOT BEEN DOUBTED BY THE AO, CONSIDERING WHICH SUCH EXPENDITU RE DESERVE TO BE ALLOWED EVEN IF PERTAINING TO THE PRIOR PERIOD AS N ECESSARY APPROVAL FOR THE SAME CAME DURING THE YEAR UNDER CONSIDERATI ON AND WITHOUT APPROVAL IT WAS NOT POSSIBLE FOR THE APPELLANT TO M AKE THE PAYMENT. ITA 978 TO 980 & 1011/JP/2017_ DCIT VS. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD. 7 IT IS SEEN THAT THE HONBLE ITAT IN THE VARIOUS GOV ERNMENT CORPORATION CASES HAS BEEN CONSISTENTLY HOLDING THA T PRIOR PERIOD EXPENSE IS AN ALLOWABLE EXPENSES AS IN THESE ORGANI ZATION THE EXPENSES ARE BOOKED ONLY IN THE YEAR IN WHICH APPRO VAL IS OBTAINED. IN THE CASE OF ACIT, CIRCLE-6 VS. M/S RAJASTHAN STA TE SEEDS CORPORATION, JAIPUR IN ITA NO. 307/JP/2009, THE HON BLE ITAT WHILE ADJUDICATING THIS ISSUE HAS OBSERVED AND DECIDED TH E MATTER AS UNDER:- FROM THE DETAILS WE NOTE THAT THE APPROVAL FOR PAY MENT OF THESE EXPENDITURE WERE GIVEN DURING THE YEAR AND THEREFOR E THE LIABILITY CRYSTALLIZED DURING THE YEAR. IN VIEW OF THESE FACT S AND THE CONSISTENT VIEW OF THIS BENCH THAT THE LIABILITY CRYSTALLIZED ON APPROVAL OF PAYMENT, WE FIND NO INFIRMITY OF LD. CITA(A) DELETI NG THE DISALLOWANCE.'' THE SIMILAR DECISION HAS BEEN GIVEN IN SUBSEQUENT YEARS ALSO. CONSIDERING THE ENTIRE FACTS AND CIRCUMSTANCES OF THE CASE AND THE CASE LAWS REFERRED BY THE A/R FOR THE APPELLANT, TH E DISALLOWANCE MADE BY THE AO IS HELD TO BE UNJUSTIFIED AND THE SA ME IS DELETED. THE APPELLANT SUCCEEDS ON THIS GROUND. 5. THE LD. CIT DR HAS SUBMITTED THAT THE LD. CIT(A) HA S ALLOWED THE GROUND OF ASSESSEE WITHOUT APPRECIATING THE FACT THA T THE ASSESSEE HAS NOT PRODUCED ANY BILLS AND VOUCHERS FOR AMOUNTING T O RS. 31,99,182/-. ON THE OTHER HAND, THE LD AR HAS VEHEMENTLY SUPPORT ED THE ORDER OF THE LD. CIT(A). 6. AFTER CONSIDERING THE PLEADINGS OF BOTH THE SIDE S ON THIS ISSUE, WE FIND THAT THE LD. CIT(A) HAS GRANTED RELIEF TO THE ASSESSEE FOR THE REASON ITA 978 TO 980 & 1011/JP/2017_ DCIT VS. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD. 8 THAT SOME OF THE EXPENSES REMAINED UNADJUSTED FOR WA NT OF NECESSARY APPROVAL. THE ASSESSEE HAD NOT SUBMITTED ANY SUCH DE TAILS. IF SUCH DETAILS ARE SUBMITTED TO LD. CIT(A) THEN A.O. HAD NO T BEEN PROVIDED ANY OPPORTUNITY. HOWEVER, BEFORE THE BENCH, NO EVIDENCE IN SUPPORT OF THIS WAS AVAILABLE, THEREFORE, CONSIDERING THESE FACTS OF ISSUE AND IN THE INTEREST OF JUSTICE AND EQUITY, WE RESTORE THIS ISSU E TO THE FILE OF THE ASSESSING OFFICER TO BE DECIDED DE NOVO. THE ASSESSE E IS DIRECTED TO PRODUCE ALL NECESSARY DOCUMENTS/EVIDENCES BEFORE TH E ASSESSING OFFICER TO DECIDE THE ISSUE ON MERIT. 7. IN THE RESULT, ITA NOS. 978/JP/2017, 979/JP/2017 & 1011/JP/2017 STAND DISMISSED AND ITA NO. 980/JP.2017 IS PARTLY A LLOWED FOR STATISTICAL PURPOSES ONLY. ORDER PRONOUNCED IN THE OPEN COURT ON 27/02/2018. SD/- SD/- FOT; IKY JKO FOT; IKY JKO FOT; IKY JKO FOT; IKY JKO HKKXPAN HKKXPAN HKKXPAN HKKXPAN (VIJAY PAL RAO) (BHAGCHAND) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 27 TH FEBRUARY, 2018 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- THE DCIT, CIRCLE-6, JAIPUR. 2. IZR;FKHZ @ THE RESPONDENT- M/S RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD., JAIPUR. 3. VK;DJ VK;QDR @ CIT ITA 978 TO 980 & 1011/JP/2017_ DCIT VS. RAJASTHAN RAJYA VIDYUT PRASARAN NIGAM LTD. 9 4. VK;DJ VK;QDRVIHY @ THE CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ @ DR, ITAT, JAIPUR 6. XKMZ QKBZY @ GUARD FILE (ITA NO. 978 TO 980 & 1011/JP/2017) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR