SHRI YASH BHATIA, KOTA V. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

ITA 1142/JPR/2019

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 8426 (ITAT-JAIPUR)
• Duration Of Justice: 3 month(s) 16 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-01-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2011-2012
• Appeal Filed On: 23-09-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ROONIPAL
• Keywords: Salary income; Bonafide mistake
• Section: 271(1)(c); 143(3); 153A; 143(2); 139(1); 13; 147; 132; 15; 139

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S,B JAIPUR JH FOT; IKY JKO] U;KF;D LNL; ,OA JH FOE FLAG ;KNO] YS[KK LNL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM VK;DJ VIHY LA-@ ITA. NO. 1142/JP/2019 FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2011-12 SH. YASH BHATIA 49-A, NEW COLONY, GUMANPURA, KOTA. CUKE VS. THE DCIT, CENTRAL CIRCLE, KOTA. TOLFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AGGPB 8006 R VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RE SPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI P.C. PARWAL (C.A.) JKTLO DH VKSJ LS @ REVENUE BY : SMT. ROONIPAL (JCIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 06/01/2020 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT : 09/01/2020 VKNS'K@ ORDER PER: VIKRAM SINGH YADAV, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST TH E ORDER OF LD. CIT(A)-II, UDAIPUR DATED 28.06.2019 FOR THE ASSESSM ENT YEAR 2011-12 WHEREIN THE ASSESSEE HAS TAKEN THE FOLLOWING GROUND S OF APPEAL:- 1. UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, THE ORDER PASSED U/S 271(1)(C) IS ILLEGAL AND BAD IN LAW. 2. THE LD. CIT(A) HAS ERRED ON FACTS AND IN LAW IN CONFIRMING THE LEVY OF PENALTY OF RS. 14,420/- U/S 271(1)(C) OF T HE IT ACT, 1961 ON THE ALLEGED UNDISCLOSED SALARY INCOME OF RS. 70, 000/- RECEIVED FROM M/S GANPATI ROYAL RESIDENCY BY NOT ACCEPTING T HE ITA NO. 1142/JP/2019 SH. YASH BHATIA VS. DCIT 2 EXPLANATION OF ASSESSEE THAT SUCH SALARY INCOME WAS INADVERTENTLY LEFT TO BE INCLUDED AT THE TIME OF FI LING THE RETURN. 2. DURING THE COURSE OF HEARING, THE LD AR SUBMITTE D THAT THE ASSESSEE DERIVES INCOME FROM SALARY AND INCOME FROM OTHER SOURCES. HE FILED HIS RETURN OF INCOME U/S 139(1) ON 30.03.2012 AT TOTAL INCOME OF RS.5,41,460/-. A SEARCH WAS CARRIED OUT ON 03.03.20 16 AT HIS RESIDENTIAL PREMISES. IN RESPONSE TO NOTICE ISSUED U/S 153A, HE FILED THE RETURN ON 27.09.2016 DECLARING THE SAME INCOME. DURING THE CO URSE OF ASSESSMENT PROCEEDINGS WHEN ASSESSEE PREPARED STATE MENT OF AFFAIRS, IT CAME TO HIS NOTICE THAT SALARY OF RS.70,000/- FR OM M/S GANPATI ROYAL RESIDENCY (UNIT OF M/S BHATIA INFRASTRUCTURE PVT. L TD.) WHICH WAS CREDITED IN HIS ACCOUNT BUT NOT ACTUALLY RECEIVED W AS LEFT TO BE INCLUDED IN THE INCOME BY MISTAKE. ACCORDINGLY, HE FILED REV ISED COMPUTATION OF TOTAL INCOME AND OFFERED THE SAME FOR TAXATION. THE AO ADDED THE SAME TO THE TOTAL INCOME OF ASSESSEE. ON THIS ADDITION, HE INITIATED PENALTY PROCEEDINGS U/S 271(1)(C) OF IT ACT ON ACCOUNT OF C ONCEALMENT OF THE PARTICULARS OF INCOME. IN PENALTY PROCEEDINGS, THE AO HELD THAT IT IS A CASE WHERE ASSESSEE HAS SUPPRESSED HIS INCOME BY WA Y OF NOT DISCLOSING HIS CORRECT INCOME IN THE REGULAR RETURN . ACCORDINGLY BY REFERRING TO EXPLANATION 5A TO SECTION 271(1)(C), H E IMPOSED PENALTY ON SUCH ADDITION OF RS.70,000/-. 3. BEFORE LD. CIT(A), THE ASSESSEE SUBMITTED THAT S INCE NO INCRIMINATING MATERIAL WAS FOUND DURING SEARCH, ADD ITION MADE BY THE AO IS NOT SUSTAINABLE IN LAW. ONLY BECAUSE ADDITION HAS BEEN MADE TO THE INCOME WOULD NOT LEAD TO PENALTY U/S 271(1)(C). FURTHER OMISSION OF SALARY FROM INCOME DECLARED IN THE ROI FILED U/S 15 3A WAS A BONAFIDE ITA NO. 1142/JP/2019 SH. YASH BHATIA VS. DCIT 3 MISTAKE. ON SUCH BONAFIDE MISTAKE, NO PENALTY IS LE VIABLE. THE LD. CIT(A) REJECTED THE EXPLANATION OF ASSESSEE BY RELY ING ON THE DECISION OF HONBLE KERALA HIGH COURT IN CASE OF E.N. GOPAKU MAR WHERE IT WAS HELD THAT ASSESSMENT PROCEEDINGS GENERATED BY THE I SSUANCE OF NOTICE U/S 153A CAN BE CONCLUDED AGAINST THE INTEREST OF A SSESSEE INCLUDING MAKING ADDITIONS EVEN WITHOUT ANY INCRIMINATING MAT ERIAL BEING AVAILABLE AGAINST THE ASSESSEE IN THE SEARCH U/S 13 2. HE FURTHER HELD THAT M/S BHATIA INFRASTRUCTURE PVT. LTD. IS A GROUP CONCERN WHEREIN SH. PREM J. BHATIA AND SH. RAM J. BHATIA ARE DIRECTORS. ASSESSEE IS THE SON OF SH. PREM J. BHAITA. THE ASSESSEE NOT BEING AWARE OF SALARY CREDITED TO HIM BY SUCH GROUP COMPANY IS NOT A CREDIBLE EXPL ANATION. IN THE IMMEDIATELY PRECEDING YEAR, THE ASSESSEE HAS BEEN C REDITED SALARY BY ANOTHER GROUP CONCERN BHATIA AUTOMOBILES PVT. LTD. WHEREIN ALSO SH. PREM J. BHATIA AND SH. RAM J. BHATIA ARE DIRECTORS BUT THE SALARY WAS NOT DECLARED BY HIM IN THE RETURN OF INCOME FILED U /S 153A. SIMILARLY IN CASE OF OTHER GROUP COMPANY NAMELY M/S BHATIA CORPO RATION PVT. LTD. WHEREIN ALSO SH. PREM J. BHATIA AND SH. RAM J. BHAT IA ARE DIRECTORS, THE COMPANY CREDITED SALARY TO SMT. SHIVA BHATIA WHO IS THE DAUGHTER OF SH. RAM J. BHATIA BUT THE SALARY WAS NOT DECLARED B Y HER IN THE RETURN OF INCOME FILED U/S 153A. THUS, THE EXPLANATION FUR NISHED BY THE ASSESSEE AS TO WHY SALARY FROM M/S BHATIA INFRASTRU CTURE PVT. LTD. WAS NOT OFFERED TO TAX IN THE RETURN OF INCOME FILED U/ S 153A IS NOT A BONAFIDE EXPLANATION. ACCORDINGLY, SHE CONFIRMED TH E LEVY OF PENALTY ON THE SALARY INCOME OF RS. 70,000/-. 4. IN THE AFORESAID BACKGROUND, THE LD. AR SUBMITTE D THAT ONLY DISPUTE IN THE PRESENT CASE IS LEVY OF PENALTY ON T HE ALLEGED UNDISCLOSED ITA NO. 1142/JP/2019 SH. YASH BHATIA VS. DCIT 4 SALARY INCOME OF RS.70,000/- CREDITED TO THE ACCOUN T OF ASSESSEE BY M/S GANPATI ROYAL RESIDENCY (UNIT OF M/S BHATIA INFRAST RUCTURE PVT. LTD.).IT IS SUBMITTED THAT ASSESSEE FILED THE ORIGINAL RETUR N OF INCOME ON 30.03.2012. THE TIME LIMIT FOR SERVICE OF NOTICE U/ S 143(2) WAS UPTO 30.09.2012. NO NOTICE WAS ISSUED TO THE ASSESSEE BE FORE THIS DATE. THUS, THE ASSESSMENT PROCEEDINGS FOR THE YEAR UNDER CONSIDERATION WERE NOT PENDING ON THE DATE OF SEARCH. IN SEARCH, NO INCRIMINATING MATERIAL INDICATING ANY UNDISCLOSED INCOME FOR THE YEAR UNDER CONSIDERATION WAS FOUND. THE COMPLETED ASSESSMENT C AN BE INTERFERED WITH BY THE AO WHILE MAKING ASSESSMENT U/S 153A ONL Y ON THE BASIS OF THE INCRIMINATING DOCUMENTS FOUND IN SEARCH. THUS, WHEN NO INCRIMINATING DOCUMENTS FOR THE YEAR UNDER CONSIDER ATION WERE FOUND, ADDITION MADE BY THE AO IN ASSESSMENT PROCEEDINGS U /S 153A IS ILLEGAL AND BAD IN LAW. THE HONBLE ITAT, JAIPUR BENCH IN C ASE OF SHRI NAVRATTAN KOTHARI VS. ACIT ITA NO. 425/JP/2017 ORDE R DATED 13.12.2017 HELD THAT ASSESSMENT OR REASSESSMENT OF INCOME OF PERSON OTHER THAN SEARCHED PERSONS BASED ON SEIZED MATERIA L CAN BE MADE U/S 153C R.W.S. 153A AND HAS OVERRIDING EFFECT ON SECTI ON 147/ 148. IN THE PRESENT CASE, ADDITION MADE BY THE AO IS NOT ON THE BASIS OF ANY MATERIAL SEIZED DURING THE SEARCH PROCEEDINGS. HENC E, ADDITION MADE BY THE AO IN THE ASSESSMENT FRAMED U/S 153A IS INCORRE CT. THE ADDITION, IF ANY, COULD HAVE BEEN PROPERLY MADE BY INVOKING THE PROVISIONS OF SECTION 147 OF THE IT ACT. THEREFORE, WHEN ADDITION MADE BY THE AO IS ITSELF ILLEGAL & BAD IN LAW, PENALTY LEVIED ON SUCH ADDITION IS ALSO NOT SUSTAINABLE. THE LD. CIT(A) REJECTED THIS EXPLANATI ON OF ASSESSEE BY RELYING ON THE DECISION OF HONBLE KERALA HIGH COUR T IN CASE OF E.N. GOPAKUMAR. HOWEVER, IN VARIOUS OTHER CASES INCLUDIN G THE DECISION OF ITA NO. 1142/JP/2019 SH. YASH BHATIA VS. DCIT 5 SUPREME COURT, IT HAS BEEN HELD THAT INVOCATION OF SEC. 153A TO REOPEN CONCLUDED ASSESSMENTS IS NOT JUSTIFIED IN ABSENCE O F INCRIMINATING MATERIAL FOUND DURING SEARCH. FURTHER, IN ASSESSEE S OWN CASE ALSO, THE HONBLE ITAT VIDE ORDER DATED 27.09.2019 IN ITA NO .1034/JP/18 HAS HELD THAT IN ABSENCE OF ANY INCRIMINATING MATERIAL FOUND OR SEIZED DURING THE COURSE OF SEARCH, ADDITION CANNOT BE MAD E BY THE AO IN THE PROCEEDINGS U/S 153A OF THE ACT WHEN THE ASSESSMENT FOR THE YEAR UNDER CONSIDERATION WAS NOT PENDING AS ON THE DATE OF SEARCH. THUS, WHERE TWO VIEWS ARE POSSIBLE, THE VIEW FAVORING THE ASSESSEE HAS TO BE ADOPTED AS HELD BY HONBLE SUPREME COURT IN CASE OF CIT VS. M/S VEGETABLE PRODUCTS LTD. (1973) 88 ITR 192. 5. IT WAS FURTHER SUBMITTED BY THE LD AR THAT DURIN G THE COURSE OF ASSESSMENT PROCEEDINGS U/S 153A WHEN THE ASSESSEE P REPARED HIS STATEMENT OF AFFAIRS, IT CAME TO HIS NOTICE THAT SA LARY OF RS.70,000/- FROM M/S GANPATI ROYAL RESIDENCY (UNIT OF M/S BHATI A INFRASTRUCTURE PVT. LTD.) WHICH WAS CREDITED IN HIS ACCOUNT BUT NO T ACTUALLY RECEIVED WAS LEFT TO BE INCLUDED IN THE INCOME BY MISTAKE. A CCORDINGLY, HE FILED REVISED COMPUTATION OF TOTAL INCOME AND OFFERED THE SAME FOR TAXATION. THUS, THE OMISSION OF SALARY FROM INCOME DECLARED I N THE ROI FILED U/S 153A IS A BONAFIDE MISTAKE. ON SUCH BONAFIDE MISTAK E, NO PENALTY IS LEVIABLE. FOR THIS RELIANCE IS PLACED ON THE DECISI ON OF HONBLE SUPREME COURT IN CASE OF PRICE WATERHOUSE COOPERS (P.) LTD. VS. CIT (2012) 348 ITR 306. IN THIS CASE THE ASSESSEE FIRM FILED ITS R ETURN OF INCOME ALONG WITH TAX AUDIT REPORT. IN ITS TAX AUDIT REPORT IT W AS INDICATED THAT PROVISION TOWARDS PAYMENT OF GRATUITY WAS NOT ALLOW ABLE BUT IT FAILED TO ADD PROVISION FOR GRATUITY TO ITS TOTAL INCOME. IT WAS HELD THAT IT WAS A ITA NO. 1142/JP/2019 SH. YASH BHATIA VS. DCIT 6 BONA FIDE AND INADVERTENT ERROR. THE SAME CAN ONLY BE DESCRIBED AS A HUMAN ERROR WHICH WE ALL ARE PRONE TO MAKE. THE ASS ESSEE COULD NOT BE HELD GUILTY OF EITHER FURNISHING INACCURATE PARTICU LARS OR ATTEMPTING TO CONCEAL ITS INCOME. THEREFORE, IMPOSITION OF PENALT Y WAS UNJUSTIFIED. 6. IT WAS FURTHER SUBMITTED THAT THE LD. CIT(A) DID NOT ACCEPT THE EXPLANATION OF ASSESSEE BY HOLDING THAT IN IMMEDIAT ELY PRECEDING YEAR, THE ASSESSEE HAS BEEN CREDITED SALARY BY ANOTHER GR OUP CONCERN BHATIA AUTOMOBILES PVT. LTD. BUT THE SALARY WAS NOT DECLAR ED BY HIM IN THE RETURN OF INCOME FILED U/S 153A. SIMILARLY IN CASE OF OTHER GROUP COMPANY NAMELY M/S BHATIA CORPORATION PVT. LTD., TH E COMPANY CREDITED SALARY TO SMT. SHIVA BHATIA BUT THE SALARY WAS NOT DECLARED BY HER IN THE RETURN OF INCOME FILED U/S 153A. IT IS S UBMITTED THAT IN THESE CASES ALSO, SALARY WAS CREDITED IN THEIR ACCOUNTS B UT WAS NOT ACTUALLY RECEIVED BY THEM AND THEREFORE, IT WAS LEFT TO BE I NCLUDED IN THE INCOME BY MISTAKE BUT WHEN SUCH MISTAKE WAS NOTICED WHILE PREPARING THE STATEMENT OF AFFAIR, THE SAME WAS INCLUDED IN THE I NCOME. HENCE, FOR THIS REASON, IT CANNOT BE INFERRED THAT THE ASSESSE E HAS INTENTIONALLY NOT DECLARED THE SALARY INCOME IN THE RETURN OF INCOME. IN VIEW OF ABOVE, PENALTY LEVIED BY AO AND CONFIRMED BY LD. CIT(A) BE DIRECTED TO BE DELETED. 7. PER CONTRA, THE LD. DR IS HEARD WHO HAS RELIED O N THE FINDING OF THE LOWER AUTHORITIES AND SUBMITTED THAT DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER OBSER VED THAT THE ASSESSEE HAS RECEIVED SALARY INCOME OF RS 70,000 FR OM M/S GANPATI ROYAL RESIDENCY AND WHICH HAS NOT BEEN DISCLOSED BY THE ASSESSEE IN ITA NO. 1142/JP/2019 SH. YASH BHATIA VS. DCIT 7 HIS RETURN OF INCOME FILED U/S 139 AS WELL AS UNDER SECTION 153A OF THE ACT AND WHICH WAS BROUGHT TO TAX. IT WAS ACCORDING LY SUBMITTED THAT IT IS A CLEAR CASE OF CONCEALMENT OF PARTICULARS OF IN COME AND THE ASSESSING OFFICER HAS RIGHTLY LEVIED THE PENALTY U/ S 271(1)(C) READ WITH EXPLANATION 5A OF THE ACT. 8. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. THE LIMITED POINT OF DISPUTE I S WHETHER ADDITION TOWARDS SALARY INCOME MADE BY THE ASSESSING OFFICER DURING THE COURSE OF PROCEEDINGS U/S 153A R/W 143(3) CAN FORM THE BAS IS FOR LEVY OF PENALTY BY INVOKING PROVISIONS OF EXPLANATION 5A TO SECTION 271(1)(C) OF THE ACT WHICH READS AS UNDER: EXPLANATION 5A. WHERE, IN THE COURSE OF A SEARCH I NITIATED UNDER SECTION 132 ON OR AFTER THE 1ST DAY OF JUNE, 2007, THE ASSESSE E IS FOUND TO BE THE OWNER OF (I ) ANY MONEY, BULLION, JEWELLERY OR OTHER VALUABLE ART ICLE OR THING (HEREAFTER IN THIS EXPLANATION REFERRED TO AS ASSETS) AND THE ASSESSEE CLAIMS THAT SUCH ASSETS HAVE BEEN ACQUIRED BY HIM B Y UTILISING (WHOLLY OR IN PART) HIS INCOME FOR ANY PR EVIOUS YEAR; OR (II ) ANY INCOME BASED ON ANY ENTRY IN ANY BOOKS OF ACCOU NT OR OTHER DOCUMENTS OR TRANSACTIONS AND HE CLAIMS THAT SUCH E NTRY IN THE BOOKS OF ACCOUNT OR OTHER DOCUMENTS OR TRANSACTIONS R EPRESENTS HIS INCOME (WHOLLY OR IN PART) FOR ANY PREVIOUS YEA R, WHICH HAS ENDED BEFORE THE DATE OF SEARCH AND, (A ) WHERE THE RETURN OF INCOME FOR SUCH PREVIOUS YEAR H AS BEEN FURNISHED BEFORE THE SAID DATE BUT SUCH INCOME HAS NOT BEEN DECLARED THEREIN; OR (B ) THE DUE DATE 17 FOR FILING THE RETURN OF INCOME FOR SUCH PREVIOUS ITA NO. 1142/JP/2019 SH. YASH BHATIA VS. DCIT 8 YEAR HAS EXPIRED BUT THE ASSESSEE HAS NOT FILED THE RETURN, THEN, NOTWITHSTANDING THAT SUCH INCOME IS DECLARED BY HIM IN ANY RETURN OF INCOME FURNISHED ON OR AFTER THE DATE OF SEARCH, HE SHALL, FOR THE PURPOSES OF IMPOSITION OF A PENALTY UNDER CLAUS E (C) OF SUB-SECTION (1) OF THIS SECTION, BE DEEMED TO HAVE CONCEALED TH E PARTICULARS OF HIS INCOME OR FURNISHED INACCURATE PARTICULARS OF SUCH INCOME. 9. IT IS A SETTLED LEGAL PROPOSITION THAT PENAL PRO VISIONS MUST BE STRICTLY CONSTRUED AND ONLY ON SATISFACTION OF COND ITIONS SPECIFIED THEREIN, THE PENALTY CAN BE LEVIED. IN THE INSTANT CASE, THE ASSESSEE HAS NOT BEEN FOUND TO BE RECIPIENT OF SALARY INCOME DURING THE COURSE OF SEARCH. THE ASSESSEE IS AN INDIVIDUAL DERIVING S ALARY AND INTEREST INCOME AND NOT REQUIRED TO MAINTAIN BOOKS OF ACCOUN TS. THERE IS NOTHING ON RECORD THAT ANY DOCUMENTS/MATERIAL/INFOR MATION WAS FOUND DURING THE COURSE OF SEARCH WHICH REMOTELY INDICATE THAT THE ASSESSEE IS RECIPIENT OF SALARY INCOME. IT IS ONLY DURING THE COURSE OF PROCEEDINGS U/S 153A THAT THE ASSESSING OFFICER NOTICED THAT TH E ASSESSEE IS IN RECEIPT OF SALARY INCOME AND WHICH HAS NOT BEEN DIS CLOSED BY THE ASSESSEE IN HIS RETURN AND THE SAME WAS ACCORDINGLY BROUGHT TO TAX. THE DISPUTE IS NOT THAT THE SALARY INCOME WAS NOT O FFERED TO TAX BY ASSESSEE IN HIS RETURN OF INCOME WHICH IS AN ADMITT ED POSITION BUT THE QUESTION IS WHETHER SUCH SALARY INCOME HAS BEEN FOU ND DURING THE COURSE OF SEARCH AND THE ANSWER TO THAT IN NOT IN A FFIRMATIVE. IN THE PRESENT CASE, WE THEREFORE FIND THAT NONE OF THE CO NDITIONS SPECIFIED IN EXPLANATION 5A TO SECTION 271(1)(C) IS SATISFIED IN THE INSTANT CASE AND THEREFORE, LEVY OF PENALTY IS HEREBY DIRECTED TO BE DELETED. ITA NO. 1142/JP/2019 SH. YASH BHATIA VS. DCIT 9 IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 09/01/2020. SD/- SD/- FOT; IKY JKO FOE FLAG ;KNO (VIJAY PAL RAO) (VIKRAM SINGH YADAV) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 09/01/2020. *SANTOSH VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SH. YASH BHATIA, KOTA. 2. IZR;FKHZ@ THE RESPONDENT- DCIT, CENTRAL CIRCLE, KOTA. 3. VK;DJ VK;QDR@ CIT 4. VK;DJ VK;QDR@ CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR. 6. XKMZ QKBZY@ GUARD FILE { ITA NO. 1142/JP/2019} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR