Akaar Foundaries Pvt. Ltd., Bangalore V. The Addl. Commissioner of Income Tax, Range-1., Belgaum

ITA 142/PAN/2014

• Counselvise Citation: 14224114 RSA 2014
• Duration Of Justice: 10 month(s) 9 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 04-03-2015
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Next Hearing Date: 19-02-2015
• Assessment Year: 2006-2007
• Appeal Filed On: 25-04-2014
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: ANAND S MARATHE
• Keywords: Unexplained investment; Sale consideration of property below Jantri Value; Capital asset; Fair market value; Valuation report
• Section: 143(3); 50C; 37

Judgement Text

1 IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH, PANAJI BEFORE SHRI P. K. BABNSAL, HONBLE ACCOUNTANT MEMBER AND SHRI D.T. GARASIA, HONBLE JUDICIAL MEMBER ITA NO. 142 / PNJ /2014 (ASST. YEAR : 200 6 - 0 7 ) AKAAR FOUNDARIES PVT. LTD. , M - 31, INDUSTRIAL ESTATE, UDYAMBAG, BELGAUM. VS. A CIT, RANGE - 1, BELGAUM. PAN NO. AACCA 3753 D (APPELLANT) (RESPONDENT) ASSESSEE BY : NONE. DEPARTMENT BY : SHRI ANAND S. MARATHE - D R DATE OF HEARING : 19 / 0 2 /2015 . DATE OF PRONOUNCEMENT : 04 / 0 3 /201 5 . O R D E R PER D.T. GARASIA , J .M THIS IS AN APPEAL BY THE ASSESSEE AGAINST THE ORDER OF LD. CIT (A), BELGAUM DATED 11 /0 2 /201 4 FOR THE A.Y. 200 6 - 0 7 . 2. THE FOLLOWING GROUNDS ARE RAISED BY THE ASSESSEE : - 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LEARNED COMMISSIONER OF INCOME - TAX (APPEALS) ERRED IN PASSING THE ORDER IN THE MANNER HE DID. 2. THE COMMISSIONER (A) OUGHT TO HAVE APPRECIATED THAT THE APPELLANT HAVING DISPUTED THE VALUATION OF THE PROPERTY BY 2 THE STAMP VALUATION AUTHORITY, THE ADOPTIO N OF THE VALUE IN TERMS OF SEC.50 C OF THE ACT BY THE ASSESSING AUTHORITY WAS BAD IN LAW. 3. THE C OMMISSIONER (A) OUGHT TO HAVE APPRECIATED THAT THE VALUE ADOPTED BY THE APPELLANT WAS FAIR MARKET VALUE CONSIDERING THE FACTS AND CIRCUMSTANCES AND THE LOCATION OF THE PROPERTY AND THEREFORE THE SAME WAS REQUIRED TO BE ADOPTED. 4. THE COMMISSIONER (A) OUGHT TO HAVE APPRECIATED THAT THE DECISIONS RELIED UPON BY THE APPELLANT WERE SQUARELY APPLICABLE AND HE OUGHT TO HAVE FOLLOWED THE SAME. 5. THE COMMISSIONER (A) ERRED IN CONFIRMING THE INTEREST CHARGED U/S.234B AND 234C OF THE ACT. 6. FOR THESE AND OTHER GROUNDS THAT MAY BE URGED AT THE TIME OF HEARING OF THE APPEAL, THE APPELLANT PRAYS THAT THE APPEAL MAY BE ALLOWED. 3. SHORT FACTS OF THE CASE ARE THAT THE ASSESSEE IS A PRIVATE LIMITED COMPANY, ENGAGED IN MANUFACTURING OF CI CASTING. THE ASSESSEE HAS FILED THE RETURN OF INCOME ON 31/03/2007 DECLARING TOTAL INCOME OF RS. 47,30,160/ - . ASSESSMENT WAS CONCLUDED U/S. 143(3) OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO AS THE 'ACT', FOR SHORT) . THE ASSESSEE , DURING THE YE AR UNDER CONSIDERATION , SOLD A LAND FOR A CONSIDERATION OF RS. 61 LAC. IT WAS VALUED AT RS. 92.65 LAC. AS PER THE STAMP VALUATION AUTHORITY (SVA) FOR STAMP DUTY PURPOSES. A SSESSEE HAS TRANSFERRED THE LAND TO THE KARNATAKA RURAL EDUCATIONAL TRUST, BANGALORE FOR A TOTAL CONSIDERATION OF RS. 61 LAC. AND ACCORDINGLY COMPUTED THE LONG TERM CAPITAL GAIN OF RS. 42,83,166/ - AND THE SAME 3 WAS DECLARED AS LONG TERM CAPITAL GAIN . AT THE REQUEST OF THE ASSESSEE, A REFERENCE WAS MADE BY THE ASSESSING OFFICER TO THE DEPARTMENTAL VALUATION OFFICER (DVO) FOR DETERMIN IN G THE VALU E OF THE LAND. THE DVO DETERMINED FAIR MARKET VALUE ( FMV) OF THE LAND AT RS. 1,50,11,400/ - . THE ASSESSING OFFICER AFTER OBTAINING THE REPORT, A SHOW - CAUSE NOTICE WAS GIVEN TO THE ASSESSEE AND AFTER SHOW - CAUSE NOTICE, THE ASSESSING OFFICER HAS RECOURSE TO THE PROVIS I ONS OF SEC. 50C(3) OF THE ACT ADOPTED AND THE VALUE DETERMINED BY THE SVA FOR COMPUTING THE CAPITAL GAIN TAX . ACCORDINGLY, THE ASSESSING OFFICER COMPUTED THE CAPITAL GAIN TAX AT RS. 74, 48,166/ - . 4 . MATTER WAS CARRIED TO THE LD. CIT(A) AND LD. CIT(A) HAS DISMISSED THE APPEAL BY OBSERVING AS UNDER: - I HAVE CAREFULLY CONSIDERED THE FACTS OF THE CASE, SUBMISSIONS MADE BY THE APPELLANT AND ALSO PERUSED THE ASSESSMENT ORDER. THE LAND SOLD BY THE ASSESSEE FOR A CONSIDERATION OF RS.61/ - LAKHS BY THE APPELLANT WAS VALUED AT RS.92.65 LAKHS BY THE STAMP VALUATION AUTHORITY FOR STAMP DUTY PURPOSES. AT THE REQUEST OF THE APPELLANT, A R EFERENCE WAS MADE BY THE A.O TO THE DEPARTMENTAL VALUATION OFFICER U/S 50C(2) FOR DETERMINING THE VALUATION OF THE LAND. THE D.V.O. VIDE HIS ORDER DATED 17.12.2008 DETERMINED THE FMV OF THE ABOVE PROPERTY AT RS.1,50,11,400/ - WHICH WAS OBJECTED TO BE THE AP PELLANT BEFORE THE A.O. HOWEVER, AS PER THE PROVISIONS OF SECTION 50C(3),THE A.O ADOPTED THE VALUE DETERMINED BY THE STAMP VALUATION AUTHORITY FOR COMPUTING THE CAPITAL GAINS TAX. ACCORDINGLY, THE ASSESSING OFFICER COMPUTED THE CAPITAL GAINS TAX AT RS.74,4 8,166/ - . THE APPELLANT HAS AGAIN DURING THE APPELLATE PROCEEDINGS OBJECTED TO THE ADOPTION OF VALUE OF LAND AS DETERMINED BY THE STAMP VALUATION OFFICER, HOWEVER, NO COGENT REASONS OR EVIDENCE FOR THAT HAS BEEN FURNISHED BY THE ASSESSEE. THE APPELLANT HAS ALREADY AVAILED THE REMEDY AVAILABLE TO IT UNDER THE LAW I.E SECTION 50C(2) 4 AND AT THE APPELLANT'S REQUEST, THE MATTER WAS REFERRED TO THE DVO BY THE A.O. AS PER THE PROVISIONS OF SECTION 50C(3), THE A.O HAS ADOPTED THE VALUE OF SVO AND NOT OF THE DVO, THE LATTER BEING HIGHER. THE APPELLANT HAS NOT POINTED OUT THE DEFECTS IN THE DVO'S REPORT OR IN THE SVO'S VALUATION AND NO EVIDENCE WHATSOEVER HAS BEEN FURNISHED BY THE APPELLANT TO BUTTRESS ITS CASE. THEREFORE, THE DECISION OF THE A.O BEING AS PER LAW IS UP HELD AND THE ADDITION MADE BY HIM IS CONFIRMED. 5. THE ASSESSEE DID NOT REMAIN PRESENT, BUT FILE THE WRITTEN SUBMISSIONS WHICH READ AS UNDER: - THE APPELLANT IS A PRIVATE LIMITED COMPANY AND IS ENGAGED IN MANUFACTURE OF CI - CASTING. THE APPELLANT FILED E - RETURN OF INCOME ON 31.03.2007 DECLARING A TOTAL INCOME OF RS.47,30,160/ - . THE ASSESSING AUTHORITY CONCLUDED THE ASSESSMENT BY MAKING AN ADDITION OF RS.74,48,166/ - ON ACCOUNT OF LONG TERM CAPITAL GAINS APART FROM OTHER ADDITIONS. THE APPELLANT HAD SOLD THE PROPERTY BELONGING TO HIM FOR A SALE CONSIDERATION OF RS.61 LAKHS BUT THE STAMP VALUE AUTHORITY (SVO) ADOPTED A VALUE OF RS.92.65 LAKHS FOR THE PURPOSE OF STAMP DUTY CALCULATION. THE APPELLANT HAD ADOPTED THE VALUE WHICH IS THE FMV AND WHAT THE SIMILAR LAND FETCHES IN THE OPEN MARKET. THIS WA S ALSO SUPPORTED BY THE VALUATION REPORT OF THE GOVERNMENT APPROVED VALUER WHO HAD TAKEN SIMILAR LAND UNTO CONSIDERATION WHILE VALUING THE LAND. THIS LAND WAS A KIADB APPROVED AND ALLOTTED USEFUL ONLY FOR INDUSTRIES PURPOSE, KIADB AS NARRATED IN THE REPOR T HAD ALLOTTED LAND @ RS.13.50 LAKH PER ACRE DURING 2005 WHICH PROVES THAT THE VALUE OF THE LAND WAS ONLY RS.13.50 LAKHS PER ACRE AND AS THE LAND IS APPROXIMATELY 4 ACRES IT IS NEARLY RS.60 LAKHS. THE VALUATION REPORT OF THE DVO IS THEREFORE NOT ACCEPTABLE AS THE COMPARABLES WERE NOT CORRECT. THE AO REMITTED THE CASE TO DVO FOR THE VALUATION OF THE PROPERTY WHO VALUED IT AT RS. 1.50 CRORES. THE ASSESSING AUTHORITY TOOK THE VIEW THAT AS THE DEPARTMENTAL VALUATION OFFICER (DVO FOR SHORT) VALUE IS GREATER THA N SVO'S VALUE, THEREFORE SVO VALUE SHOULD BE DEEMED TO BE FULL VALUE CONSIDERATION OF THE PROPERTY SOLD AND CALCULATED LONG TERM CAPITAL GAINS ON SUCH VALUE ADOPTED BY SVO AND MADE THE ABOVE ADDITION. 5 AGGRIEVED BY THE ABOVE ORDER THE APPELLANT FILED AN AP PEAL BEFORE THE CIT(A), BELGAUM. THE APPELLANT SUBMITTED BEFORE THE CIT(A) THAT THE VALUE ADOPTED BY THE SVO AND DVO WERE BASED ON GENERAL FACTORS WHEREAS THE VALUE OF THE PROPERTY DECLARED BY THE APPELLANT WAS THE ACTUAL CONSIDERATION AND THERE WAS NO CON SIDERATION RECEIVED OVER AND ABOVE IT. THE APPELLANT ALSO GOT THE PROPERTY VALUED BY A GOVERNMENT APPROVED VALUER WHO AFTER CONSIDERING VARIOUS FACTORS OF THE PROPERTY SUCH AS AREA OF THE PROPERTY, LOCATION, DEVELOPABLE AREA AS PER GOVERNMENT RULES ETC., CONCLUDED THAT THE VALUE IS RS.60 LAKHS. ALL THE DETAILS WERE FURNISHED BEFORE THE CIT(A) VIDE WRITTEN SUBMISSION AS ATTACHED. THE CIT(A) IN HIS ORDER DID NOT ACCEPT THE CONT ENTION OF THE APPELLANT BUT INSTEAD ALSO GAVE A FINDING THAT 'THE APPELLANT HAS NOT POINTED OUT THE DEFECTS IN THE DVO'S REPORT OR IN THE SVO'S VALUATION AND NO EVIDENCE WHATSOEVER HAS BEEN FURNISHED BY THE APPELLANT TO BUTTRESS ITS CASE.'. WHEREAS THIS IS NOT CORRECT AS THE APPELLANT HAS SUBMITTED A WRITTEN SUBMISSION AS ENCLOSED ALONG WITH SUPPORTING DOCUMENTS AND CASE LAW. THEREFORE, THIS APPEAL BEFORE THE HON'BLE ITAT. THE APPELLANT SUBMITS HEREIN THAT DVO'S VALUATION IS NOT ACCEPTABLE AS IT IS BASED ON VERY GENERAL ASPECTS AND NOT ON SPECIFIC PROPERTY BASIS. THE COMPARABLE TAKEN BY THE DVO WAS ALSO VERY VAGUE AND UNCOMPARABLE AS THIS PROPERTY WAS MORE THAN 4 ACRES AND THE COMPARED PROPERTY WAS ONLY 18 GUNTAS PLOT WHERE THE AREA IS BIG, A LOT OF SPACE GO ES UNTO DEVELOPMENT OF ROADS AND OTHER AMENITIES WHICH IS NOT CONSIDERED. AND FOR OTHER REASONS AS STATED IN THE WRITTEN SUBMISSION BEFORE THE CIT(A) ATTACHED. ALSO THE LAND WAS ALLOTTED BY KIADB WHO HAD ALLOTTED SIMILAR LANDS AT RS.13.5 LAKHS PER ACRE IN THE YEAR 2005. THE APPELLANT ALSO DOES NOT ACCEPT THE SVO VALUATION AS IT IS BASED ON GENERAL ASPECTS AND ONLY TO CALCULATE STAMP DUTY WHEREAS SEC.SOC TALKS ABOUT FAIR MARKET VALUE AND FMV AS PER GOVERNMENT APPROVED VALUER IS ONLY RS.60 LAKHS. THERE IS ALS O NO EVIDENCE TO PROVE THAT THE APPELLANT HAS RECEIVED EXCESS CASH OR CONSIDERATION. THEREFORE, THE VALUE CANNOT BE ENHANCED. THE APPELLANT PLACES RELIANCE ON THE ATTACHED CASE LAWS AND PLEADS THE HON'BLE ITAT TO GRANT RELIEF IN THE INTEREST OF JUSTICE AND EQUITY. 6. LEARNED DR SUBMITTED THAT THE ASSESSEE HAS VALUED THE FMV OF THE LAND ON THE BASIS OF KIADB REPORT, IN WHICH VALUE OF THE LAND HAS 6 BEEN MENTIONED A S RS. 60 LAC. THE ASSESSEE SOLD THE LAND FOR A CONSIDERATION OF RS. 61 LAC., BUT THE SVA VALUED THE SAME AT RS. 92.65 LAC. FOR THE PURPOSE OF STAMP DUTY CALCULATION . WITH THE INSTANCE OF THE ASSESSEE, MATTER WAS REFERRED TO DVO, WHO VALUED THE PROPERTY AT RS. 1.50 CRORES. THE ASSESSING OFFICER HAS TAKEN RECOURSE TO THE PROVISIONS OF SEC. 50 C(3) OF THE ACT AND ADOPTED THE VALUE DETERMINED BY THE SVA AT RS. 92.65 LAC. LEARNED DR SUBMITTED THAT AS PER SEC. 50C(3) OF THE ACT, THE VALUATION ADOPTED BY THE VALUATION OFFICER HAS TO BE TAKEN AS FMV, UNLESS THE MATTER IS REPORTED TO DVO AND THE DVOS VALUATION WOULD BE A FINAL . AS PER SEC. 50C(1) OF THE ACT, IF THE ASSESSEE TRANSFERS ANY CAPITAL ASSET, BEING LAND OR BUILDING, THE VALUE DECIDED BY THE SVA FOR THE PURPOSE OF P AYMENT OF STAMP DUTY IN RESPECT OF SUCH TRANSFER, THE VALUE SO ADOPTED OR ASSESSED SHALL FOR THE PURPOSES OF SECTION 48, BE DEEMED TO BE THE FULL VALUE OF THE CONSIDERATION RECEIVED OR ACCRUING AS A RESULT OF SUCH TRANSFER . SUB - SECTION (2) OF SEC. 50C PROVIDES THAT IF THE ASSESSEE OBJECTED TO THE ASSESSED BY THE SVA , THEN THE MATTER HAS TO BE REFERRED TO THE DVO AND THE VALUATION BY DVO HAS TO BE TAKEN AS FMV FOR SUCH TRANSFER. IF THE ASSESSEE DID NOT DISPUTE THE VALUE OF SVA IN ANY APPEAL OR REVIS ION, THE VALUATION OF THE SVA BECOMES FINAL. THEREFORE, IN THIS CASE, THE 7 ASSESSING OFFICER HAS TAKEN THE FMV AS DECIDED BY THE SVA, THEREFORE THE ASSESSING OFFICER AND THE LD. CIT(A) ARE JUSTIFIED IN THEIR ACTION. 7. WE HAVE HEARD RIVAL CONTENTIONS OF BOTH THE PARTIES. IT IS RELEVANT TO QUOTE SEC. 50C WHICH READS AS UNDER: - 50C. (1) WHERE THE CONSIDERATION RECEIVED OR ACCRUING AS A RESULT OF THE TRANSFER BY AN ASSESSEE OF A CAPITAL ASSET, BEING LAND OR BUILDING OR BOTH, IS LESS THAN THE VALUE ADOPTED OR ASSESSED [OR ASSESSABLE] BY ANY AUTHORITY OF A STATE GOVERNMENT (HEREA FTER IN THIS SECTION REFERRED TO AS THE 'STAMP VALUATION AUTHORITY' ) FOR THE PURPOSE OF PAYMENT OF STAMP DUTY IN RESPECT OF SUCH TRANSFER, THE VALUE SO ADOPTED OR ASSESSED [OR ASSESSABLE] SHALL, FOR THE PURPOSES OF SECTION 48 , BE DEEMED TO BE THE FULL VALUE OF THE CONSIDERATION RECEIVED OR ACCRUING AS A RESULT OF SUCH TRANSFER. (2) WITHOUT PREJUDICE TO THE PROVISIONS OF SUB - SECTIO N (1), WHERE (A) THE ASSESSEE CLAIMS BEFORE ANY ASSESSING OFFICER THAT THE VALUE ADOPTED OR ASSESSED [OR ASSESSABLE] BY THE STAMP VALUATION AUTHORITY UNDER SUB - SECTION (1) EXCEEDS THE FAIR MARKET VALUE OF THE PROPERTY AS ON THE DATE OF TRANSFER; (B) THE VALUE SO ADOPTED OR ASSESSED [OR ASSESSABLE] BY THE STAMP VALUATION AUTHORITY UNDER SUB - SECTION (1) HAS NOT BEEN DISPUTED IN ANY APPEAL OR REVISION OR NO REFERENCE HAS BEEN MADE BEFORE ANY OTHER AUTHORITY, COURT OR THE HIGH COURT, THE ASSESSING OFFICER MAY REFER THE VALUATION OF THE CAPITAL ASSET TO A VALUATION OFFICER AND WHERE ANY SUCH REFERENCE IS MADE, THE PROVISIONS OF SUB - SECTIONS (2), (3), (4), (5) AND (6) OF SECTION 16A, CLAUSE (I) OF SUB - SECTION (1) AND SUB - SECTIONS (6) AND (7) OF SECTION 23A, SUB - SECTION (5) OF SECTION 24, SECTION 34AA, SECTION 35 AND SECTION 37 OF THE WEALTH - TAX ACT, 1957 (27 OF 1957), SHALL, WITH NECESSARY MODIFICATIONS, APPLY IN RELATION TO SUCH REFERENCE AS THEY APPLY IN RELATION TO A REFERENCE MADE BY THE ASSESSING OFFICER UND ER SUB - SECTION (1) OF SECTION 16A OF THAT ACT. FROM THE ABOVE SECTION, IT IS CLARIFIED THAT THE ASSESSING OFFICER HAS TO ADOPT THE VALUE OF THE SVA AS FMV , FOR THE PURPOSE S OF PAYMENT OF 8 STAMP DUTY IN RESPECT OF SUCH TRANSFER , THE VALUE SO ADOPTED OR ASSESSED SHALL FOR THE PURPOSES OF SECTION 48 BE DEEMED TO BE THE FULL VALUE OF CONSIDERATION RECEIVED OR ACCR U ING AS A RESULT OF SUCH TRANSFER. SUB - SEC. (2) OF SEC. 50C PROVIDES THAT IF ANYBODY OBJECTS , THEN THE MATTER SHOULD BE REFERRED TO DVO. ON SUCH REFERENCE, IF THE VALUE DETERMINED BY THE DVO IS MORE THAN THE VALUE ADOPTED OR ASSESSED BY THE SVA, THE ASSESSING OFFICER SHALL ADOPT THE MARK E T VALUE AS DETERMINED BY THE SVA. IN THE INSTANT CASE, THE ASSESSEE HAS REQUESTED THE ASSESSING OFFICE R FOR REFER RING THE MATTER TO DVO WHEREIN THE ASSESSEE WAS GIVEN SHOW - CAUSE NOTICE AND THEREAFTER DVO HAS MADE HIS REP O RT . WE FIND THAT IN THE INSTANT CASE, THE VALUATION ASSESSED BY SVA IS AT RS. 92.65 LAC. WHEREIN THE DVOS VALUE AT RS. 1.50 C RORE. SO, ASSESSING OFFICER ADOPTED THE VALUE DECLARED BY SVA. WE FIND THAT THE ASSESSING OFFICER IS JUSTIFIED IN HIS ACTION. WE HAVE GONE THROUGH THE JUDGMENT OF HONBLE PUNJAB & HARYANA HIGH COURT IN THE CASE OF CIT VS. SMT. SHWETA BHUCHAR REPORTED IN (2010) 192 TAXMAN 67, IN WHICH THE HONBLE HIGH COURT HAS HELD THAT IF THE ADDITION HAS TO BE MADE ON ACCOUNT OF UNEXPLAINED INVESTMENT IN PURCHASE OF PROPERTY, THE ASSESSING OFFICER SHOULD MAKE A REFERENCE TO THE VALUATION OFFICER IN TERMS OF SUB - SECTION (2) OF SEC. 50C OF THE ACT. WE FIND THAT IN THE INSTANT CASE, THE ASSESSING OFFICER HAS OBTAINED THE 9 REPORT FROM DVO, THEREFORE THIS JU DG MENT WILL NOT HELPFUL TO THE ASSESSEE. SIMILARLY, IN THE CASE OF CIT VS. CHANDNI BHUCHAR REPORTED IN (2010) 191 TAXMA N 142 , THE HONBLE PUNJAB & HARYANA HIGH COURT DECIDED THE ISSUE RELATING TO ADDITION MADE U/S. 48 ON ACCOUNT OF UNEXPLAINED INVESTMENT IN THE PROPERTY. IN THE INSTANT CASE, IT IS A CASE OF DECIDING THE FMV, THEREFORE THIS JUDGMENT ALSO WILL NOT HELPFUL T O THE ASSESSEE. THEREFORE, WE ARE OF THE VIEW THAT THE ASSESSING OFFICER AND THE LD. CIT(A) ARE JUSTIFIED IN THEIR ACTION. 8. IN THE RESULT, APPEAL OF THE ASSESSEE IS DISMISSED. ( ORDER PRONOUNCED IN OPEN COURT ON 04 TH MARCH, 2015 ) SD/ - SD/ - (P.K. BANSAL) (D.T. GARASIA) ACCOUNTANT MEMBER JUDICIAL MEMBER DATED : 04 TH MARCH , 201 5 . VR/ - COPY TO: 1 . THE APPELLANT 2 . THE RESPONDENT 3 . THE LD. CIT 4 . THE CIT(A) 5 . THE D.R 6 . GUARD FILE. BY ORDER ASSISTANT REGISTRAR I.T.A.T., PANAJI .