ITO 15(2)(2), MUMBAI V. JAWAHAR R. DHRONA, MUMBAI

ITA 142/MUM/2010

• Counselvise Citation: [2012] 119 COUNSELVISE.COM (IT) 8427 (ITAT-MUMBAI)
• Duration Of Justice: 2 year(s) 9 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-10-2012
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: I
• Next Hearing Date: 30-10-2012
• Assessment Year: 2005-2006
• Appeal Filed On: 07-01-2010
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: OM PRAKASH MEENA
• Assessee Lawyers: D V LAKHANI
• Keywords: Capital asset; Business income; Residential status; Permanent establishment
• Section: 14A; 10

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES I : MUMBAI BEFORE SHRI D.K.AGRAWAL, JUDICIAL MEMBER AND SHRI N.K.BILLAIYA, ACCOUNTANT MEMBER ITA. NO.142/MUM/2010 ASSESSMENT YEAR 2005-2006 INCOME TAX OFFICER 15(2)(2) MUMBAI 400 008 VS. SHRI JAWAHAR R. DHRONA MUMBAI 400 054 PAN AHAPD3141Q (APPELLANT) (RESPONDENT) ITA.NO. 143/MUM/2010 ASSESSMENT YEAR 2006-2007 A CIT - 15 ( 2 ) MUMBAI-400 008. VS. SHRI JAWAHAR R. DHRONA MUMBAI 400 054 PAN AHAPD3141Q (APPELLANT) (RESPONDENT) FOR REVENUE : SHRI OM PRAKASH MEENA (D.R.) FOR ASSESSEE : SHRI D.V.LAKHANI (A.R.) DATE OF HEARING : 30-10-2012 DATE OF PRONOUNCEMENT : 30-10-2012 ORDER PER N.K.BILLAIYA, A.M. BOTH THESE APPEALS BY THE REVENUE ARE DIRECTED AGAI NST THE TWO SEPARATE ORDERS OF THE CIT(A)-26, MUMBAI DATED 29-10-2009 PE RTAINING TO THE ASSESSMENT YEARS 2005-2006 AND 2006-2007. AS COMMON ISSUES ARE IN INVOLVED IN BOTH THE APPEALS THOUGH QUANTUM MAY DIF FER BOTH THE APPEALS ARE TAKEN-UP TOGETHER FOR THE SAKE OF CONVENIENCE. 2 2. ITA. NO. 142/MUM/2010 :- THE REVENUE IS AGGRIEVED BY THE ORDER OF THE CIT(A) WHO TREATED THE INCOME OF RS.16,87,326/- AS SHORT TERM CAPITAL GAIN INSTEAD OF BUSINESS INCOME AND GROUND NO.2 RELATES TO THE DIRECTION THAT ASSESSEE MAY BE TREATED AS A NON-RESIDENT. AS DECIS ION OF GROUND NO.2 WILL DECIDE THE FATE OF GROUND NO.1, THEREFORE, GROUND N O.2 IS TAKEN-UP FIRST. 3. IT IS THE SAY OF THE ASSESSEE THAT HE IS A NON-R ESIDENT INDIAN AND IT IS THE SAY OF THE ASSESSING OFFICER THAT ASSESSEE IS A RES IDENT. DURING THE COURSE OF THE APPELLATE PROCEEDINGS, IT IS SEEN THAT THE ASSE SSEE HAS FILED DETAILS IN RESPECT OF HIS STAY IN INDIA IN THE PREVIOUS YEAR A ND DURING THE YEAR PRECEDING TO PREVIOUS YEAR. THE CIT(A) AFTER CONSIDERING THE DETAILS FILED BY THE ASSESSEE CAME TO THE CONCLUSION THAT ASSESSEE IS A NON-RESID ENT INDIAN (NRI). IT IS THE SAY OF THE REVENUE THAT THE CIT(A) HAS GROSSLY ERRE D IN CONSIDERING THE SUBMISSION OF THE ASSESSEE WITHOUT PROVIDING ANY OP PORTUNITY TO THE ASSESSING OFFICER BY IGNORING THE FACTS THAT NO SUCH EVIDENCE S WERE PRODUCED BY THE ASSESSEE DURING THE ASSESSMENT PROCEEDINGS. 4. WE HAVE PERUSED THE ORDERS OF THE LOWER AUTHORIT IES AND ALSO THE PAPER BOOK SUBMITTED BY THE ASSESSEE. WE FIND THAT THE SU BMISSION OF THE D.R. HAS CONSIDERABLE FORCE AS NO DETAILS WERE PRODUCED BEFO RE THE ASSESSING OFFICER DURING THE COURSE OF ASSESSMENT PROCEEDINGS. THEREF ORE, IN THE INTEREST OF JUSTICE AND FAIR PLAY, WE RESTORE THIS ISSUE BACK T O THE FILE OF THE ASSESSING OFFICER. THE ASSESSING OFFICER IS DIRECTED TO VERIF Y THE DETAILS OF STAY OF THE ASSESSEE IN INDIA AND DECIDE AFRESH WHETHER THE ASS ESSEE STATUS IS OF RESIDENT OR NON-RESIDENT, AFTER GIVING A REASONABLE OPPORTUN ITY OF BEING HEARD TO THE ASSESSEE. 5. COMING BACK TO THE ISSUE INVOLVED IN GROUND NO.1 RELATING TO THE TREATMENT OF SHORT TERM CAPITAL GAIN AS BUSINESS IN COME BY THE ASSESSING OFFICER IN OUR CONSIDERED VIEW THE FINDING OF GROUN D NO.2 WOULD DECIDE THE FATE OF THIS ISSUE BECAUSE AS PER THE RBI DIRECTIONS NON -RESIDENT INDIAN HAVE TO TAKE DELIVERY OF THE SHARES AND GIVE DELIVERY OF THE SHA RES SOLD UNDER THE SCHEME 3 AND ARE NOT ALLOWED TO TRADE. THIS ASPECT HAS ALSO BEEN DEALT WITH AT LENGTH BY THE TRIBUNAL IN ITA.NO. 3229/MUM/2009 AND 3230/MUM/ 2009 IN THE CASE OF ITO VS. SHRI SALIL SEVANTILAL SHAH. WHEREAS THE TRI BUNAL AT PAGE 11 IN PARA 12 HAS HELD AS FOLLOWS : 12. ONE OF THE MOST IMPORTANT ASPECT IN FAVOUR OF THE ASSESSEE IS THAT THE ASSESSEE IS A NRI AND AS SUCH NOT ALLOWED TO TR ADE IN SHARES IN VIEW OF THE RBI REGULATIONS. ASSESSEE COULD HAVE POSSIBLY INVESTED IN SHARES AND THAT TOO THROUGH PORTFOLIO I NVESTMENT SCHEMES THROUGH CERTAIN AUTHORISED DEALERS. IN THE CASE OF FIDELITY NORTH STAR FUNDS & OTHERS IN-RE [SUPRA] FO LLOWING QUESTIONS WERE RAISED (I) WHETHER PROFITS FROM THE SALE OF PORTFOLIO INVESTME NTS IN INDIA WILL BE TREATED AS BUSINESS INCOME; (II) WHETHER THE APPLICANT COULD BE REGARDED AS HAVING A PERMANENT ESTABLISHMENT IN INDIA (III) IF THE INCOME IS FOUND TO BE IN THE NATURE OF BUSINESS INCOME WHETHER THE APPLICANT WILL BE TAXA BLE IN INDIA; AND (IV) WHETHER THE INCOME FROM THE PORTFOLIO INVEST MENTS WOULD BE TAXABLE IN INDIA AT THE FIXED RATE OF 20 PER CENT UNDER SECTION LL5ADOF THE INCOME TAX ACT, 1961. AND THE ANSWERS GIVEN BY THE AUTHORITIES ARE AS UND ER: (I) THAT THE TRANSACTIONS WERE ONLY IN THE N ATURE OF INVESTMENT IN CAPITAL ASSETS TO EARN CAPITAL GAINS BEC AUSE (A) THE WHOLE SCHEME MEANT FOR ELLS WAS TO INVEST IN SE CURITIES IN INDIA TO RECEIVE INCOME FROM THEM SO LONG AS THEY H OLD THE SAME AND REALIZE CAPITAL GAINS ON THEIR TRANSFER. (B) THE EXPRESSION INCOME RECEIVED IN RESPECT OF SECUR ITIES IN CL.(A) CONNOTES THE INCOME THEREFROM WHEN THE SECURITIES H ELD BY A FII ARE INTACT, E.G. DIVIDENDS. INTEREST, ETC. LIKE FR UITS FROM A TREE OR A 4 RENT FROM AN IMMOVABLE PROPERTY. THE TERM INCOME EMPLOYED THEREIN, HAVING REGARD TO THE CONTEXT, CAN, BY NO S TRETCH OF IMAGINATION, BE ASSUMED AS INCOME ARISING FROM THE TRANSFER OF SUCH SECURITIES FOR THE SIMPLE REASON THAT SUCH TYP E OF INCOME IS REFERRED TO IN CL. (B) WHERE THE INCOME IS SPECIFIE D AS BEING BY WAY OF SHORT-TERM AND LONG-TERM CAPITAL GAINS ARISI NG FROM THE TRANSFER OF SUCH SECURITIES. IT WAS AGAINST DEDUCTI ON OF EXPENDITURE SUCH AS BY WAY OF SALARY OF THE STAFF, ETC., EXPENDITURE IN OBTAINING LOANS AND PAYING INTEREST THEREON THAT PARLIAMENT GUARDED, BY PROVIDING IN CLAUSE (A) OF S ECTION 115AD(2) THAT NO DEDUCTION SHALL BE ALLOWED IN COMPUTING INCOME IN RESPECT OF SECURITIES REFERRED IN CLAUSE (A] OF SUB-SECTION [1). (C) THE PLETHORA OF LEGISLATIVE PROVISIONS UNMISTAKABLY POINTED OUT THAT AN FII WAS NOT REGISTERED FOR CARRYING ON TRAD E IN SECURITIES; IT COULD ONLY INVEST IN SECURITIES FOR THE PURPOSE OF EARNING INCOME BY WAY OF DIVIDENDS AND INTEREST AND REALIZ ING CAPITAL GAINS ON THEIR TRANSFER. TRADING IN SEC URITIES BY A FII WAS PROHIBITED. (D) IT WOULD BE PREPOSTEROUS TO IMPUTE AN INTENTION TO FIIS, WHO RESPONDED TO THE OFFER OF INVESTMENT IN SECURITIES IN RESPONSE TO THE GUIDELINES, GOT THEMSELVES REGISTERED UNDER THE SEBI REGULATIONS AND UNDERTOOK TO ABIDE BY THOSE REGULA TIONS THAT THEY WOULD, IN THE VERY FIRST STEP ITSELF, HAVE INT ENDED TO VIOLATE ALL THE LEGISLATIVE REQUIREMENTS WHICH PROVIDED THE M THE OPPORTUNITY TO ENTER THE CAPITAL MARKET IN INDIA. (II) THAT THEREFORE, THE QUESTION DID NOT REQUIRE ANY RULING. THERE IS NO SCOPE FOR READING THE SEBI (FOREIGN INS TITUTIONAL INVESTORS) REGULATIONS, 1995,AS PERMITTING TRADING IN SECURITIES. THE SECURITIES. THE EXPRESSION OR OTHERWISE DEAL I N IN REGULATION 3(1) MEANS OTHER THAN BUYING AND SELLING, E.G. LEND ING/BORROWING PERMITTED UNDER REGULATION 15(8). IT CANNOT BE UNDE RSTOOD TO MEAN DOING BUSINESS IN SECURITIES BECAUSE TRADING I TSELF INVOLVES BUYING AND SELLING AND IF IT IS CONSTRUED TO MEAN T HE EXPRESSION BECOMES OTIOSE. REGULATION 15A OF SEBI REGULATIONS PERMITS DEALING IN OFFSHORE DERIVATIVE INSTRUMENTS ONLY AND NONE OTHER. THE WORDS TRANSACT BUSINESS AND THE TRANSACTION OF BUSINESS IN CLAUSES (A) AND (C) RESPECTIVELY OF SUB-REGULATI ON (3) OF REGULATION 15 POSTULATE TRANSACTION OF SALE AND PUR CHASE, THEY DO NOT REFER, AS SUCH, TO THE TRADING ACTIVITY. TRANSA CTING BUSINESS IS 5 DIFFERENT AND DISTINGUISHABLE FROM CARRYING ON BUSI NESS. TRANSACT BUSINESS IS A GENERAL TERM WHICH REFERS TO CARRYING ON ALL TYPES OF ACTIVITIES WHEREAS BUSINESS TRANSACTION REFERS TO O NLY COMMERCIAL TRADING ACTIVITIES. THESE WORDS AND EXPRESSIONS, IN THE CONTEXT IN WHICH THEY ARE USED, DO NOT DEAL WITH THE SUBJECT O F TRADING IN SECURITIES MUCH LESS DO THEY PERMIT ACTIVITIES OF T RADING IN SECURITIES BY A FII. IN THE CASE BEFORE US ALSO THE RBI HAS ISSUED THE F OLLOWING DIRECTIONS WHICH HAVE BEEN INTIMATED TO THE ASSESSEE BY HDFC B ANK THROUGH THEIR LETTER WHICH HAS BEEN FILED BEFORE US. NRIS / OCBS HAVE TO TAKE DELIVERY OF THE SHARES /C ONVERTIBLE DEBENTURES AND GIVE DELIVERY OF THE SHARES/ CONVERT IBLE DEBENTURE SOLD UNDER THE SCHEME AND ARE NOT ALLOWED TO TRADE. THE ABOVE CLEARLY SHOWS THAT WHEN AS PER THE SEBI R EGULATIONS (IN THE CASE BEFORE US RBI REGULATIONS) THE ASSESSEE WAS NO T PERMITTED TO DO IN TRADING THEN GAINS RECEIVED FROM SALE AND PURCHA SE OF SHARES CAN BE ONLY TAXED AS CAPITAL GAINS. 6. RESPECTFULLY FOLLOWING THE FINDINGS OF THE TRIBU NAL (SUPRA), WE RESTORE THIS ISSUE BACK TO THE FILE OF THE ASSESSING OFFICER. TH E ASSESSING OFFICER IS DIRECTED TO DECIDE THIS ISSUE AFTER GIVING A FINDING ON THE RESIDENTIAL STATUS OF THE ASSESSEE IF THE ASSESSEE HAPPENS TO BE A NON-RESIDE NT, THEN THE INCOME HAS TO BE TREATED UNDER THE HEAD CAPITAL GAINS. ACCORDIN GLY, GROUND NO. 1 AND 2 ARE ALLOWED FOR STATISTICAL PURPOSES. 7. GROUND NO.3 RELATES TO THE ALLOWANCE OF DIVIDEND INCOME OF RS.1,59,109/- AS EXEMPT FROM TAX UNDER SECTION 10 ( 34). IT IS SEEN FROM THE ASSESSMENT ORDER THAT THE ASSESSING OFFICER HAS TRE ATED THE DIVIDEND RECEIVED BY THE ASSESSEE AS HIS BUSINESS INCOME. BECAUSE OF THE OPINION OF THE ASSESSING OFFICER, AS THE ASSESSEE IS TRADING IN SH ARES, THE DIVIDEND INCOME OF SUCH SHARES AND SECURITIES ARE ALSO PART AND PARCEL OF THE BUSINESS INCOME. WHEN THIS MATTER WAS AGITATED BEFORE THE CIT(A), TH E LEARNED CIT(A) GAVE A 6 CATEGORICAL FINDING THAT DIVIDEND INCOME IS EXEMPT UNDER SECTION 10 (34) OF THE ACT. 8. WE HAVE CONSIDERED THE ORDERS OF THE LOWER AUTHO RITIES AS THE CIT(A) HAS RIGHTLY HELD THAT DIVIDEND INCOME IS EXEMPT UNDER S ECTION 10 (34) OF THE ACT WE DO NOT FIND ANY REASON TO INTERFERE WITH THE FINDIN GS OF THE CIT(A) WHICH ARE UPHELD. GROUND NO.3 IS ACCORDINGLY DISMISSED. 9. GROUND NO.4 RELATES TO THE DELETION OF RS.6,30,0 00/- MADE BY THE ASSESSING OFFICER UNDER SECTION 69B OF THE ACT. DUR ING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER NOTIC ED THAT THE ASSESSEE HAS MADE INVESTMENT IN SHARES OF TATA CONSULTANCY SERVI CES LTD. TO THE TUNE OF RS.6,30,000/-. ACCORDING TO THE ASSESSING OFFICER, THIS AMOUNT IS NOWHERE REFLECTED IN THE BOOKS OF ACCOUNTS MAINTAINED BY TH E ASSESSEE. IT IS THE SAY OF THE ASSESSING OFFICER THAT PARTICULARS WERE GIVEN T O THE ASSESSEE, SO THAT HE COULD GIVE COMPLETE BREAK-UP OF THE INVESTMENTS MAD E IN SHARES AND SECURITIES. HOWEVER, DURING THE YEAR THE ASSESSEE H AS NOT GIVEN TRUE DETAILS OF INVESTMENT. IN THE ABSENCE OF ANY SUPPORTING EVIDEN CE OF INVESTMENT MADE IN SHARES OF TCS THE ASSESSING OFFICER WENT ON TO ADD A SUM OF RS.6,30,000/- UNDER SECTION 69B OF THE ACT. DURING THE APPELLATE PROCEEDINGS, THE ASSESSEE FILED BANK STATEMENT OF STANDARD CHARTERED BANK BEA RING ACCOUNT NO.23110014329 AND STATED THAT THE MONEY HAS BEEN W ITHDRAWN FROM THIS BACK ACCOUNT AND THE DEBIT IS DULY REFLECTED IN THE BANK STATEMENT. IT IS THE SAY OF THE ASSESSEE THAT HE HAS APPLIED FOR 700 SHARES OF TCS AT THE PRICE OF RS.900/- PER SHARE. HOWEVER, THE ASSESSEE WAS ALLOT TED 37 SHARES @ RS.850/- PER SHARE AND THE BALANCE AMOUNT OF RS.5,98,550/- W AS REFUNDED BY THE COMPANY TO THE ASSESSEE. IT WAS POINTED OUT BY THE ASSESSEE BEFORE THE CIT(A) THAT THE REFUND AMOUNT IS ALSO REFLECTED IN THE BAN K STATEMENT WITH HSBC. THE CIT(A) AFTER CONSIDERING THE FACTS AND EVIDENCES SU BMITTED BY THE ASSESSEE CAME TO THE CONCLUSION THAT THE ASSESSEE HAS CLEARL Y SHOWN THE SOURCE OF INVESTMENT AND THEREFORE, THERE IS NO REASON TO SUS TAIN THE ADDITION OF 7 RS.6,30,000/- AND ACCORDINGLY, DELETED THE ADDITION MADE BY THE ASSESSING OFFICER. 10. BEFORE US, LEARNED D.R. STRONGLY CONTENDED THAT THE CIT(A) HAS CONSIDERED THE EVIDENCES WHICH WERE NEVER BEFORE TH E ASSESSING OFFICER. ATLEAST THE CIT(A) SHOULD HAVE CALL FOR A REMAND REPORT BY GIVING AN OPPORTUNITY TO THE ASSESSING OFFICER TO EXAMINE ALL THESE EVIDENCES. 11. PER CONTRA, THE COUNSEL SUBMITTED THAT THE ASSE SSING OFFICER DID NOT GIVE ANY OPPORTUNITY TO THE ASSESSEE TO EXPLAIN HIS CASE . 12. AFTER HEARING BOTH THE PARTIES, IN OUR HUMBLE O PINION, THE CIT(A) ERRED IN ADJUDICATING THE ISSUE BY ADMITTING ADDITIONAL EVID ENCE. IN THE INTEREST OF JUSTICE AND FAIR PLAY, WE RESTORE THIS ISSUE BACK T O THE FILE OF THE ASSESSING OFFICER. THE ASSESSEE IS DIRECTED TO FURNISH THE BA NK STATEMENTS TO SUBSTANTIATE HIS CLAIM THAT INVESTMENT HAS BEEN MADE FROM THE BA NK ACCOUNT. THE ASSESSING OFFICER IS DIRECTED TO VERIFY ALL THE DET AILS SUBMITTED BY THE ASSESSEE, AFTER GIVING A REASONABLE OPPORTUNITY OF BEING HEAR D. GROUND NO.4 IS ALLOWED FOR STATISTICAL PURPOSES. 13. IN THE RESULT, APPEAL OF THE REVENUE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES. 14. ITA. NO. 143/MUM/2010 :- ISSUES RAISED BY GROUND NO. 1 AND 2 ARE IDENTICAL TO THAT OF ISSUES RAISED IN GROUND NO.1 A ND 2 OF ITA.142/MUM/2010 FOR THE ASSESSMENT YEAR 2005-2006. FOLLOWING OUR FI NDINGS IN THE SAID APPEAL, WE RESTORE THIS ISSUE BACK TO THE FILE OF THE ASSES SING OFFICER TO BE DECIDE AS PER THE DIRECTIONS GIVEN IN ITA.NO.142/MUM/2010. 15. GROUND NO.3 RELATES TO THE DELETION OF ADDITION OF RS.25,000/- MADE BY THE ASSESSING OFFICER BY INVOKING SECTION 14A. DURI NG THE COURSE OF THE ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER NOTIC ED THAT THE ASSESSEE HAS EARNED DIVIDEND INCOME AMOUNTING TO RS.1,15,753/-. THE ASSESSING OFFICER WAS OF THE OPINION THAT SOME PORTION OF EXPENSES PE RTAIN TO TAX FREE INCOME AND 8 ACCORDINGLY DISALLOWED A SUM OF RS.25,000/- INVOKIN G THE PROVISIONS OF SECTION 14A OF THE ACT. 16. BEFORE THE CIT(A), ASSESSEE CONTENDED THAT THE INCOME GENERATED FROM THE INVESTMENT IN SHARES HAS BEEN TAKEN AS CAPITAL GAINS AND NO EXPENDITURE IS ATTRIBUTABLE FOR EARNING DIVIDEND OF RS.1,15,753/-. AFTER CONSIDERING THE FACTS AND SUBMISSIONS OF THE ASSESSEE, THE LEARNED CIT(A) DELETED THE ADDITION HOLDING THAT AS THE INCOME FROM SHARE TRANSACTIONS HAS BEEN HELD AS CAPITAL GAINS, ANY DISALLOWANCE WILL HAVE NIL EFFECT IN RES PECT OF CORRECT HEADS OF INCOME. THE CIT(A) FURTHER HELD THAT THE ASSESSING OFFICER HIMSELF HAS ADMITTED IN PARA 7 OF THE ASSESSMENT ORDER THAT THE DIVIDEND INCOME IS RECEIVED FROM LONG TERM INVESTMENT. 17. WE HAVE CAREFULLY PERUSED THE ORDERS OF THE LOW ER AUTHORITIES AND FIND THAT DIVIDEND HAS BEEN RECEIVED FROM INVESTMENT MAD E IN EARLIER YEARS. ON THAT, NOTE WE DO NOT FIND ANY INFIRMITY IN THE FIND ING OF THE LEARNED CIT(A) AND IT IS CONFIRMED. GROUND NO.3 IS DISMISSED. 18. IN THE RESULT, APPEAL OF THE REVENUE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 30 TH DAY OF OCTOBER, 2012. SD/- SD/- (D.K.AGRAWAL) (N.K.BILLAIYA) JUDICIAL MEMBER ACCOUNTANT MEMBER MUMBAI, DATE 30 TH OCTOBER, 2012 VBP/- 9 COPY TO 1. INCOME TAX OFFICER 15(2)(2), MATRU MANDIR, ROOM NO. 110, TARDEV, MUMBAI 400 008. 2. SHRI JAWAHAR R. DHRONA, 14 - RAJSHREE BLDG., DATTATRAY ROAD, N.RELIANCE VB WORLD, SANTACRUZ (W), MUMBAI 400 054 PAN AHAPD3141Q 3. CIT(A) - 26 , MUMBAI. 4. CIT , CITY - 15 , MUMBAI 5. DR I BENCH 6. GUARD FILE (TRUE COPY) BY ORDER ASST. REGISTRAR, I.T.AT. MUMBAI BENCHE S MUMBAI.