M/s. Shree Balaji Enterprises, Jaipur V. ASSISTANT Commissioner of Income Tax, Circle-5, Jaipur

ITA 1276/JPR/2018

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 4039 (ITAT-JAIPUR)
• Duration Of Justice: 2 month(s) 22 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 06-02-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2013-2014
• Appeal Filed On: 14-11-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: K C GUPTA
• Keywords: Rejection of books of accounts; Depreciation; Rectification of order; Tax effect
• Section: 154; 143(3)

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S,A 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. 1276/JP/2018 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2013-14 M/S SHREE BALAJI ENTERPRISES 3 KA, 22, JAWAHAR NAGAR, JAIPUR. CUKE VS. THE ACIT, CIRCLE-5 JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: ABEFS 3243 E VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI P.C. PARWAL (C.A.) JKTLO DH VKSJ LS @ REVENUE BY : SHRI K.C. GUPTA (J.CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 04/02/2019 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT: 06/02/2019 VKNS'K@ ORDER PER: VIJAY PAL RAO, J.M. THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST TH E ORDER DATED 27.08.2018 OF LD. CIT (A), JAIPUR FOR A.Y. 2013-14. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS AS UNDER:- 1. THE RECTIFICATION ORDER PASSED BY LD. CIT(A) U/ S 154/250 IS ILLEGAL & BAD IN LAW. 2. THE LD. CIT(A) HAS ERRED ON FACTS AND IN LAW IN ESTIMATING THE N.P. RATE OF 5% (AFTER DEPRECIATION & INTEREST TO P ARTNERS) ON THE GROSS RECEIPT AS AGAINST N.P. RATE OF 15% ON GROSS RECEIPT SUBJECT TO DEPRECIATION & INTEREST TO PARTNERS ASSESSED BY AO WHICH WAS REDUCED TO 10% BY CIT(A) IN ORDER DT. 23.03.2018 AG AINST WHICH ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 2 APPEAL FILED BY THE DEPARTMENT WAS DISMISSED BY HON BLE ITAT VIDE ORDER DATED 03.08.2018 SUBJECT TO OBSERVATION TAT RELIEF GRANTED BY CIT(A) WOULD NOT HAVE THE EFFECT OF REDU CING THE RETURNED INCOME. 2.1 THE LD. CIT(A) HAS ERRED ON FACTS AND IN LAW IN APPLYING N.P. RATE OF 5% ON THE GROSS RECEIPT AFTER DEPRECIATION & INTEREST TO PARTNERS BUT AT THE SAME TIME NOT DIRECTING TO EXC LUDE FDR & NSC INTEREST OF RS. 10,46,613/- WHILE RECTIFYING H IS ORDER U/S 154 2. THE GRIEVANCE OF THE ASSESSEE AGAINST THE IMPUGN ED ORDER IS THAT WHILE PASSING THE ORIGINAL ORDER DATED 23.03.2018 T HE LD. CIT(A) RESTRICTED THE TRADING ADDITION MADE BY THE AO TO 1 0% AS AGAINST THE NET PROFIT ADOPTED BY THE AO AT 15% OF TOTAL RECEIP T BEFORE DEPRECIATION AND INTEREST/ REMUNERATION TO PARTNERS WAS FURTHER RECEIVED WHILE PASSING THE ORDER U/S 154 OF THE ACT. THE SAID FIRS T ORDER OF LD. CIT(A) WAS CHALLENGED BY THE REVENUE BEFORE THIS TRIBUNAL AND THE ONLY GROUND RAISED BY THE REVENUE IS THAT THE LD. CIT(A) IS NOT JUSTIFIED IN RESTRICTING THE NET PROFIT FROM 15% TO 10% WHICH HA S RESULTED IN DETERMINATION OF INCOME LESS THAN THE RETURN INCOME . THE TRIBUNAL VIDE ORDER DATED 03.08.2018 OBSERVED THAT NET PROFIT ADO PTED BY THE LD. CIT(A) WOULD NOT AFFECT THE RETURNED INCOME OF THE ASSESSEE AND THEREFORE, THE IMPUGNED ORDER OF THE LD. CIT(A) WAS NOT FOUND TO BE ILLEGAL ON THAT GROUND THOUGH THE APPEAL OF THE REV ENUE WAS DISMISSED ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 3 DUE TO LOW TAX EFFECT IN VIEW OF THE CBDT CIRCULAR NO. 3/2018. THE LD. AR HAS FURTHER CONTENTED THAT THE LD. CIT(A) SUBSEQ UENTLY AFTER THE ORDER OF THIS TRIBUNAL HAS PASSED THE IMPUGNED ORDE R U/S 154 OF THE ACT AND REVISED THE NET PROFIT FROM 10% BEFORE THE DEPR ECIATION AND INTEREST TO PARTNERS TO 5% AFTER DEPRECIATION AND I NTEREST TO PARTNERS WHICH HAS RESULTED AN ADDITION TO THE TOTAL INCOME OF THE ASSESSEE. THUS, THE LD. CIT(A) TRAVELLED BEYOND THE JURISDICT ION U/S 154 OF THE ACT. 3. ON THE OTHER HAND, THE LD. DR HAS RELIED UPON TH E IMPUGNED ORDER AND SUBMITTED THAT THE LD. CIT(A) HAS STATED THAT THERE WAS TYPOGRAPHIC MISTAKE WHILE PASSING THE EARLIER ORDER DATED 23.03.2018 REGARDING THE NET PROFIT PERCENTAGE AND THE CORRECT NET PROFIT ESTIMATED BY THE LD. CIT(A) IS 5% AFTER DEPRECIATION AND INTE REST TO PARTNERS AS HELD IN THE IMPUGNED ORDER PASSED U/S 154 OF THE AC T. 4. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WELL AS RELEVANT MATERIAL ON RECORD. THE ASSESSING OFFICER DURING TH E ASSESSMENT PROCEEDING U/S 143(3) OF THE ACT REJECTED THE BOOKS OF ACCOUNTS OF THE ASSESSEE BY INVOKING THE PROVISIONS OF SECTION 145( 3) OF THE ACT AND CONSEQUENTLY ESTIMATED THE INCOME OF THE ASSESSEE B Y ADOPTING THE NET PROFIT AT 15% BEFORE DEPRECIATION AND INTEREST/REMU NERATION TO PARTNERS. THE ASSESSEE CHALLENGED THE SAID ORDER OF THE ASSESSING ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 4 OFFICER BEFORE THE LD. CIT(A). THE LD. CIT(A) WHILE PASSING THE ORDER DATED 23.03.2018 RESTRICTED THE NET PROFIT ADOPTED BY THE AO TO 10% BEFORE DEPRECIATION AND INTEREST/REMUNERATION TO PA RTNERS. SINCE, THERE WAS NO ADDITION TO THE TOTAL INCOME OF THE ASSESSEE AFTER THE ORDER OF THE LD. CIT(A) DATED 23.03.2018, THEREFORE, ASSESSE E DID NOT CHALLENGE THE SAID ORDER, HOWEVER, THE REVENUE FILED THE APPE AL WHICH WAS DECIDED BY THIS TRIBUNAL VIDE ORDER DATED 03.08.201 8 IN ITA NO. 734/JP/2018. THE GROUNDS RAISED BY THE REVENUE REPR ODUCED BY THE TRIBUNAL IN PARA 1 AS UNDER:- 1. WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES O F THE CASE, THE CIT(A) IS JUSTIFIED IN RESTRICTING THE N.P. FRO M 15% TO 10% WHICH HAS RESULTED IN DETERMINATION OF INCOME LESS THAN THE INCOME SHOWN BY THE ASSESSEE IN THE RETURN. THE ONLY GRIEVANCE OF THE REVENUE WAS RESTRICTED TH E N.P. FROM 15% TO 10% APART FROM THAT IT HAS REDUCED THE TOTAL INCOME LESS THAN THE RETURN INCOME OF THE ASSESSEE. THE TRIBUNAL WHILE C ONSIDERING THE APPEAL OF THE REVENUE HAS OBSERVED AND DECIDED IN P ARA 3 TO 5 VIDE ORDER DATED 03.08.2018 HAS HELD AS UNDER:- 3. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. WE MAY CLARIFY THAT THE RELIEF GRANTED BY THE LD. CIT (A) RESTRICTING THE NET PROF IT FROM 15% TO 10% WOULD NOT AFFECT THE RETURNED INCOME OF THE ASS ESSEE AND HENCE THE IMPUGNED ORDER OF THE LD. CIT (A) WOULD N OT HAVE THE ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 5 EFFECT OF REDUCING THE RETURNED INCOME. IT IS OBSER VED THAT THE DEMAND/ TAX EFFECT IN THE REVENUES APPEAL IN QUEST ION IS BELOW RS. 20.00 LACS. UNDER THE POWERS VESTED BY SECTION. 268A(1) OF THE I T ACT, CBDT HAS RECENTLY ISSUED CIRCULAR NO. 3/2018 DATED 11TH JULY, 2018 (F NO. 279/MISC. 142/2007-ITJ(PT) I NSTRUCTING THE AUTHORITIES BELOW THAT DEPARTMENTAL APPEAL SHOULD N OT BE FILED BEFORE ITAT WHERE THE DEMAND/TAX EFFECT DOES NOT EX CEED RS. 20 LACS. THE CIRCULAR IS SPECIFICALLY MENTIONED TO BE APPLICABLE FOR ALL PENDING APPEALS. 4. SUBJECT TO SOME EXCEPTIONS, IT IS FURTHER DIRECT ED BY CBDT THAT ALL THE DEPARTMENTAL APPEALS PENDING BEFORE ITAT WH ERE THE DEMAND/TAX EFFECT IS NOT EXCEEDING THAN 20 LACS SHO ULD BE EITHER WITHDRAWN OR NOT PRESSED BY THE DEPARTMENTAL REPRES ENTATIVES. 5. THE PRESENT APPEAL IS NOT COVERED BY ANY EXCEPT IONS MENTIONED IN THE SAID CBDT CIRCULAR. SINCE THE TAX DEMAND IN DISPUTE IN THIS DEPARTMENTAL APPEAL IS BELOW THE LI MIT SET OUT BY CBDT FOR THE APPEAL, THE APPEAL OF THE ASSESSEE IS NOT MAINTAINABLE IN VIEW OF CBDT CIRCULAR NO. 3 OF 2018 DATED 11.07.2018. ACCORDINGLY THE APPEAL OF THE DEPARTMEN T IS DISMISSED AS NOT PRESSED/WITHDRAWN. THEREFORE, THE GRIEVANCE OF THE REVENUE THAT THE IN COME OF THE ASSESSEE WOULD BE REDUCED LESS THAN THE RETURN OF I NCOME AS A RESULT OF THE ORDER OF THE LD. CIT(A) DATED 23.03.2018 HAS BE EN DEALT WITH BY THE TRIBUNAL WITH OBSERVED THAT THE ESTIMATION OF THE I NCOME BY ADOPTING THE N.P. AT 10% BY THE LD. CIT(A) WOULD NOT AFFECT THE RETURN OF INCOME OF THE ASSESSEE AND THEREFORE, THE SAME WOULD NOT H AVE THE EFFECT OF REDUCING THE RETURN OF INCOME. THE TRIBUNAL HAS NOT GONE INTO THE MERIT OF THE ISSUE AS THE LOW TAX EFFECT THE REVENUE WAS NOT EXCEEDING THE ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 6 LIMIT PROVIDED UNDER CBDT CIRCULAR NO. 3/2018. AFTE R THE SAID ORDER DATED 03.08.2018 THE LD. CIT(A) HAS PASSED THE IMPU GNED ORDER DATED 27.08.2018 WHEREBY REVISED THE N.P. FOR ESTIMATION OF INCOME OF THE ASSESSEE. IT IS PERTINENT TO NOTE THE QUESTION ARIS ES WHETHER THE REVISION OF N.P. PASSED U/S 154 OF THE ACT WOULD FALL IN THE CATEGORY MISTAKE APPARENT ON RECORD WHICH CAN BE RECTIFIED U/S 154 O F THE ACT OR IT WOULD AMOUNT TO REVISION/REVIEW OF THE ORDER DECISION OF THE LD. CIT(A). WHILE PASSING THE ORIGINAL ORDER DATED 23.03.2018 THE LD. CIT(A) HAS CONSIDERED THE ISSUE OF ESTIMATION OF INCOME OF THE ASSESSEE AS UNDER:- AS REGARDS THE PERCENTAGE TO BE APPLIED, THE AR SU BMITTED THAT IN THE PREVIOUS 3 YEARS WHERE SCRUTINY WAS UNDERTAK EN SMALL ROUTINE ADDITIONS HAVE BEEN MADE. THE SUBMISSION OF THE AR NEEDS TO BE REJECTED BECAUSE IN THIS YEAR, THE AO, THROUGH A DETAILED ANALYSIS HAD BROUGHT OUT DEFECTS IN THE BO OKS AND THE SAME HAVE TO BE ACCEPTED, THE FACTS OF THIS YEAR AR E DIFFERENT AND ONCE THE BOOKS ARE REJECTED AFTER PROPER ANALYSIS, THE PROFIT PERCENTAGE HAS TO BE ESTIMATED. AS PER THE CHART OF THE PREVIOUS YEAR PROFITS THE PROFIT PERCENTAGE RETURNED ON A TU RNOVER OF 9.75 CRORES WHICH IS SIMILAR IN THIS YEAR TO 11.7 CRORES IS AT 4.92%. IN THE OTHER 2 YEARS THAT IS 2011-12 AND 2012-13 THE S AME IS 0.38% AND 3.51% ON A INCREASED TURNOVER OF 21 CRORES AND 24.1 CRORES APPROXIMATELY. THE AO NOTED THAT THE APPELLANT HAS SHOWN TRADING SALES TURNOVER OF RS. 6,34,48,293/- WITH A GP OF RS. 2,65,93,567/- OR A GROSS PROFIT RATIO OF 41.9% AND ITS NET PROFIT IS 19,47,153/- OR A MERE 1.68% OF RECEIPTS OF RS. 11,7 7,11,454/- FROM BOTH TRADE SALES AND CONTRACTS. RELYING ON THE CASE OF CHOUDHARY BROTHERS ITA NO. 879/JP/2011 OF THE JURIS DICTIONAL TRIBUNAL WHEREIN 11.5% WAS CONFIRMED AND OPINING TH AT ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 7 APPELLANT WAS ALSO INTO TRADING MADE AN ESTIMATE OF NP% AT 15%. HOWEVER CONSIDERING THE PAST HISTORY OF THE CA SE AND THE DISCUSSION AS ABOVE AND THE DEFECTS IN THE BOOKS OF THE ACCOUNTS, THE NP PERCENT IS ESTIMATED AT 10% WHICH SHALL BE R EASONABLE IN VIEW OF THE DEFECTS POINTED IN THE BOOKS OF ACCOUNT S WHICH COULD NOT BE CONTROVERTED BY THE APPELLANT. THE GROUND OF APPEAL IS PARTLY ALLOWED. THUS, IT IS CLEAR THAT THE LD. CIT(A) HAS ANALYZED THE PAST HISTORY OF THE ASSESSEE AND NOTED THAT IN THE PRECEDING TWO YEARS I.E. 2011-12 AND 2012-13 THE ASSESSEE HAS DECLARED N.P. @ 0.38% AND 3.51%. FURTHER, THOUGH ON THE HIGHER TURNOVER IN THE COMPARISON IN THE YEAR UNDER CONSIDERATION. AFTER CONSIDERING OF THESE FACTS AS WELL AS THE DECISION OF THIS TRIBUNAL WHEREIN THE N.P. @ 11.5% WAS CONSIDER ED AS REASONABLE THE LD. CIT(A) HELD THAT THE N.P. IS ESTIMATED AS 1 0% IT SHALL BE REASONABLE IN VIEW OF THE BOOKS OF ACCOUNTS REJECTE D BY THE AO. THE LD. CIT(A) HAS REVISED THE N.P. WHILE PASSING THE IMPUG NED ORDER U/S 154 OF THE ACT AS UNDER:- AS REGARDS THE PERCENTAGE TO BE APPLIED, THE AR SU BMITTED THAT IN THE PREVIOUS 3 YEARS WHERE SCRUTINY WAS UNDERTAK EN SMALL ROUTINE ADDITIONS HAVE BEEN MADE. THE SUBMISSION OF THE AR NEEDS TO BE REJECTED BECAUSE IN THIS YEAR, THE AO, THROUGH A DETAILED ANALYSIS HAD BROUGHT OUT DEFECTS IN THE BO OKS AND THE SAME HAVE TO BE ACCEPTED, THE FACTS F THIS YEAR ARE DIFFERENT AND ONCE THE BOOKS ARE REJECTED AFTER PROPER ANALYSIS, THE PROFIT PERCENTAGE HAS TO BE ESTIMATED. AS PER THE CHART OF THE PREVIOUS YEAR PROFITS, THE PROFIT PERCENTAGE RETURNED ON A T URNOVER OF RS. ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 8 9.75 CRORES WHICH IS SIMILAR IN THIS YEAR TO RS. 11 .7 CRORES IS AT 4.92%. IN THE OTHER 2 YEARS, THAT IS, 2011-12 AND 2 012-13, THE SAME IS 0.38% AND 3.51% ON AN INCREASED TURNOVER OF RS. 21 CRORES AND RS. 24.1 CRORES APPROXIMATELY. THE AO NO TED THAT THE APPELLANT HAS SHOWN TRADING SALES TURNOVER OF RS. 6 ,34,48,293/- WITH A GP OF RS. 2,65,93,567/- OR A GROSS PROFIT RA TIO OF 41.9% AND ITS NET PROFIT IS 19,47,153/- OR A MERE 1.68% O F RECEIPTS OF RS. 11,77,11,454/- FROM BOTH TRADE SALES AND CONTRA CTS. RELYING ON THE CASE OF CHOUDHARY BROTHERS ITA NO. 879/JP/20 11 OF THE JURISDICTIONAL TRIBUNAL WHEREIN 11.5% WAS CONFIRMED AND OPINING THAT APPELLANT WAS ALSO INTO TRADING MADE AN ESTIMA TE OF GP% AT 15%. HOWEVER, CONSIDERING THE PAST HISTORY OF THE C ASE AND THE DISCUSSION AS ABOVE AND THE DEFECTS IN THE BOOKS OF THE ACCOUNTS, THE NP PERCENT (AFTER DEPRECIATION AND INTEREST TO PARTNERS) IS ESTIMATED AT 5% WHICH SHALL BE REASONABLE IN VIEW O F THE DEFECTS POINTED IN THE BOOKS OF ACCOUNTS WHICH COULD NOT BE CONTROVERTED BY THE APPELLANT. THE GROUND OF APPEAL IS PARTLY AL LOWED. THEREFORE, IT IS NOTHING BUT REVISION OF EARLIER DE CISION ON THE POINT OF ESTIMATION OF INCOME BY TAKING PERCENTAGE OF NET PR OFIT. THE EARLIER LD. CIT(A) HAS MODIFIED THE N.P. ADOPTED BY THE AO AT 1 5% TO 10% THOUGH THE AO HAS ACCEPTED THE SAID N.P. BEFORE THE DEPREC IATION AND INTEREST/REMUNERATION TO PARTNERS. HOWEVER, IN THE IMPUGNED ORDER THE LD. CIT(A) HAS REVISED THE N.P. FROM 10% TO 5% BUT AFTER DEPRECIATION AND INTEREST/REMUNERATION TO PARTNERS THEREFORE, IT IS CHANGE THE DECISION AND NOT RECTIFICATION OF MISTAKE ON THE PA RT OF THE LD. CIT(A). ACCORDINGLY, THE IMPUGNED ORDER PASSED BY THE LD. C IT(A) IS BEYOND THE ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 9 SCOPE OF RECTIFICATION OF MISTAKE U/S 154 OF THE AC T. EVEN OTHERWISE WHEN THE KEEPING IN VIEW THE PAST HISTORY OF THE AS SESSEE THE N.P. DECLARED BY THE ASSESSEE AT 2.47% IS IN THE LINE OF THE AVERAGE NET PROFIT OF THE PRECEDING YEARS. THE LD. CIT(A) HAS G IVEN THE DETAILS OF THE N.P. OF THE CURRENT YEAR AS WELL AS PRECEDING YEAR HAS HELD AS UNDER:- A.Y GROSS RECEIPT NET PROFIT N.P.RATE 2010-11 97516812 4797555 4.92% 2011-12 211870008 804402 0.38% 2012-13 241659668 8493483 3.51% 2013-14 117711454 2910033 2.47% THUS, THE AVERAGE OF THE PRECEDING THREE YEARS I.E. 2010-11 TO 2012-13 COMES TO 2.93% AND THEREFORE, THE N.P. DECLARED BY THE ASSESSEE IN THE YEAR UNDER CONSIDERATION AT 2.47% IS NOT SUBSTANTIA LLY IN VARIANCE FROM THE AVERAGE OF THE PRECEDING YEARS. ACCORDINGLY, TH E IMPUGNED ORDER OF THE LD. CIT(A) PASSED U/S 154 OF THE ACT IS SET ASI DE. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOW ED. ORDER PRONOUNCED IN THE OPEN COURT ON 06/02/2018 SD/- SD/- FOE FLAG ;KNO FOT; IKY JKO (VIKRAM SINGH YADAV) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 06/02/2018. * SANTOSH. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: ITA NO. 1276/JP/2018 M/S SHREE BALAJI ENTERPRISES VS. ACIT 10 1. VIHYKFKHZ@ THE M/S M/S SHREE BALAJI ENTERPRISES, JAIPUR. 2. IZR;FKHZ@ THE RESPONDENT- ACIT, CIRCLE-5, JAIPUR. 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. 1276/JP/2018} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR