Narayan Keshav Kulkarni, Mumbai V. Income-tax Officer,

ITA 1408/PUN/2016

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 0448 (ITAT-PUNE)
• Duration Of Justice: 4 month(s) 19 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-11-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2010-2011
• Appeal Filed On: 29-06-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SUMITRA BANERJI
• Keywords: Retrospective amendment; Question of law; Cost of acquisition; Fair market value; Valuation report
• Section: 133(6)

Judgement Text

- IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH SMC , PUNE , BEFORE MS. SUSHMA CHOWLA, JM . / ITA NO. 1 408 /PN/201 6 / ASSESS MENT YEAR : 20 1 0 - 1 1 SHRI NARAYAN KESHAV KULKARNI, C/O SHIRISH H. SHAH & CO., CHARTERED ACCOUNTANTS, 1/2, MANGROL MANSION, 6, RUSTOM SIDHWA MARG, FORT, MUMBAI 400001 . / APPELLANT PAN: A KTPK1563H VS. THE INCOME TAX OFFICER , THE INCOME TAX OFFICER , WARD - 3, AHME DNAGAR . / RESPONDENT / APPELLANT BY : S HRI SANKET JOSHI / RESPONDENT BY : SMT. SUMITRA BANERJI / DATE OF HEARING : 1 8 . 1 0 .201 6 / DATE OF PRONOUNCEMENT: 18 . 1 1 .201 6 / ORDER PER SUSHMA CHOWLA, J M : TH IS APPEAL FILED BY THE ASSESSEE IS AGAINST THE ORDER OF CIT (A) - 2 , PUNE , DATED 2 2 . 0 2 .20 1 6 RELATING TO ASSESSMENT YEAR 20 1 0 - 1 1 AGAINST ORDER PASSED UNDER SECTION 1 4 3(3) OF THE INCOME - TAX ACT , 1961 (IN SHORT THE ACT) . ITA NO. 1 408 /PN/20 1 6 SHRI NARAYAN KESHAV KULKARNI 2 2 . THE ASSESSEE HAS FILED REVISED GROUND S OF APPEAL , WHICH READ AS UNDER : - 1] THE LEARNED CIT(A) ERRED IN CONFIRMING THE ADDITION OF RS.28,79,562/ - MADE BY THE A.O. IN RESPECT OF LONG TERM CAPITAL GAINS ON SALE OF HOTEL LAND AND BUILD ING MADE ON 16.01.2010. 2] THE LEARNED CIT(A) ERRED IN ADOPTING THE FAIR MARKET VALUE OF HOTEL PROPERTY AS ON 01.04.1981 AT RS.41,400 / - AS DETERMINED BY THE DVO AS AGAINST THE FAIR MARKET VALUE OF RS.45,37,500 / - DETERMINED BY THE GOVT. APPROVED VALUE R FOR THE PURPOSES OF COMPUTING LONG TERM CAPITAL GAINS ON SALE OF THE IMPUGNED PROPERTY. 3] THE LEARNED CIT(A) FAILED TO APPRECIATE THAT THE FAIR MARKET VALUE OF HOTEL PROPERTY AS ON 01.04.1981 CLAIMED BY THE ASSESSEE ON THE BASIS OF GOVT. APPROVED V ALUER'S REPORT WAS MORE THAN THE FAIR MARKET VALUE SOUGHT TO BE ADOPTED BY THE A.O. AND HENCE, THE REFERENCE MADE TO THE DVO U/S 55A FOR THE CURRENT YEAR WAS BAD IN LAW AND THEREFORE, THE VALUATION AS ON 01.04.1981 CLAIMED BY THE ASSESSEE SHOULD HAVE BEEN ADOPTED FOR THE PURPOSES OF COMPUTING LONG TERM CAPITAL GAINS ON SALE OF THE HOTEL PROPERTY. 4] THE LEARNED CIT(A) ERRED IN NOT APPRECIATING THAT IN CASE, THE FAIR MARKET VALUE OF THE SAID PROPERTY WAS ADOPTED AS PER THE VALUATION DONE BY THE GOVT. AP PROVED VALUER, THERE DID NOT ARISE ANY LONG TERM CAPITAL GAINS ON SALE OF THE PROPERTY AND HENCE, THE ADDITION MADE BY THE A.O. SHOULD HAVE BEEN DELETED. 5] THE APPELLANT SUBMITS THAT THE ISSUE UNDER CONSIDERATION IS SQUARELY COVERED IN FAVOUR OF THE ASSESSEE BY THE DECISION OF HON'BLE ITAT, COVERED IN FAVOUR OF THE ASSESSEE BY THE DECISION OF HON'BLE ITAT, PUNE IN THE CASE OF SHRI RAJENDRA KESHAVRAO KULKARNI [ITA NO. 1340 / PN/20 15] WHO WAS THE C O - OWNER IN THE IMPUGNED PROPERTY SOLD BY THE ASSESSEE AND HENCE, IT IS REQUESTED THAT THE SAME RATIO MAY BE FOLLOWED IN THE CASE OF THE ASSESSEE. 3. THE ISSUE ARISING IN THE PRESENT APPEAL IS AGAINST COMPUTATION OF LONG TERM CAPITAL GAINS ON SALE OF HOTEL LAND AND BUILDING. THE ASSESSEE IS AGGRIEVED BY THE ORDERS OF AUTHORITIES BELOW IN ADOPTING THE FAIR MARKET VALUE OF THE PROPERTY AS ON 01.04.1981 AT RS. 41,400/ - AS DETERMINED BY THE DVO AS AGAINST THE FAIR MARKET VALUE OF RS. 45,37,500/ - DETERMINED BY THE GOVERNMENT APPROVED VALUER. THE ASSESSEE HAS CHALLENGED THE REFERENCE MADE TO THE DVO UNDER SECTION 55A OF THE ACT BEING BAD IN LAW SINCE THE FAIR MARKET VALUE OF THE PROPERTY AS ON 01.04.1981 CLAIMED BY THE ASSESSEE ON THE BASIS OF APPROVED VALUER REPORT WAS MORE THAN THE FAIR MARKET VALUE SOUGHT TO BE ADOPTED BY THE ASSESSING OFFICER. ITA NO. 1 408 /PN/20 1 6 SHRI NARAYAN KESHAV KULKARNI 3 4. THE LEARNED AUTHORIZED REPRESENT ATIVE FOR THE ASSESSEE AT THE OUTSET POINTED OUT THAT THE ISSUE RAISED IN THE PRESENT APPEAL IS SQUARELY COVERED BY THE ORDER OF TRIBUNAL IN THE CASE OF S HRI RAJENDRA KESHAVRAO KULKARNI, WHO I S BROTHER OF ASSESSEE AND WAS CO - OWNER OF THE PROPERTY. ANOTHER POINT RAISED BY THE LEARNED AUTHORIZED REPRESENTATIVE FOR THE ASSESSEE WAS THAT THE REGISTERED VALUER HAD ADOPTED THE COST OF ACQUISITION OF LAND TO BE THE FAIR MARKET VALUE AS ON 01.04.1981 AND HAD ALSO VALUED THE STRUCTURE THERE ON AT RS.45 LAKHS, WHEREA S THE DVO HAD ERRED ONLY IN CONSIDERING THE VALUE OF LAND FOR DETERMINING THE FAIR MARKET VALUE OF THE LAND AS ON 01.04.1981. 5. THE LEARNED DEPARTMENTAL REPRESENTATIVE FOR THE REVENUE POINTED OUT THAT THE ASSESSEE HAS FAILED TO APPEAR BEFORE THE CIT(A) A ND FURNISH ANY INFORMATION AND HENCE, NO MERIT IN THE SUBMISSIONS MADE NOW. 6. ON PERUSAL OF RECORD AND AFTER HEARING BOTH THE LEARNED AUTHORIZED REPRESENTATIVES, THE ISSUE WHICH NEEDS TO BE ADJUDICATED IN THE PRESENT CASE IS THE FAIR MARKET VALUE OF THE PROPERTY AS ON 01.04.1981, WHICH WAS SOLD BY THE ASSESSEE DURING THE YEAR, WHICH IS NEEDED TO BE CO MPUTED AS INCOME FROM LONG TERM CAPITAL GAINS IN THE HANDS OF ASSESSEE. THE ASSESSEE OWNED A HOTEL LAND, BUILDING THEREON, WHICH WAS SOLD BY THE ASSESSEE ON 16.01.2010. THE ASSESSEE HAD DECLARED THE FAIR MARKET VALUE OF THE SAID PROPERTY I.E. COST OF LAND AND THE SUPER STRUCTURE AT RS. 45,37,500/ - , WHICH IN TURN, WAS SUPPORTED BY GOVERNMENT APPROVED VALUER. THE ASSESSEE ACCORDINGLY, HAD COMPUTED THE LONG TER M CAPITAL GAINS ON THE SALE OF SAID PROPERTY. THE ASSESSING OFFICER WAS OF THE VIEW THAT THE FAIR MARKET VALUE DECLARED BY THE ASSESSEE AS ON 01.04.1981 WAS HIGHER AND CONSEQUENTLY, REFERENCE WAS MADE TO THE DVO TO ITA NO. 1 408 /PN/20 1 6 SHRI NARAYAN KESHAV KULKARNI 4 DETERMINE THE FAIR MARKET VALUE AS ON 01 .04.1981. THE DVO HAD VALUED THE SAID PROPERTY AT RS. 41,400/ - . THE ASSESSEE HAS PLACED ON RECORD THE COPY OF VALUATION REPORT OF DVO AT PAGES 1 TO 6 PAPER BOOK AND THE COPY OF REGISTERED VALUATION REPORT AT PAGES 7 TO 36 OF THE PAPER BOOK. THE PERUSAL O F DVOS VALUATION REPORT REFLECTS THAT THE COST OF LAND AS ON 01.04.1981 WAS COMPUTED BY THE DVO AT RS.41,400/ - AND THE COST OF SUPER STRUCTURE WAS SEPARATELY WORKED OUT BUT THE SAME WAS NOT CONSIDERED BY THE ASSESSING OFFICER WHILE COMPUTING THE INCOME FR OM LONG TERM CAPITAL GAINS IN THE HANDS OF ASSESSEE. 7. THE FIRST ISSUE WHICH NEEDS TO BE ADDRESSED IN THE PRESENT CASE IS THE ACTION OF ASSESSING OFFICER IN MAKING REFERENCE UNDER SECTION 55A OF THE ACT TO THE DVO TO DETERMINE THE FAIR MARKET VALUE OF PROPERTY AS ON 01.04.1981 ON THE SURMISE THAT THE VALUE DECLARED BY THE ASSESSEE IS HIGHER. I FIND IDENTICAL THE SURMISE THAT THE VALUE DECLARED BY THE ASSESSEE IS HIGHER. I FIND IDENTICAL ISSUE OF REFERENCE UNDER SECTION 55A OF THE ACT TO THE DVO BY THE ASSESSING OFFICER AROSE IN THE CASE OF BROTHER OF ASSESSEE WHO WAS THE CO - OWNER OF THE PROPERTY. THE TRIBUNAL IN ITA NO.1340/PN/2015, RELATING TO ASSESSMENT YEAR 20 10 - 11, ORDER DATED 22.07.2016 NOTED THE FACT THAT THE ISSUE IS SQUARELY COVERED BY THE RATIO LAID DOWN BY THE HONBLE BOMBAY HIGH COURT IN CIT VS. PUJA PRINTS REPORTED IN 360 ITR 697 (BOM) AND HELD AS UNDER: - 8. I FIND AN IDENTICAL ISSUE HAD COME UP BEFORE THE HONBLE BOMBAY HIGH COURT IN THE CASE OF CIT VS. PUJA PRINTS REPORTED IN 360 ITR 697. THE HONBLE HIGH COURT AFTER CONSIDERING THE PROVISIONS OF SECTION 55A AS WELL AS THE AMENDMENT TO THE SAID SECTION BY THE FINANCE ACT, 2012 W.E.F. 01 - 07 - 2012 HAS HELD THAT REFERENCE U/S.55A CAN BE MADE TO THE DVO ONLY WHEN THE VALUE ADOPTED BY THE ASSESSEE IS LESS THAN THE FAIR MARKET VALUE. WHERE THE VALUE ADOPTED BY THE ASSESSEE IS MUCH MORE THAN THE FAIR MARKET VALUE, NO REFERENCE CAN BE MADE TO THE VALUATION OFFICER UNDER THE PROVISIONS OF SECTION 55A. THE RELEVANT OBSERVATION OF THE HONBLE HIGH COURT AT PAGE 701 TO 703 READ AS UNDER : ITA NO. 1 408 /PN/20 1 6 SHRI NARAYAN KESHAV KULKARNI 5 6 . WE HAVE CONSIDERED THE RIVAL SUBMI SSIONS. WE FIND THAT THE IMPUGNED ORDER DATED 18 FEBRUARY, 2011 ALLOWING THE RESPONDENT ASSESSEE'S APPEAL HOLDING THAT NO REFERENCE TO THE DEPARTMENTAL VALUATION OFFICER CAN BE MADE UNDER SECTION 55A OF TH E ACT, ONLY FOLLOWS THE DECISION OF THIS COURT IN THE MATTER OF DAULAL MOHTA HUF (SUPRA). THE REVENUE HAS NOT BEEN ABLE TO POINT OUT HOW THE AFORESAID DECISION IS INAPPLICABLE TO THE PRESENT FACTS NOR HAS THE REVENUE POINTED OUT THAT THE DECISION IN DAULAL MOHTA HUF (SUPRA) HAS NOT BEEN ACCEPTED BY THE REVENUE. ON THE AFORESAID GROUND ALONE, THIS APPEAL NEED NOT BE ENTERTAINED. HOWEVER, AS SUBMISSIONS WERE MADE ON MERITS, WE HAVE INDEPENDENTLY EXAMINED THE SAME. 7 . WE FIND THAT SECTION 55A(A) OF THE ACT VERY CLEARLY AT THE RELEVANT TIME PROVIDED THAT A REFERENCE COULD BE MADE TO THE DEPARTMENTAL VALUATION OFFICER ONLY WHEN THE VALUE ADOPTED BY THE ASSESSEE WAS LESS THAN THE FAIR MARKET VALUE. IN THE PRESENT CASE, IT IS AN UNDISPUTED POSITION THAT THE VALUE ADOPTED BY THE RESPONDENT - ASSESSEE OF THE PROPERTY AT RS.35.99 LAKHS WAS MUCH MORE THAN THE FAIR MARKET VALUE OF RS.6.68 LAKHS EVEN AS DETERMINED BY THE DEPARTMENTAL VALUATION OFFICER. IN FACT, THE ASSESSI NG OFFICER REFERRED THE ISSUE OF VALUATION TO THE DEPARTMENTAL VALUATION OFFICER ONLY BECAUSE IN HIS VIEW THE VALUATION OF THE PROPERTY AS ON 1981 AS MADE BY THE RESPONDENT - ASSESSEE WAS HIGHER THAN THE FAIR MARKET VALUE. IN THE AFORESAID CIRCUMSTANCES, THE INVOCATION OF SECTION 55A(A) OF THE ACT IS NOT JUSTIFIED. 8. THE CONTENTION OF THE REVENUE THAT IN VIEW OF THE AMENDMENT TO SECTION 55A(A) OF THE ACT IN 2012 BY WHICH THE WORDS 'IS LESS THEN THE FAIR MARKET VALUE' IS SUBSTITUTED BY THE WORDS ' 'IS AT VARIANCE WITH ITS FAIR MARKET VALUE' IS SUBSTITUTED BY THE WORDS ' 'IS AT VARIANCE WITH ITS FAIR MARKET VALUE' IS CLARIFACTORY AND SHOULD BE GIVEN RETROSPECTIVE EFFECT. THIS SUBMISSION IS IN FACE OF THE FACT THAT THE 2012 AMENDME NT WAS MADE EFFECTIVE ONLY FROM 1 JULY 2012. THE PARLIAMENT HAS NOT GIVEN RETROSPECTIVE EFFECT TO THE AMENDMENT. THEREFORE, THE LAW TO BE APPLIED IN THE PRESENT CASE IS SECTION 55A(A) OF THE ACT AS EXISTING DURING THE PERIOD RELEVANT TO THE ASSESSMENT YEAR 2006 - 07. AT THE RELEVANT TIME, VERY CLEARLY REFERENCE COULD BE MADE TO DEPARTMENTAL VALUATION OFFICER ONLY IF THE VALUE DECLARED BY THE ASSESSEE IS IN THE OPINION OF ASSESSING OFFICER LESS THAN ITS FAIR MA RKET VALUE. 9. THE CONTENTION OF THE REVENUE THAT THE REFERENCE TO THE DEPARTMENTAL VALUATION OFFICER BY THE ASSESSING OFFICER IS SUSTAINABLE IN VIEW OF SECTION 55A(A) (II) OF THE ACT IS NOT ACCEPTABLE. T HIS IS FOR THE REASON THAT SECTION 55A(B) OF THE ACT VERY CLEARLY STATES THAT IT WOULD APPLY IN ANY OTHER CASE I.E. A CASE NOT COVERED BY SECTION 55A(A) OF THE ACT. IN THIS CASE, IT IS AN UNDISPUTABLE POSITION THAT THE ISSUE IS COVERED BY SECTION 55A(A) OF THE ACT. THEREFORE, RESORT CANNOT BE HAD TO THE RESIDUARY CLAUSE PROVIDED IN SECTION 55A(B)(II) OF THE ACT. IN VIEW OF THE ABOVE, THE CBDT CIRCULAR DATED 25 NOVEMBER 1972 CAN HAVE NO APPLICATION IN THE FACE OF THE CLEAR POSITION IN LAW. THIS IS SO AS THE UNDERSTANDING OF THE STATUTORY PROVISIONS BY THE REVE NUE AS FOUND IN CIRCULAR ISSUED BY THE CBDT IS NOT BINDING UPON THE ASSESSEE AND IT IS OPEN TO AN ASSESSEE TO CONTEND TO THE CONTRARY. 10. THE CONTENTION OF THE REVENUE THAT THE ASSESSING OFFICER IS ENTITLED TO REFER THE ISSUE OF VALUATION OF THE PROPE RTY TO THE DEPARTMENTAL VALUATION OFFICER IN EXERCISE OF ITS POWER UNDER SECTIONS ITA NO. 1 408 /PN/20 1 6 SHRI NARAYAN KESHAV KULKARNI 6 131 , 133(6) AND 142( 2) OF THE ACT IS ENTIRELY BASED UPON THE DECISION OF THE GUWAHATI HIGH COURT IN SMT. AMIYA BALA PAUL (SUPRA). HOWEVER, THE APEX COURT IN SMT. AMIYA BALA PAUL (SUPRA) HAS REVERSED THE DECISION OF THE GUWAHATI HIGH COURT AND HELD THAT IF THE POWER TO REFER ANY DISPUTE WITH REGARD TO THE VALUATION OF THE PROPERTY WAS ALREADY AVAILABLE UNDER SECTIONS 131(1) , 136(6) AND 142(2) OF THE ACT, THERE WAS NO NEED TO SPECIFICALLY EMPOWER THE ASSESSING OFFICER TO DO SO IN CIRCUMSTANCES SPECIFIED UNDER SECTION 55A OF THE ACT. IT FURTHER HELD THAT WHEN A SPECIFIC PROVISI ON UNDER WHICH THE REFERENCE CAN BE MADE TO THE DEPARTMENTAL VALUATION OFFICER IS AVAILABLE, THERE IS NO OCCASION FOR THE ASSESSING OFFICER TO INVOKE THE GENERAL POWERS OF ENQUIRY. IN VIEW OF THE ABOVE AND PARTICULARLY IN VIEW OF CLEAR PROVISIONS OF LAW A S EXISTING DURING THE PERIOD RELEVANT TO ASSESSMENT YEAR 2006 - 07, WE ARE OF THE VIEW THAT QUESTIONS (A) AND (B) DO NOT RAISE ANY SUBSTANTIAL QUESTION OF LAW. REGARDING QUESTION (C): - 11 . THE TRIBUNAL BY ITS IMPUGNED ORDER HAS MERELY REMANDED THE ISSUE TO THE ASSESSING OFFICER TO DETERMINE THE DATE ON WHICH THE RESPONDENT - ASSESSEE ACQUIRED THE PROPERTY FOR THE PURPOSE OF WORKING OUT THE COST OF ACQUISITION. NO SPECIFIC SUBMISSIONS IN REGARD TO THIS ISSUE WAS MADE BY THE REVENUE DURING THE ORAL SUBMISSION S. IN ANY EVENT, AN ORDER OF REMAND IN THESE FACTS DOES NOT GIVE RISE TO ANY SUBSTANTIAL QUESTION OF LAW. 12. ACCORDINGLY, WE SEE NO REASON TO ENTERTAIN QUESTIONS (A), (B) AND 12. ACCORDINGLY, WE SEE NO REASON TO ENTERTAIN QUESTIONS (A), (B) AND (C) AS FORMULATED BY THE REVENUE AS THEY DO NOT RAISE ANY SUBSTANTIAL QUESTION S OF LAW. ACCORDINGLY, APPEAL IS DISMISSED WITH NO ORDER AS TO COSTS. 9. THE HONBLE BOMBAY HIGH COURT IN THE CASE OF CIT VS. DAULAL MOHTA (HUF) REPORTED IN 360 ITR 680 HAS HELD THAT REFERENCE TO DVO CAN ONLY BE MADE IN A CASE WHERE VALUE OF ASSET SHOWN BY THE ASSESSEE IS LESS THAN ITS FAIR MARKET VALUE OF THE LAND. 10. IN VIEW OF THE ABOVE BINDING PRECEDENTS OF THE HONBLE JURISDICTIONAL HIGH COURT AND CONSIDERING THE FACT THAT THE FAIR MARKET VALUE AS ON 01 - 04 - 1981 CLAIMED BY THE ASSESSEE ON THE BASIS OF THE REGISTERED VALUERS REPORT WAS MORE THAN THE FAIR MARKET VALUE SOUGHT TO BE ADOPTED BY THE AO, THEREFORE, NO REFERENCE COULD HAVE BEEN MADE BY THE AO U/S.55A OF THE ACT TO THE DVO. IN VIEW OF THE ABOVE DISCUSSION, I SET ASIDE THE ORDER OF THE CIT(A ) AND DIRECT THE AO TO DELETE THE ADDITION OF RS.11,91,040/ - . GROUNDS RAISED BY THE ASSESSEE ARE ACCORDINGLY ALLOWED. 8. THE ISSUE ARISING IN THE PRESENT APPEAL IS IDENTICAL TO THE ISSUE BEFORE THE TRIBUNAL IN CO - OWNER S CASE AND FOLLOWING THE SAME PARI TY OF REASONING, I FIND THERE IS NO MERIT IN COMPUTATION OF INCOME IN THE HANDS OF ASSESSEE AS DETERMINED BY THE ASSESSING OFFICER. THE REFERENCE MADE UNDER SECTION 55A ITA NO. 1 408 /PN/20 1 6 SHRI NARAYAN KESHAV KULKARNI 7 OF THE ACT BY THE ASSESSING OFFICER TO THE DVO TO DETERMINE THE FAIR MARKET VALUE OF P ROPERTY AS ON 01.04.1981 WHICH WAS WORKED OUT TO BE LESSER THAN TH E VALUE DECLARED BY THE ASSESSEE ON THE BASIS OF REGISTERED VALUERS REPORT, IS NOT WARRANTED. IN VIEW THEREOF, THE ORDER OF CIT(A) IS SET ASIDE AND THE ASSESSING OFFICER IS DIRECTED TO DELETE THE ADDITION MADE ON THIS ACCOUNT. THE GROUNDS OF APPEAL RAIS ED BY THE ASSESSEE ARE THUS, ALLOWED. 9 . IN THE RESULT, THE APPEAL OF ASSESSEE IS ALLOWED. ORDER PRONOUNCED ON THIS 18 TH DAY OF NOVEMBER , 201 6 . SD/ - (SUSHMA CHOWLA) / JUDICIAL MEMBER / ; / PUNE ; DATED : 18 TH NOVEMBER , 201 6 . GCVSR / COPY OF THE ORDER IS FORWARDED TO : 1. / THE APPELLANT ; 2. / THE RESP ONDENT; 3. ( ) / THE CIT(A) - 2 , PUNE ; 4. / THE PR. CIT - 1 , PUNE ; 5. 6. , , , - / DR SMC , ITAT, PUNE; / GUARD FILE . / BY ORDER , // TRUE CO PY // / SR. PRIVATE SECRETARY , / ITAT, PUNE