SMT. PRABHATI DEVI MEENA , JAIPUR V. INCOME TAX OFFICER, WARD-7-4, JAIPUR

ITA 1283/JPR/2018

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 4363 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 3 month(s) 11 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-02-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2009-2010
• Appeal Filed On: 15-11-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: CHANCHAL MEENA J DHK
• Assessee Lawyers: R N SHARMA
• Keywords: Capital asset; Question of law; Reason to believe; Reassessment proceedings
• Section: 48; 147; 148

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCH 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. 1283/JP/2018 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2009-10 SMT. PRABHATI DEVI MEENA W/O LATE SHRI RAM DHAN MEENA VILLAGE & POST: HARWAR, TEHSIL: AMER DISTT. JAIPUR (RAJ) CUKE VS. THE ITO WARD- 7(4) JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: CMHPP 1163 J VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI R.N. SHARMA, ADVOCATE JKTLO DH VKSJ LS@ REVENUE BY : MS. CHANCHAL MEENA, JCIT-DR LQUOKBZ DH RKJH[K@ DATE OF HEARING : 25/02/2020 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 26 /02/2020 VKNS'K@ ORDER PER VIJAY PAL RAO, JM THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST T HE ORDER OF LD. CIT(A)-3, JAIPUR DATED 11-09-2018 FOR THE ASSESSM ENT YEAR 2009-10. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS. 1.1 THE IMPUGNED ORDER U/S 143(3)/147 DATED 10-03 -2015 IS BAD IN LAW AND ON FACTS OF THE CASE FOR WANT OF JURISDICTI ON, BARED BY LIMITATION AND VARIOUS OTHER REASONS AND HENCE THE SAME MAY KINDLY BE QUASHED. ITA NO.1283/JP/2018 SMT. PRABHATI DEVI MEENA VS ITO , WARD- 7(4) , JAIPUR 2 1.2 THE ACTION TAKEN U/S 147 IS BAD IN LAW AND ON F ACTS OF THE CASE FOR WANT OF JURISDICTION AND VARIOUS OTHER REASONS AND HENCE THE SAME MAY KINDLY BE QUASHED. 1.3 THE AO HAS ERRED IN PASSING THE ASSESSMENT ORDE R WITHOUT PROVIDING ADEQUATE AND REASONABLE OPPORTUNITY OF BE ING HEARD AND WITHOUT CONFRONTING THE MATERIAL GATHERED IN THE GR OSS BREACH OF LAW. HENCE, THE ASSESSMENT ORDER SO MADE AND CONSEQUENT ADDITIONS SO MADE MAY KINDLY BE QUASHED AND DELETED. 2. RS.7,00,000/-: THE AO HAS GROSSLY ERRED IN LAW A S WELL AS ON THE FACTS OF THE CASE IN MAKING THE ADDITION OF RS. 7,00,000/- ON ACCOUNT OF CASH DEPOSITED IN HER BANK AS A INCOME F ROM OTHER SOURCES WHILE AMOUNT DEPOSITED WAS NOT AN INCOME FROM OTHER SOURCES INCOME AS PER IT ACT. THUS THE AO HAS ERRED IN TAXING THE INCOME FROM OTHER SOURCES. HENCE, THE ADDITION SO MADE BY THE AO WITH OUT CONSIDERING THE TRUE FACTS AND LEGAL POSITION IS TOTALLY CONTRA RY TO THE PROVISIONS OF LAW AND FACTS. HENCE, THE SAME MAY KINDLY BE DELETE D IN FULL. 3. THE AO ERRED IN LAW AS WELL AS ON THE FACTS OF T HE CASE IN CHARGING INTEREST U/S 234B, 234C AND 234D AS CONSEQ UENTIAL IN NATURE. THE APPELLANT TOTALLY DENIES LIABILITY OF CHARGING OF ANY SUCH INTEREST. HENCE, THE INTEREST SO CHARGED, BEING CONTRARY TO T HE PROVISIONS OF LAW AND FACTS, MAY KINDLY BE DELETED IN FULL. 2.1 THE ONLY ISSUE ARISES IN THIS APPEAL BY THE ASS ESSEE IS WHETHER THE AO HAD JURISDICTION TO MAKE THE ADDITION OF RS. 7.0 0 LACS ON ACCOUNT OF UNEXPLAINED CASH DEPOSIT IN THE BANK ACCOUNT WHEN N O ADDITION WAS MADE BY THE AO IN THE REASSESSMENT PROCEEDINGS ON THE IS SUE FOR WHICH ASSESSMENT WAS REOPENED. 2.2 WE HAVE HEARD THE LD.AR AS WELL AS THE LD. DR AND CONSIDERED THE RELEVANT MATERIALS AVAILABLE ON RECORD. THE ASSESSE E IS AN AGRICULTURIST AND SHOWN THE AGRICULTURE INCOME DURING THE YEAR UNDER CONSIDERATION. ON THE ITA NO.1283/JP/2018 SMT. PRABHATI DEVI MEENA VS ITO , WARD- 7(4) , JAIPUR 3 BASIS OF THE INFORMATION REGARDING SALE OF LAND, TH E AO REOPENED THE ASSESSMENT BY RECORDING THE REASONS AS UNDER:- NAME OF THE ASSESSEE : SMT. PRABHATI W/O LATE SHRI RAMDHAN VILLAGE:HARVAR,TEHSIL:AMER, JAIPUR ASSESSMENT YEAR : 2009-10 STATUS : INDIVIDUAL REASONS TO BELIEF FOR REOPENING U/S 147OF THE I.T . ACT, 1961 AS PER INFORMATION RECEIVED FROM DIRECTOR OF INCOM E TAX (INV), JAIPUR VIDE LETTER NO.DIT(INV.)/ ITO(CRU)/JAIPUR/2012-1/32 31 DATED 22-03-2013, A COMMON LAND OF KAJOD, PRABAHATI, RAMDHAN, HARI NARA YAN, SITUATED AT VILLAGE-HARVAR,TEHSIL-AMER, JAIPUR SOLD ON02-08-200 8 THROUGH REGISTERED DOCUMENTS WITH SUB-REGISTRAR, AMER AT RS. 1,11,000/ -. OUT OF THIS THE ASSESSEE HAS 1/3 RD SHARE I.E. 37,000/-. ANOTHER LAND LOCATED AT VILLA GE-HARVER, TEHSIL-AMER ALSO SOLD BY THE ASSESSEE ON 02-08-200 8 AT SALE CONSIDERATION RS. 23,72,000/- AND 23,72,000/- AND GOT REGISTERED WITH SUB REGISTRAR AMER ON 02-08-2008. THUS THE ASSESSEE HAS RECEIVED TOTAL S ALE CONSIDERATION RS. 47,81,000/-( 37,000 +23,72,000+23,72,000). AS PER L OCATION, THE LAND SITUATED WITHIN THE MUNICIPAL LIMITS OF JAIPUR NAGAR NIGAM A ND ASCERTAINED AS CAPITAL ASSET. THUS THE SALE CONSIDERATION IN THE MEANING O F SEC 48 WILL BE TAKEN AT RS. 47,81,000/-. AS PER RECORD OF THIS OFFICE, NO RETURN HAS BEEN FI LED BY THE ASSESSEE FOR THE A.Y. 2009-10. I HAVEN THEREFORE, REASON TO BELIEVE THAT AS THE A SSESSEE HAS APPARENTLY NOT DISCLOSED THE INCOME EXTENT TO RS. 47,81,000/- FOR THE A.Y. 2009-10 WHICH IS ESCAPED ASSESSMENT OF INCOME IN THE MEANING OF U /S 147OF THE INCOME TAX ACT, 1961 FOR THE A.Y. 2009-10. DATED 08-11-2013 SD/- (P.K..KALYANIA) INCOME TAX OFFICER WARD- 7(3), JAIPUR THUS IT IS CLEAR THAT THAT THE AO HAS REOPENED THE ASSESSMENT TO ASSESS THE PROPOSED INCOME ARISING FROM SALE OF LAND. DURING T HE ASSESSMENT ITA NO.1283/JP/2018 SMT. PRABHATI DEVI MEENA VS ITO , WARD- 7(4) , JAIPUR 4 PROCEEDING, THE AO CONDUCTED ENQUIRY AND AFTER ASCE RTAINING THE FACTS THAT THE LANDS IN QUESTION ARE SITUATED BEYOND 8 KM FROM JAIPUR MUNICIPAL LIMIT AND NO ADDITION OR ASSESSMENT WAS M ADE ON ACCOUNT OF SALE OF LAND. TO THIS EFFECT, THE AO HAS GIVEN HIS FINDINGS AT PAGE 2 OF HIS ORDER AS UNDER:- RGLHYNKJ] RGLHY&VKESJ US VIUS I= DZEKAD 321 FNUKAD 06-02- 2015 DS }KJK FU/KKZFJRH }KJK FODZ; DH XBZ D`F'K HKW FE FTUDS [KLJS U- 811]812]814]815]853]854] 855] 856] 858] 860] 861] 8 62] 882 VKSJ 883 DKS RGLHYNKJ] VKESJ }KJK IZEKF.KR DJRS GQ, FJIKVZ ISK DH FD MIJKSDR [KLJS U- UXJ FUXE T;IQJ DH LHEK LS 8 FDYKSEHVJ DS CKGJ FL FKR GSA BL FJIKSVZ DS VK/KKJ IJ FU/KKZFJRH }KJK FODZ; DH XBZ D `F'K HKWFE;KSA IJ IWWTHXR YKHK VFTZR UGHA GKSRK GSA THEREAFTER, THE AO HAS COME TO CONCLUSION THAT NO I NCOME ON ACCOUNT OF SALE OF LAND HAS ESCAPED ASSESSMENT. THE AO THEN TA KE UP THE ISSUE OF DEPOSIT OF RS. 7.00 LACS IN THE BANK ACCOUNT OF THE ASSESSEE ON 4-08-2008 AND MADE THE ADDITION OF THE SAID AMOUNT OF RS. 7.0 0 LACS. THE LD.AR OF THE ASSESSEE HAS RELIED ON VARIOUS JUDGMENTS ON THI S ISSUE INCLUDING THE JUDGMENT OF HON'BLE BOMBAY HIGH COURT IN THE CASE O F CIT VS JET AIRWAYS (I) LTD 331, ITR 236 AS WELL AS THE JUDGEME NT OF HON'BLE DELHI HIGH COURT IN THE CASE OF RANBAXY LABORATORIES LTD. VS CIT 351 ITR 23. ITA NO.1283/JP/2018 SMT. PRABHATI DEVI MEENA VS ITO , WARD- 7(4) , JAIPUR 5 ONCE THE AO IN THE REASSESSMENT PROCEEDINGS WAS SAT ISFIED THAT NO INCOME HAS ESCAPED ASSESSMENT ON ACCOUNT OF SALE OF LAND THEN THE AO CANNOT ASSUME JURISDICTION TO MAKE OTHER ADDITION B Y INVOKING THE EXPLANATION 3 TO SECTION 147 OF THE ACT AS HELD BY HON'BLE BOMBAY HIGH COURT IN THE CASE OF CIT VS JET AIRWAYS (I) LTD (SU PRA) IN PARA 15 AND 21 TO 23 AS UNDER:- 15. THE SHORTER OXFORD DICTIONARY DEFINES THE EXPRESSI ON 'ALSO' TO MEAN 'FURTHER, IN ADDITION, BESIDES, TOO'. THE WORD HAS BEEN TREATED AS BEING RELATIVE AND CONJUNCTIVE. EVIDENTLY, THEREFORE, WHA T PARLIAMENT INTENDS BY USE OF THE WORDS 'AND ALSO' IS THAT THE AO, UPON THE FO RMATION OF A REASON TO BELIEVE UNDER S. 147 AND THE ISSUANCE OF A NOTICE U NDER S. 148(2) MUST ASSESS OR REASSESS : (I) 'SUCH INCOME'; AND ALSO (II) ANY OTH ER INCOME CHARGEABLE TO TAX WHICH HAS ESCAPED ASSESSMENT AND WHICH COMES TO HIS NOTICE SUBSEQUENTLY IN THE COURSE OF THE PROCEEDINGS UNDER THE SECTION. TH E WORDS 'SUCH INCOME' REFER TO THE INCOME CHARGEABLE TO TAX WHICH HAS ESCAPED A SSESSMENT AND IN RESPECT OF WHICH THE AO HAS FORMED A REASON TO BELIEVE THAT IT HAS ESCAPED ASSESSMENT. HENCE, THE LANGUAGE WHICH HAS BEEN USED BY PARLIAME NT IS INDICATIVE OF THE POSITION THAT THE ASSESSMENT OR REASSESSMENT MUST B E IN RESPECT OF THE INCOME IN RESPECT OF WHICH HE HAS FORMED A REASON TO BELIE VE THAT IT HAS ESCAPED ASSESSMENT AND ALSO IN RESPECT OF ANY OTHER INCOME WHICH COMES TO HIS NOTICE SUBSEQUENTLY DURING THE COURSE OF THE PROCEEDINGS A S HAVING ESCAPED ASSESSMENT. IF THE INCOME, THE ESCAPEMENT OF WHICH WAS THE BASIS OF THE FORMATION OF THE REASON TO BELIEVE IS NOT ASSESSED OR REASSESSED, IT WOULD NOT BE OPEN TO THE AO TO INDEPENDENTLY ASSESS ONLY THAT IN COME WHICH COMES TO' HIS NOTICE SUBSEQUENTLY IN THE COURSE OF THE PROCEEDING S UNDER THE SECTION AS HAVING ESCAPED ASSESSMENT. IF UPON THE ISSUANCE OF A NOTICE UNDER S. 148(2), THE AO ACCEPTS THE OBJECTIONS OF THE ASSESSEE AND D OES NOT ASSESS OR REASSESS THE INCOME WHICH WAS THE BASIS OF THE NOTICE, IT WO ULD NOT BE OPEN TO HIM TO ASSESS INCOME UNDER SOME OTHER ISSUE INDEPENDENTLY. PARLIAMENT WHEN IT ENACTED THE PROVISIONS OF S. 147 W.E.F. 1ST APRIL, 1989 CLEARLY STIPULATED THAT THE AO HAS TO ASSESS OR REASSESS THE INCOME WHICH H E HAD REASON TO BELIEVE HAD ESCAPED ASSESSMENT AND ALSO ANY OTHER INCOME CH ARGEABLE TO TAX WHICH CAME TO HIS NOTICE DURING THE PROCEEDINGS. IN THE A BSENCE OF THE ASSESSMENT OR REASSESSMENT OF THE FORMER, HE CANNOT INDEPENDENTLY ASSESS THE LATTER. ITA NO.1283/JP/2018 SMT. PRABHATI DEVI MEENA VS ITO , WARD- 7(4) , JAIPUR 6 21. EXPLANATION 3 LIFTS THE EMBARGO, WHICH WAS INSERTE D BY JUDICIAL INTERPRETATION, ON THE MAKING OF AN ASSESSMENT OR R EASSESSMENT ON GROUNDS OTHER THAN THOSE ON THE BASIS OF WHICH A NOTICE WAS ISSUED UNDER S. 148 SETTING OUT THE REASONS FOR THE BELIEF THAT INCOME HAD ESCA PED ASSESSMENT. THOSE JUDICIAL DECISIONS HAD HELD THAT WHEN THE ASSESSMEN T WAS SOUGHT TO BE REOPENED ON THE GROUND THAT INCOME HAD ESCAPED ASSE SSMENT ON A CERTAIN ISSUE, THE AO COULD NOT MAKE AN ASSESSMENT OR REASSESSMENT ON ANOTHER ISSUE WHICH CAME TO HIS NOTICE DURING THE PROCEEDINGS. THIS INT ERPRETATION WILL NO LONGER HOLD THE FIELD AFTER THE INSERTION OF EXPLN. 3 BY T HE FINANCE ACT (NO. 2) OF 2009. HOWEVER, EXPLN. 3 DOES NOT AND CANNOT OVERRID E THE NECESSITY OF FULFILLING THE CONDITIONS SET OUT IN THE SUBSTANTIV E PART OF S. 147. AN EXPLANATION TO A STATUTORY PROVISION IS INTENDED TO EXPLAIN ITS CONTENTS AND CANNOT BE CONSTRUED TO OVERRIDE IT OR RENDER THE SU BSTANCE AND CORE NUGATORY. SEC. 147 HAS THIS EFFECT THAT THE AO HAS TO ASSESS OR REASSESS THE INCOME ('SUCH INCOME') WHICH ESCAPED ASSESSMENT AND WHICH WAS THE BASIS OF THE FORMATION OF BELIEF AND IF HE DOES SO, HE CAN ALSO ASSESS OR REASSESS ANY OTHER INCOME WHICH HAS ESCAPED ASSESSMENT AND WHICH, COMES TO HI S NOTICE DURING THE COURSE OF THE PROCEEDINGS. HOWEVER, IF AFTER ISSUIN G A NOTICE UNDER S. 148, HE ACCEPTED THE CONTENTION OF THE ASSESSEE AND HOLDS T HAT THE INCOME WHICH HE HAS INITIALLY FORMED A REASON TO BELIEVE HAD ESCAPED AS SESSMENT, HAS AS A MATTER OF FACT NOT ESCAPED ASSESSMENT, IT IS NOT OPEN TO HIM INDEPENDENTLY TO ASSESS SOME OTHER INCOME. IF HE INTENDS TO DO SO, A FRESH NOTICE UNDER S. 148 WOULD BE NECESSARY, THE LEGALITY OF WHICH WOULD BE TESTED IN THE EVENT OF A CHALLENGE BY THE ASSESSEE. 22. WE HAVE APPROACHED THE ISSUE OF INTERPRETATION THA T HAS ARISEN FOR DECISION IN THESE APPEALS, BOTH AS A MATTER OF FIRS T PRINCIPLE, BASED ON THE LANGUAGE USED IN S. 147(1) AND ON THE BASIS OF THE PRECEDENT ON THE SUBJECT. WE AGREE WITH THE SUBMISSIONS WHICH HAS BEEN URGED ON BEHALF OF THE ASSESSEE THAT S. 147(1) AS IT STANDS POSTULATES THAT UPON THE FOR MATION OF A REASON TO BELIEVE THAT INCOME CHARGEABLE TO TAX HAS ESCAPED ASSESSMEN T FOR ANY ASSESSMENT YEAR, THE AO MAY ASSESS OR REASSESS SUCH INCOME 'AND ALSO ' ANY OTHER INCOME CHARGEABLE TO TAX WHICH COMES TO HIS NOTICE SUBSEQU ENTLY DURING THE PROCEEDINGS AS HAVING ESCAPED ASSESSMENT. THE WORDS 'AND ALSO' ARE USED IN A CUMULATIVE AND CONJUNCTIVE SENSE. TO READ THESE WOR DS AS BEING IN THE ALTERNATIVE WOULD BE TO REWRITE THE LANGUAGE USED B Y PARLIAMENT. OUR VIEW HAS BEEN SUPPORTED BY THE BACKGROUND WHICH LED TO THE I NSERTION OF EXPLN. 3 TO S. 147. PARLIAMENT MUST BE REGARDED AS BEING AWARE OF THE INTERPRETATION THAT WAS PLACED ON THE WORDS 'AND ALSO' BY THE RAJASTHAN HIG H COURT IN SHRI RAM SINGH (SUPRA). PARLIAMENT HAS NOT TAKEN AWAY THE BA SIS OF THAT DECISION. WHILE IT IS OPEN TO PARLIAMENT, HAVING REGARD TO THE PLEN ITUDE OF ITS LEGISLATIVE POWERS TO DO SO, THE PROVISIONS OF S. 147(1) AS THEY STOOD AFTER THE AMENDMENT OF 1ST APRIL, 1989 CONTINUE TO HOLD THE FIELD. ITA NO.1283/JP/2018 SMT. PRABHATI DEVI MEENA VS ITO , WARD- 7(4) , JAIPUR 7 23. IN THAT VIEW OF THE MATTER AND FOR THE REASONS THA T WE HAVE INDICATED, WE DO NOT REGARD THE DECISION OF THE TRI BUNAL IN THE PRESENT CASE AS BEING IN ERROR. THE QUESTION OF LAW SHALL, ACCORDIN GLY, STAND ANSWERED AGAINST THE REVENUE AND IN FAVOUR OF THE ASSESSEE. THE APPE AL IS, ACCORDINGLY, DISMISSED. THERE SHALL BE NO ORDER AS TO COSTS. THEREFORE, ONCE THE AO WAS SATISFIED ON THE ISSUE O N WHICH THE ASSESSMENT WAS REOPENED THAT THERE IS NO ESCAPEMENT OF ASSESSMENT THEN HE CANNOT PROCEED FURTHER TO TAKE UP SOME OTHER ITE M OF INCOME AND MAKE THE ADDITION. IT TRANSPIRES FROM THE RECORD THAT TH E ASSESSEE HAD RECEIVED A SUM OF RS. 47.81 LACS AS SALE CONSIDERATION FROM TH E SALE OF LAND VIDE SALE DEED DATED 02-08-2008 AND AN AMOUNT OF RS. 7.00 LAC S WAS FOUND DEPOSITED ON 4-08-2008 IN THE HER BANK ACCOUNT. THE REFORE, THESE FACTS ITSELF ARE SELF-EXPLANATORY ABOUT THE SOURCE OF DEP OSIT OF SAID AMOUNT OF RS. 7.00 LACS, THOUGH DURING THE COURSE OF ASSESSM ENT PROCEEDINGS, THE ASSESSEE CLAIMED THAT THE SOURCE OF DEPOSIT IS AGRI CULTURAL INCOME AND PAST SAVINGS. HOWEVER, ONCE THE SALE CONSIDERATION ITSELF IS SUFFICIENT SOURCE OF DEPOSIT THEN THE ADDITION MADE BY THE AO IN REASSESSMENT PROCEEDINGS AFTER DROPPING THE ISSUE ON WHICH THE A SSESSMENT WAS REOPENED IS NOT SUSTAINABLE IN LAW. HENCE, THE ADDI TION OF RS. 7.00 LACS MADE BY THE AO IS DELETED. ITA NO.1283/JP/2018 SMT. PRABHATI DEVI MEENA VS ITO , WARD- 7(4) , JAIPUR 8 3.0 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS AL LOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 26 /02/2 020. 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:- 26/02/ 2020 *MISHRA VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1 VIHYKFKHZ@ THE APPELLANT- SMT. PRABHATI DEVI MEENA, JAIPUR 2 IZR;FKHZ@ THE RESPONDENT- ITO, WARD- 7(4), JAIPUR 3. VK;DJ VK;QDRVIHY ) @ CIT(A), 4. VK;DJ VK;QDR@ CIT, 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO. 1283/JP/2018) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR