Smt. Ram Lagan, Faridabad V. ITO, New Delhi

ITA 1375/DEL/2013

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 81908 (ITAT-DELHI)
• Duration Of Justice: 1 year(s) 7 month(s) 9 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-10-2014
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: F
• Next Hearing Date: 25-08-2014
• Assessment Year: 2007-2008
• Appeal Filed On: 07-03-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: MANOJ KUMAR CHOPRA
• Assessee Lawyers: ANJU JAI SINGH
• Section: 143(3); 142(1); 144

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: F NEW DELHI BEFORE SHRI B. C. MEENA, ACCOUNTANT MEMBER AND SHRI C. M. GARG, JUDICIAL MEMBER I.T.A .NO. - 1375 /DEL/2013 (ASSESSMENT YEAR - 200 7 - 0 8 ) RAM LAGAN, VS. ITO H. NO. 1483, SECTOR - 16 WARD - 15( 1 ) FARIDABAD - 121006 DELHI. HARYANA. PAN:AA BPL7973L (APPELLANT) (RESPONDENT) ASSESSEE BY: - MS . ANJU JAI SINGH , CA . REVENUE BY: - SH. MANOJ KUMAR CHOPRA, SR. DR ORDER PER C. M. GARG, JM. THIS APPEAL OF THE ASSESSEE HAS BEEN PREFERRED AGAINST THE ORDER OF CIT (APPEALS) - XVIII, NEW DELHI, VIDE DATED 18 .12.2012 IN APPEAL NO. 01 /201 0 - 1 1 FOR THE ASSESSMENT YEAR 200 7 - 0 9 . 2. THE ASSESSEE HAS RAISED FOLLOWING GROUNDS IN THIS APPEAL: 1.1 THE LEARNE D CIT (APPEALS) HAS ERRED ON FACTS AND IN LAW IN SUSTAINING THE ADDITION UNDER HEAD WAGES AND SALARY TO THE EXTENT THAT THE PROFIT FROM BUSINESS IS COMPUTED AT 25% OF GROSS RECEIPTS. THEREBY INCREASING THE NET PROFIT FROM RS.4,35,032 TO RS.13,59,945/ - . 1.2 THE LEARNED CIT (APPEALS) HAS ERRED ON FACTS AND IN LAW IN SUST AINING THE ADDITION UNDER HEAD TRAVELLING EXPENSES INCURRED BY THE ASSESSEE, WHERE THE ASSESSEE IS MANAGING THREE PLACES OF BUSINESS AT LUDHIANA AND K O LKATA, TO THE 2 EXTENT THAT THE PROFIT FRO M BUSINESS IS COMPUTED AT 25% OF GROSS RECEIPTS. THEREBY INCREASING THE NET PROFIT FROM RS.4,35,032 TO RS.13,59,945/ - . 1.3 THE LEARNED CIT (APPEALS) HAS ERRED ON FACTS AND IN LAW IN SUSTAINING THE ADDITION UNDER ALL OTHERS HEADS OF EXPENSES INCURRED TO THE EXTENT THAT THE PROFIT FROM BUSINESS IS COMPUTED AT 25% OF GROSS RECEIPTS. THEREBY INCREASING THE NET PROFIT FROM RS.4,35,032 TO RS.13,59,945/ - . 1.4 THE LEARNED CIT (APPEALS) HAS ERRED ON FACTS AND IN NOT CONSIDERING THE ADVANCE RECEIVED RS.1,83,000/ - WHE RE AS THIS WAS NOT RECEIVED DURING THE RELEVANT ASSESSMENT YEAR BY THE ASSESSEE AND THEREBY MADE AN ADDITION OF RS. 1, 83,000/ - . 1.5 THE LEARNED CIT (APPEALS) HAS ERRED ON FACTS IN NOT CONSIDERING THE TRANSFER OF WIFE S CAPITAL ON HER DEATH WITHOUT GIVING A N OPPORTUNITY TO EXPLAIN, THEREBY MAKING AN ADDITION OF RS.1,72,000/ - . LD. CIT(A) FAILED TO APPRECIATE THAT THE ASSESSEE HAS NOT RECEIVED THIS CAPITAL ON DEATH OF WIFE AS CAPITAL. 3. BRIEFLY STATED THE FACTS ; GIVING RISE TO THAT THE CASE WAS SELECTED UNDER SCRUTINY ON CASS AND ACCORDINGLY STATUTORY NOTICE U/S 143(2) OF THE INCOME TAX ACT, 1961, (FOR SHORT THE ACT ) WAS ISSUED ON 16.09.2008. AFTER AFFORDING DUE OPPORTUNITY OF HEARING THE AO MADE CERTAIN ADDITIONS ON ACCOU NT OF DIFFERENCE IN TDS CERTIFICATES, UNEXPLAINED LOAN TRANSFERRED TO CAPITAL, UNEXPLAINED ADVANCE AGAINST SALE OF SHOP AT MAYUR VIHAR, DISALLOWANCE ON ACCOUNT WAGES AND LABOUR CHARGES, SALARY, TRAVELLING EXPENSES, REMAINING EXPENSES AND THE AO COMPLETED T HE ASSESSMENT AT TOTAL TAX INCOME OF 3 RS.33,97,405/ - AS AGAINST THE RETURNED INCOME OF RS.4,70,600/ - . THE ASSESSEE PREFERRED AN APPEAL BEFORE LD. CIT(A) WHICH WAS PARTLY ALLOWED GRANTING PART RELIEF IN REGARD TO TRADING ADDITIONS AND DIFFERENCE AS PER TDS C ERTIFICATES, BUT THE LD. CIT(A) DISMISSED THE APPEAL OF THE ASSESSEE ON ACCOUNT OF UNEXPLAINED ADVANCE AGAINST SALE OF SHOP AT MAYUR VIHAR AND UNEXPLAINED LOAN TRANSFERRED TO CAPITAL ACCOUNT. AGGRIEVED ASSESSEE HAS PREFERRED IN PRESENT APPEAL AGAINST THE I MPUGN ED ORDER WITH THE GR OUNDS AS REPRODUCED HEREINABOVE . GROUND NOS. 1.1, 1.2 & 1.3 4 . WE HAVE HEARD ARGUMENT OF BOTH THE SIDES AND CAREFULLY PERUSED THE RELEVANT MATERIAL PLACED ON RECORD , INTER ALIA , ASSESSMENT ORDER AND IMPUGNED ORDER. 5 . THE LD. AR SUBMITTED THAT THE AO MADE DISALLOWANCE OF 50% OF EXPENSES CLAIMED WAGES, SALARY AND TRAVELLING EXPENSES AND 30% UNDER THE HEAD OF OTHER EXPENSES WITHOUT ANY BASIS AND THE LD. CIT(A) ACCEPTED THE CONTENTIONS AND EXPLANATION OF THE ASSESSEE BUT THE LD. CIT( A) GROSSLY ERRED IN DIRECTING THE AO TO COMPUTE THE NET PROFIT AT 25% OF GROSS RECEIPTS SHOWN BY THE ASSESSEE. THE LD. AR ALSO CONTENDED THAT THE LD. CIT(A) HAS ERRED ON FACTS IN LAW IN SUSTAINING THE ADDITION AND DIRECTING THE AO TO COMPUTE THE PROFIT FRO M BUSINESS AT 25% OF GROSS RECEIPTS OF THE ASSESSEE . 6 . THE LD. AR DRAWN OUR ATTENTION TOWARDS THE FACT THAT THE LOWER AUTHORITIES HAVE NOT REJECTED BOOKS OF ACCOUNTS AND STATEMENT OF ACCOUNTS OF THE ASSESSEE, 4 THEREFORE, ESTIMATION OF PROFIT FROM BUSINESS ON THE BASIS OF GROSS RECEIPTS IS NOT PERMISSIBLE UNDER THE STATUTORY PROVISION OF THE ACT. 7 . THE LD. DR SUPPORTED THE ORDER OF THE AUTHORITIES BELOW AND SUBMITTED THAT THE ASSESSEE WAS ASKED TO FURNISH THE MUSTER ROLL AND WAGES REGISTER FOR EXAMINATION WITH NAMES AND ADDRESSES OF THE PERSONS TO WHOM THE AMOUNT WAS PAID AND WAS ALSO ASKED TO BIFURCATE THE PAYMENT BUT THE ASSESSEE DID NOT FILE ANY SUBMISSIONS OR REQUIRED DOCUMENT AND EVIDENCE WHATSOEVER IN THIS REGARD AND IN THIS SITUATION THE AO WAS JUST IFIED IN MAKING IMPUGNED DISALLOWANCE IN ABSENCE OF ANY DOCUMENTARY EVIDENCE IN SUPPORT OF PAYMENT ON ACCOUNT OF WAGES AND LABOUR CHARGES WHICH REMAIN UNEXPLAINED. 8 . THE LD. DR ALSO SUBMITTED THAT THE AO ASKED THE ASSESSEE TO FURNISH NAMES, ADDRESSES AND DESIGNATION OF THE EMPLOYEES TO WHOM SALARY WAS PAID AND THE ASSESSEE WAS ALSO EXPECTED TO PRODUCE SALARY REGISTER BUT THE ASSESSEE FAIL S TO SUBMIT THE REQUIRE DETAILS AND IN ABSENCE OF ANY DOCUMENTARY EVIDENCE OF PAYMENT OF RS.4,16,160/ - ON ACCOUNT OF SALARY THE AO HAS RIGHTLY HELD THAT THE CLAIM REMAINED UNEXPLAINED. 9 . THE LD. DR ALSO DRAWN OUR ATTENTION TOWARDS ASSESSMENT ORDER AND SUBMITTED THAT THE ASSESSEE WAS ALSO DIRECT ED BY THE AO TO SUBMIT DOCUMENTARY EVIDENCE SUCH AS BILLS/VOU CHERS/TICKETS AND OTHER DETAILS PERTAINING TO THE CLAIM OF TRAVELLING EXPENSES OF RS.1,99,481/ - REMAINING EXPENSES OF RS.10,00,489/ - BUT THE ASSESSEE ALSO FAIL TO SUBMIT THE SAME, THEREFORE, THE AO WAS RIGHT IN 5 MAKING 50% DISALLOWANCE OF TRAVELLING EXPENSE S AND 30% OF CLAIM OF THE REMAINING EXPENSES IN THIS REGARD. 1 0 . THE LD. DR ALSO SUBMITTED THAT THE LD. CIT(A) GRANTED RELIEF FOR THE ASSESSEE BY DIRECTING THE AO TO COMPUTE PROFIT FROM BUSINESS AT 25% OF THE GROSS RECEIPTS TAKING A BALANCING APPROACH THE REFORE, THIS GROUND OF THE ASSESSEE IS NOT SUSTAINABLE. 1 1 . ON CAREFULLY CONSIDERATION OF ABOVE SUBMISSIONS WE OBSERVE THAT THE AO PICKED UP THE CASE FOR SCRUTINY AND ISSUE D A SHOW CAUSE NOTICE U/S 142(1) OF THE ACT DATED 8.10.2009 BY FIXING THE CASE FOR FINAL HEARING ON 14.10.2009 GIVING ONLY 5 - 6 DAYS TIME TO SUBMIT THE REPLY. ON THE DATE OF HEARING THAT WAS 14.10.2009 THE AO OBSERVE THAT NO REPLY WAS RECEIVED NOR ANY BOOKS OF ACCOUNTS OR BILLS AND VOUCHERS AS WELL AS THE AO ASSUMED THAT THE ASSESSEE HAS NOTHING TO SAY IN HIS DEFENCE AND THE ASSESSEE DELIBERATELY CHOSE NOT TO REPLY TO THE QUERIES AND NOTICE OF THE AO. THE AO CONCLUDED THE ASSESSMENT PROCEEDINGS ON VERY SAME DATE I.E. 14.10.2009 AND PASS THE ASSESSMENT ORDER DATED 3.11.2009 U/S 143(3) OF TH E ACT. DURING THE FIRST APPELLATE PROCEEDINGS THE LD. CIT(A) RESTRICTED THE DISALLOWANCE AND DIRECTED THE AO TO COMPUTE THE BUSINESS PROFIT OF THE ASSESSEE AT 25% OF THE GROSS RECEIPTS SHOWN BY THE ASSESSEE. THE RELEVANT OPERATING PART OF THE IMPUGNED ORDE R READS AS UNDER: DURING APPELLATE PROCEEDINGS, THE APPELLANT CLAIMED THAT THE DISALLOWANCE MADE BY THE ASSESSING OFFICER WAS EXCESSIVE SINCE THIS RESULTED IN COMPUTATION OF PROFIT AT 54.32% OF THE CONTRACT RECEIPTS AS AGAINST 8% DECLARED BY THE ASSESSEE. EVEN IN CASE OF 6 BEST JUDGMENT ASSESSMENT, THE ESTIMATE MADE HAS TO BE ON THE BASIS OF THE NATURE OF WORK AND THE BEST JUDGMENT AND IN A RATIONAL MANNER. THE APPELLANT WAS ASKED TO JUSTIFY THE CLAIM OF THE EXPENSES UNDER THE HEAD WAGES AND SALARY BY PRODUCING RETURN OF ESI & PF DEDUCTED FOR THE YEAR. FOR THIS PURPOSE, THE CASE WAS FIXED FOR 09.01.2012, ADJOURNED TO 30.01.2012, 06.02.2012, AND AGAIN TO 21.02.2012. HOWEVER, N O DETAILS WERE FORTHCOMING AND THE APPELLANT DID NOT PRODUCE THE ESI & PF RETURNS. FRESH NOTICES WERE ISSUED FIXING THE CASE FOR 10.05.2012, 25.10.2012, 05.11.2012 AND 13.12.2012. HOWEVER, STILL THERE WAS NO COMPLIANCE ON PART OF THE APPELLANT. FROM THE AB OVE, IT IS CLEAR THAT THE EXPENSES CLAIMED BY THE APPELLANT ARE EXCESSIVE AND NO DETAILS ARE MAINTAINED BY HIM IN RESPECT OF VARIOUS EXPENSES DEBITED UNDER THE HEAD WAGES, SALARY, TRAVELLING & OTHER EXPENSES. THE APPELLANT HAS SHOWN GROSS RECEIPTS OF RS.54 ,39,781 / - . IT CANNOT BE DENIED THAT THE APPELLANT MUST HAVE INCURRED SOME EXPENSES ON WAGES, SALARY, TRAVELLING, ETC. THE ASSESSING OFFICER HAS FRAMED A BEST JUDGEMENT ASSESSMENT AND HAS MADE DISALLOWANCE OF 50% OF EXPENSES CLAIMED UNDER THESE HEADS AND 30 % UNDER THE HEAD OTHER EXPENSES. HOWEVER, KEEPING IN VIEW THE NATURE OF BUSINESS AND THE NON - MAINTENANCE OF RECORD BY THE APPELLANT, THE ASSESSING OFFICER IS DIRECTED TO COMPUTE THE NET PROFIT AT 25% OF THE GROSS RECEIPTS SHOWN BY THE APPELLANT. THESE GROU NDS OF APPEAL ARE DISPOSED OFF ACCORDINGLY. 1 2 . FROM PERUSAL OF ABOVE, WE CLEARLY OBSERVE THAT THE LD. CIT(A) WAS NOT AGREED TO THE CONCLUSION OF THE AO IN THE ASSESSMENT ORDER WHEREIN THE AO FRAMED BEST JUDGMENT ASSESSMENT AND MADE DISALLOWANCE OF 50% OF EXPENSES CLAIMED UNDER WAGES SALARY, TRAVELLING AND OTHER EXPENSES AND 30% UNDER THE HEAD OF OTHER EXPENSES. AT THE SAME TIME WE ALSO OBSER VE THAT THE LD. CIT(A) 7 DIRECTED THE AO TO COMPUTE THE NET PROFIT OF THE ASSESSEE AT 25% OF THE GROSS RECEIPTS SHOWN BY THE ASSESSEE BUT WE ARE UNABLE TO SEE ANY BASIS OR COGENT REASON SUPPORTING THIS DIRECTION OF THE LD. CIT(A) IN THE IMPUGNED ORDER. DURING THE HEARING THE LD. DR FAIRLY ACCEPTED THAT THE DEPARTMENT HAS NO SERIOUS OBJECTION TO THAT IF IT IS FOUND JUST AN D PROPER TO RESTORE THE ISSUE TO THE FILE OF THE AO FOR FRESH ADJUDICATION . 1 3 . IN VIEW OF ABOVE DISCUSSION, WE REACH TO A CONCLUSION THAT THE AO MADE DISALLOWANCES IN A HURRIED MANNER WITHOUT GIVING ANY ADEQUATE OPPORTUNITY FOR THE ASSESSEE TO SUBMIT RELEVANT DETAILS, REGISTERS, BILLS, VOUCHERS AND OTHER EVIDENCE AS REQUIRED BY THE AO DURING ASSESSMENT PROCEEDINGS. THE LD. CIT(A) IMPLIEDLY SET ASIDE THESE DISALLOWANCES AND DIRECT ED THE AO TO COMPUTE THE BUSINESS PROFIT OF THE ASSESSEE ON THE BASIS OF 2 5% OF THE GROSS RECEIPTS SHOWN BY THE ASSESSEE BUT WITHOUT ANY BASIS AND JUSTIFIED GROUND. IT IS A WELL SETTLED PROPOSITION THAT IF THE ASSESSEE IS NOT COOPERATING WITH THE AO DURING THE ASSESSMENT PROCEEDINGS THEN AO MAY COMPLETE THE ASSESSMENT PROCEEDING S U/S 14 4 OF THE ACT, ON THE BASIS OF BEST JUDGMENT ASSESSMENT. AT THE SAME TIME , IT IS THE DUTY OF THE AO TO TAKE COGNIZANCE OF EARLIER AND SUBSEQUENT ASSESSMENT ORDERS AND SUITABLE AND REASONABLE COMPARABLES FOR ESTIMATING THE INCOME OF THE ASSESSEE. BUT IN THE INSTANT CASE THE AO MISERABLY FAIL TO COMPLY WITH THE DUTIES CASTED UPON HIM AS PER STATUTORY PROVISION OF THE ACT. 1 4 . WE ALSO OBSERVE THAT THE LD. CIT(A) WA S NOT AGREED WITH THE APPROACH OF THE AO BUT THE LD. CIT(A) ALSO ERRED IN DIRECTING THE A O TO COMPUTE THE 8 BUSINESS PROFIT OF THE ASSESSEE AT 25% OF THE GROSS RECEIPTS SHOWN BY THE ASSESSEE, WITHOUT ANY BASIS AND REASONING. THE LD. CIT(A) ALSO DID NOT CONSIDER THE EARLIER AND SUBSEQUENT ASSESSMENT ORDERS AND THE OTHER SUITABLE COMPARABLES TO ES TIMATE THE PROFIT OF THE ASSESSEE FOR THE YEAR UNDER CONSIDERATION. 15. UNDER THESE FACTS AND CIRCUMSTANCES, WE ARE OF THE CONSIDERED OPINION THAT THE ENDS OF JUSTICE WOULD MEET IF THE ISSUE INVOLVED IN GROUND NO. 1.1, 1.2 AND 1.3 IS SET ASIDE AND RESTORE BACK TO THE FILE OF AO FOR FRESH CONSIDERATION AND ADJUDICATION AFTER AFFORDING DUE OPPORTUNITY OF HEARING FOR THE ASSESSEE. THEREFORE, WE SET ASIDE THE ASSESSMENT AND IMPUGNED ORDER ON THIS ISSUE AND DIRECT THE AO TO ADJUDICATE THE ISSUE OF IMPUGNED DISA LLOWANCE DE NOVO AFTER GIVING DUE OPPORTUNITY OF HEARING FOR THE ASSESSEE AND WITHOUT BEING PREJUDICED BY THE OBSERVATIONS AND FINDINGS IN THE EARLIER IMPUGNED AND ASSESSMENT ORDER . HENCE, GROUND NO. 1.1, 1.2 & 1.3 OF THE ASSESSEE ARE DEEMED TO BE ALLOWED FOR STATISTICAL PURPOSES. GROUND NO. 1.4 & 1.5 16. APROPOS GROUND NOS. 1.4 & 1.5 ARGUMENT OF BOTH THE SIDES AND CAREFULLY PERUSED THE RELEVANT MATERIAL INTER ALIA ASSESSMENT ORDER AND THE IMPUGNED ORDER. 17. THE LD. AR SUBMITTED THAT THE ASSESSEE WAS NOT GRANTED DUE OPPORTUNITY OF HEARING BY THE AO AND THE LD. CIT(A) ALSO UPHELD THE ADDITIONS IN A CRYPTIC MANNER THEREFORE THE ASSESSEE SHOULD BE GRANTED DUE OPPORTUNITY OF HEARING TO SUBMIT REQUIRED EXPLANATION, EVIDENCE AND DETAILS OF SUPPORT HIS CLAIM. 9 18. THE LD. DR CONTENDED THAT IF ON SPECIFIC QUERY FROM THE AO THE ASSESSEE HIMSELF FAIL S TO SUBMIT THE REQUIRED INFORMATION, EXPLANATION AND EVIDENCE DURING THE ASSESSMENT PROCEEDINGS THEN THE AO HAS NO OPTION BUT TO COMPLETE THE ASSESSMENT PROCEEDINGS ON THE BASIS OF BEST JUDGMENT ASSESSMENT. 19. ON CAREFUL CONSIDERATION OF ABOVE, WE ARE OF THE CONSIDERED OPINION THAT THE AO HAS MADE IMPUGNED ADDITION PERTAINING TO AMOUNT OF ADVANCE AGAINST SALE OF SHOP AT MAYUR VIHAR, AND LOANS TRANSFERRED TO CAPITAL ON DEATH OF WIFE BY HOLDING THAT NO REPLY/EXPLA NATION BE FILED BY THE ASSESSEE BUT AS WE HAVE ALREADY NOTICED HEREINABOVE THAT THE AO ISSUED NOTICE ON 8.10.2009 AND CLOSED THE PROCEEDINGS ON 14.10.2009 IN THE HASTE MANNER. THEREFORE, IT CAN SAFELY BE PRESUMED THAT THE ASSESSEE WAS NOT GRANTED DUE OPPOR TUNITY OF HEARING BY THE AO DURING THE EARLIER PROCEEDINGS. 20. DURING FIRST APPELLATE PROCEEDINGS THE LD. CIT(A) OBSERVE THAT THE ASSESSEE FAIL ED TO FILE FINAL SALE AGREEMENT TO SUPPORT THE AUTHENTICITY OF THE TRANSACTION AND THE IDENTIFICATION AND GENUI NENESS OF THE PERSON FROM WHOM THE AMOUNT OF RS.1,83,000/ - HAS BEEN RECEIVED. THE LD. CIT(A) ALSO NOTICED THAT THE AO HAS NOT MADE ANY COMMENT ON THE DEATH CERTIFICATE SUBMITTED BY THE ASSESSEE TO SUPPORT THE DATE OF DEATH OF HIS WIFE. SINCE WE HAVE RESTOR ED THE MAIN ISSUE TO THE FILE OF THE AO FOR AFRESH DE NOVO THE ADJUDICATION, WE FIND AN APPROPRIATE TO RESTORE THE ISSUES INVOLVED IN GROUND NOS. 1.4 & 1.5 OF THE ASSESSEE TO THE FILE OF THE AO WITH A DIRECTION THAT THE AO SHALL DECIDE THESE ISSUES AFTER A FFORDING DUE OPPORTUNITY OF HEARING FOR THE ASSESSEE AND WITHOUT 10 BEING PREJUDICED WITH THE CONCLUSION AND OBSERVATIONS IN THE EARLIER ASSESSMENT AND IMPUGNED ORDER ON THESE ISSUES. ACCORDINGLY GROUND NOS. 1.4 & 1.5 OF THE ASSESSEE ARE ALSO DEEMED TO BE ALL OWED FOR STATISTICAL PURPOSES. 21. IN THE RESULT, APPEAL OF THE ASSESSEE IS DEEMED TO BE ALLOWED FOR STATISTICAL PURPOSES ON THE ISSUE AS INDICATED ABOVE. ORDER PRONOUNCED IN THE OPEN COURT ON 16 /10/2014. SD/ - SD/ - (B. C. M EENA ) (C. M. GARG) A CCOUNTANT MEMBER JUDICIAL MEMBER DATED: 16 /10/2014 *AK VERMA* COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGISTRAR