The ACIT, Gandhidham Circle, Gandhidham V. M/s Kewar Career Handling & Transport Co., Gandhidham

ITA 148/RJT/2007

• Counselvise Citation: [2018] 119 COUNSELVISE.COM (IT) 0393 (ITAT-RAJKOT)
• Duration Of Justice: 11 year(s) 9 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-11-2018
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2003-2004
• Appeal Filed On: 12-02-2007
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Unexplained cash credit; Income from undisclosed sources

Judgement Text

KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 1 OF 12 , , IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT . . , . . , BEFORE SHRI C.M.GARG, JUDICIAL MEMBER AND SHRI O.P.MEENA, ACCOUNTANT MEMBER . . ./I.T.A. NO.55 /RJT/2007 /ASSESSMENT YEAR : 2003-04 KEWAR CARRIER HANDLING & TRANSPORT CO., OFFICE NO.12, FIRST FLOOR, GOKUL PARK, PLOT NO.356, WARD- 12B, GANDHIDHAM (KUTCH). [PAN: AAFFK 7054 B] VS. THE INCOME TAX OFFICER, @ARD-1, BHUJ (GANDHIDHAM). APPELLANT /RESPONDENT . . ./I.T.A. NO.148/RJT/2007 /ASSESSMENT YEAR : 2003-04 THE ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE, GANDHIDHAM. VS. KEWAR CARRIER HANDLING & TRANSPORT CO., OFFICE NO.12, FIRST FLOOR, GOKUL PARK, PLOT NO.356, WARD- 12B, GANDHIDHAM (KUTCH). [PAN: AAFFK 7054 B] APPELLANT /RESPONDENT /ASSESSEE BY SHRI KALPESH DOSHI A.R. /REVENUE BY SHRI PRAVEEN VERMA SR.DR / DATE OF HEARING: 26.11.2018 /PRONOUNCEMENT ON 07 .1 2 .2018 KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 2 OF 12 /O R D E R PER O. P. MEENA, ACCOUTANT MEMBER: 1. THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER OF LEARNED COMMISSIONER OF INCOME TAX (APPEALS), JAMNAGAR(IN SHORT THE CIT (A)) DATED 13.03.2014 PERTAINING TO BLOCK PERIOD 01.04.1987 TO 06.08.1997. 2. GROUND NO.1 RELATES TO CONFIRMING THE ADDITION OF RS.14 LAKHSMADE U/S.68 OF THE ACT WITHOUT CONSIDERING THE VARIOUS SUBMISSIONS AND EXPLANATION OF THE ASSESSEE. 3. BRIEFLY STATED FACTS OF THE CASE ARE THAT THE ASSESSEE HAS ACCEPTED NEW/FRESH UNSECURED LOANS AMOUNT TO RS.61,00,044/- FOR WHICH A SHOWCAUSE NOTICE WAS ISSUED BY THE AO. HOWEVER, THE ASSESSEE HAS FAILED TO PROVE OR FURNISHED ANY SATISFACTORY EXPLANATION. SINCE THE ASSESSMENT WAS ALSO FRAMED U/.144 OF THE ACT, THE AO THEREFORE MADE ADDITION OF CREDIT AMOUNT F RS.61,00,044/- AS UNEXPLAINED CASH CREDIT U/S.68 OF THE ACT. 4. BEING AGGRIEVED, THE ASSESSES HAS FILED AN APPEAL BEFORE THE LD.CIT(A) WHEREIN THE ASSESSEE HAS SUBMITTED COPIES OF CONFIRMING LOANS ALONG WITH A ACCOUNT EXTRACTS, IT WAS EXPLAINED THAT NON- KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 3 OF 12 COMPLIANCE WAS ON ACCOUNT OF DEATH OF THE ACCOUNTANT ON 16.07.2005, THEREFORE, THE CIT(A) HAS CALLED FOR REMAND REPORT FROM THE AO WHO HAS SUBMITTED HIS REMAND REPORT DATED 04.09.2006 AND 16.10.2006 WHICH HAS BEEN REPRODUCED BY THE CIT(A) AT PAGE 13 AND 14 OF THE ASSESSMENT ORDER. AFTER TAKING INTO CONSIDERATION THE EVIDENCES PRODUCED BY THE ASSESSEE AND REMAND REPORT OF THE AO, THE CIT(A) OBSERVED THAT SHRI MAHESH MEHTA, PROPRIETOR OF AMIT HANDLING AGENCY IN HIS STATEMENT HAS DEPOSED BEFORE THE AO THAT HE HAS NOT DEPOSITED ANY MONEY WITH THE ASSESSEE. WHAT WAS DEPOSITED WAS ONLY ON ACCOUNT OF CASH RECEIVED AND DEPOSITED IN THE BANK AND CHEQUE WAS GIVEN TO HIM. THE ASSESSEE HAD CALLED FOR CROSS-EXAMINATION IN HIS REJOINDER AND ALSO FURNISHED A BANK ACCOUNT. THE ASSESSEE HAS ALSO DEMANDED CROSS-EXAMINATION OF MR.MAHESH MEHTA. FURTHER, THE CIT(A) OBSERVED THAT THE ASSESSEE HAS SUBMITTED A BANK STATEMENT WHEREIN MR.MAHESH MEHTA HAD WITHDRAWN CASH OF RS.37 LAKHS, IT IS INTERESTING TO NOTICE THAT MR.MAHESH MEHTA HAS DEPOSITED THE CASH OF RS.2 LAKHS ON 19.10.2002, RS.5.05 LAKHS ON 22.11.2002 AND RS.6.5 LAKHS ON 19.12.2002 AND IMMEDIATELY CHEQUE WAS GIVEN TO THE ASSESSEE ON THE SAME DAY. THIS CLEARLY INDICATES SOURCE OF KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 4 OF 12 CREDIT AND IN CAPACITY OF THE PERSONS TO GIVE SUCH CREDIT ON HIS OWN. THEREFORE, THE CIT(A) HELD THAT THE QUESTION DRAWN BY THE AO IN REMAND REPORT THAT CREDIT IS BOGUS CANNOT BE DISPUTED AND THE ADDITION OF RS.14 LAKHS ON THIS ACCOUNT WAS THEREFORE SUSTAINED. HOWEVER, THE CIT(A) HAS DELETED THE ADDITION IN RESPECT OF GAYATRI TRANSPORT OF RS.3 LAKHS AS THE ASSESSEE HAS PRODUCED PRIMARY EVIDENCE TO ADDRESS OF PARTY, PAN WAS GIVEN BY THE ASSESSEE THE LOAN WAS REPAID DURING THE YEAR UNDER CONSIDERATION, THUS, A CLEARED UP CREDIT THE DIFFERENCE IN SIGNATURE IS ONLY ISSUE. THE AO FURTHER OBSERVED THAT INVESTIGATED WHEN ONCE SAME SECONDARY EVIDENCE ABOUT THE GENUINENESS OF THE CREDITOR IS INDICATING. THE CREDITOR IS ASSESSED TO TAX AT GANDHIDHAM, THEREFORE, THIS ADDITION WAS DELETED. SIMILARLY, ADDITION OF RS.14,20,000/- IN RESPECT OF AL-KARIM HANDLING & TRANSPORT CO. WAS DELETED ON THE GROUND THAT AO HAS GIVEN THE FINDING THAT THE TRANSACTION IS GENUINE IN HIS REMAND REPORT COPIES OF ACCOUNT, COPIES OR RETURN OF INCOME FILED AUDITED REPORT FILED BEFORE THE AO. BUT NOBODY APPEARED ON BEHALF OF THE BOTH THE FIRM. THEREFORE, THE AO OBSERVED THAT CREDIT WORTHINESS IS NOT PROVED. SIMILARLY, ADDITION OF RS.4 LAKHS IN RESPECT OF ALFA KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 5 OF 12 SHIPPING WAS DELETED AS THE TRANSACTION WAS FOUND TO GENUINE THROUGH PERSONS CONCERNED HAS NOT APPEARED WITH THE AO. HOWEVER, THE CIT(A) OBSERVED THAT BECAUSE NOBODY APPEARED FROM THESE FIRMS, IT CANNOT BE CONSIDERED AS THE CASE OF MAKING ADDITION U/S.68 OF THE ACT. SIMILARLY, ADDITION IN RESPECT OF SHREE RAM FINANCE CORPORATION OF RS.5 LAKHS, KANWARAM TRADERS RS.4 LAKHS, KEWAR ROADLINES RS.4,30,000/- K.M. RAMANI & CO. RS.10.50 LAKHS AND ROMESH CHATURAN RS.2 LAKHS WERE ALSO DELETED. AS THE ASSESSEE HAS FILED THE COPY OF LEDGER ACCOUNT ACKNOWLEDGEMENT RECEIPT OF INCOME TAX RETURN, BANK STATEMENT AND CASH BOOK THAT THEY HAVE NOT APPEARED BEFORE THE AO. 5. THE LD.CIT(A) WAS OF THE VIEW MERE NON-APPEARANCE OF THE CREDITOR CANNOT BE ATTRACTED TO THE NON-COMPLIANCE ON THE PART OF THE ASSESSEE. THEREFORE, THE CASH CREDIT NOT PROVED WHICH AND SAME CANNOT BE DISALLOWED, HENCE, THE ADDITION WAS DIRECTED TO BE DELETED. 6. BEING AGGRIEVED, THE ASSESSEE IS IN APPEAL AGAINST THE CONFIRMATION OF RS.14 LAKHS AND REVENUE IS IN APPEAL AGAINST THE DELETION OF ADDITION OF RS.47,00,044/- OUT OF RS.61,00,040/-. THE KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 6 OF 12 LD.COUNSEL FOR THE ASSESSEE SUBMITTED THAT SHRI M.P.MEHTA, PROPRIETOR OF AL-KARIM HANDLING & TRANSPORT CO. HAS APPEARED BEFORE THE AO DURING THE REMAND REPORT AND DENIED THE TRANSACTION WITH THE ASSESSEE, HOWEVER, LATER ON M.P.MEHTA HAS ACCEPTED THE TRANSACTION TO BE GENUINE. THEREFORE, THE CIT(A) WAS NOT JUSTIFIED IN CONFIRMING THE SAID ADDITION WITHOUT ALLOWING THE CROSS-EXAMINATION OF SHRI M.MEHTA. WITH REGARD TO DELETION TO THE ADDITION OF RS.47 LAKHS IN RESPECT OF OTHER CREDITOR THE LD.COUNSEL FOR THE ASSESSEE SUPPORTED THE ORDER OF CIT(A). 7. ON THE OTHER HAND, THE LD.SENIOR DEPARTMENTAL REPRESENTATIVE (SR.DR) SUBMITTED THAT THE CIT(A) WAS NOT JUSTIFIED IN DELETING THE ADDITION MERELY BECAUSE CONTRA COPY OF CONFIRM ACCOUNT OF THE ACKNOWLEDGMENT OF INCOME TAX RETURN, BANK STATEMENT WAS FILED WHEREAS THEY HAVE NOT APPEARED BEFORE THE AO. THEREFORE, THE CREDIT WORTHINESS OF THE CREDITORS IS NOT PROVED. WITH REGARD TO CONFIRMATION OF ADDITION OF RS.14 LAKHS THE SR.DR SUBMITTED THAT THE CIT(A) HAS RIGHTLY CONFIRMED THE SAME AS THE PROPRIETOR OF THE AMIT HANDLING AGENCY HAS DENIED IN HIS STATEMENT BEFORE THE AO TO HAVE GIVEN ANY CASH CREDIT TO THE KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 7 OF 12 ASSESSEE AND ACCEPTED THAT HE HAS GIVEN CHEQUES OUT OF CASH RECEIVED FROM THE ASSESSEE. 8. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL ON RECORD. WE FIND THAT THE ASSESSEE HAS TAKEN LOAN FROM SHRI M.MEHTA, PROPRIETOR OF AMIT HANDLING AGENCIES ON OCTOBER 19 TH , NOVEMBER 22 ND AND DECEMBER 19 TH TOTAL TO RS.14 LAKHS. THE PERUSAL OF BANK STATEMENT SHOWS THAT THE ASSESSEE SHRI M.MEHTA HAS DEPOSITED CASH OF RS.2 LAKHS ON 19.10.2002, RS.5.5 LAKHS ON 22.11.2002 AND RS.6.5 LAKHS ON 19.12.2002 AND IMMEDIATELY THEREAFTER CHEQUES WERE GIVEN TO THE ASSESSEE ON RESPECTIVE DATE. FURTHER, THIS FACT IS ALSO CONFIRMED BY THE SHRI M.MEHTA RECORDED ON OATH U/S.131 OF THE ACT WHEREIN HE DEPOSED THAT HE HAS GIVEN 3 CHEQUES TO SHRI LATIF AYUB KEWAR, PARTNER OF M/S.KEWAR HANDLING AND TRANSPORTING COMPANY AND HE DEPOSITED THOSE IN HIS BANK ACCOUNT AND HE WAS THE PERSON WHO DEPOSITED THOSE AMOUNT IN HIS BANK ACCOUNT AND GOT THE CHEQEUS CLEARED, THE ADDITION CONFIRMED BY THE CIT(A) AS THEREFORE UPHELD. ACCORDINGLY, THIS GROUND OF APPEAL OF THE ASSESSEE IS DISMISSED. KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 8 OF 12 9. WITH REGARD TO GROUND OF REVENUE WE FIND THAT THE ASSESSEE HAS FURNISHED DETAILS LIKE COPY OF LEDGER ACCOUNT ACKNOWLEDGMENT RECEIPTS, IT RETURN, BANK STATEMENT AND CASH BOOK, AUDITED REPORT. FURTHER, THE AO HAS ALSO GIVEN A FINDING THAT THE TRANSACTION IS GENUINE IN HIS REMAND REPORT AS MENTIONED IN THE PARA 5 OF THE APPELLATE ORDER. THEREFORE, MERELY BECAUSE THE PERSON CONCERNED WERE NOT APPEARED BEFORE THE AO DOES NOT MEAN THAT THE AFORESAID CREDITORS ARE NOT GENUINE. IN THE LIGHT OF THESE FACTS, WE FIND NO REASON TO INTERFERE WITH THE FINDINGS OF THE LD.CIT(A), ACCORDINGLY SAME IS UPHELD, THEREFORE, GROUND NO.1 OF THE REVENUE OF APPEAL IS ALSO DISMISSED. 10. GROUND NO.2 RELATES TO CONFIRMING ADDITION OF RS.3,03,017/- OUT OF LABOUR EXPENSES WITHOUT CONSIDERING THE FACT OF THE CASE IN PROPER PERSPECTIVE. SIMILARLY, GROUND NO.2 OF REVENUE RELATES TO RESTRICTING THE ADDITION TO THE TUNE OF RS.3,03,017/- OUT OF RS.2,18,71,865/- MADE ON ACCOUNT OF INFLATED / BOGUS UNPAID EXPENSES. THE AO NOTICED THAT THE ASSESSEE HAS CLAIMED UNPAID EXPENSES AMOUNT OF RS.2,18,71,865/- UNDER THE HEAD OF SUNDRY CREDITORS OF WHICH DETAILS WERE NOT FILED IN SPITE OF SEVERAL KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 9 OF 12 OPPORTUNITIES, THEREFORE, THE AO HAS ADDED THE SAME TO THE TOTAL INCOME OF THE ASSESSEE. 11. BEING AGGRIEVED, THE ASSESSEE HAS FILED APPEAL BEFORE THE LD.CIT(A) WHEREIN IT WAS CLAIMED THAT ALL THE EXPENDITURE ARE GENUINELY INCURRED IN LABOUR INTENSIVE CONTACT, BUT STILL UNPAID. THE AO WAS OF THE VIEW THAT IT WAS PAID IN CASH AND THESE CASH WAS GENERATED OUT OF UNACCOUNTED INCOME OF THE ASSESSEE. THERE IS NO FURTHER ANY VALUE ADDITION OF EVIDENCES BY THE AO AT THE TIME OF HEARING OR THROUGH HIS REMAND REPORT. THE ASSESSEE HAD SUBMITTED A COPY OF ORDER ITAT IN HIS SISTER CONCERNS CASES M/S.AYUB BAHACHAN AND M/S.AYUB BHECHA SHIPPING AND ALLIED SERVICES IN ITA NO.604/RJT/2003 AND IN ITA NO.607/RJT/2003. IN THOSE SISTER CONCERNS, THERE WAS SIMILAR EXPENDITURE INCURRED TO ALSO UNPAID AS ON DATE OF CLOSURE OF ACCOUNTS. THERE WAS ALSO A SUSPICION THAT WAGES COULD HAVE BEEN PAID IN CASH. THE LD.CIT(A) DELETED THE ADDITION. 12. BEING AGGRIEVED BY THE ORDER, THE DEPARTMENT HAD GONE INTO ITAT, THE ITAT BASED ON EARLIER YEARS ORDER HELD THAT THE FACTS AND CIRCUMSTANCES OF THE CASE THAT THE TRIBUNAL IS NOT MAKING KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 10 OF 12 ADDITION ON ACCOUNT OF UNPAID LABOUR CHARGES TO MODIFY THE ORDER OF CIT(A) BY DIRECTING THE AO TO ESTIMATE NET PROFIT AT 1.75% INSTEAD OF 1.41 % SHOWN BY THE ASSESSEE. THE CIT(A), THEREFORE OBSERVED THAT THE FACTS OF THE CASE IN THE SISTER CONCERNS AND ALSO THE ASSESSEE REGARDING THE UNPAID EXPENDITURE IS SAME. THE AO HAD ALSO NOT MADE OUT THE CASE EVEN ON SAMPLE ITEMS TO CONFIRM THE AOS BELIEF AND CASH MIGHT HAVE BEEN PAID ON ACCOUNT OF LABOUR AND OTHER EXPENSES. THEREFORE, THE CIT(A) FOLLOWING THE ORDER OF ITAT HAS DIRECTED THE AO TO TAKE NET PROFIT AT 2% IN PLACE OF 1.79 % DECLARED BY THE ASSESSEE. ACCORDINGLY, THE ADDITION WAS RESTRICTED TO RS.3,03,017/- AS AGAINST ADDITION OF RS.2,18,71,865/- MADE BY THE AO. 13. BEING AGGRIEVED, THE ASSESSEE AS WELL AS REVENUE HAS FILED AN APPEAL AGAINST THE CONFIRMATION OF ADDITION OF RS.3,03,017/- AND THE REVENUE HAS FILED AGAINST THE DELETION OF ADDITION. THE LD.COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE LABOUR EXPENSES WERE SHOWN AS UNPAID BUT THAT DOES NOT MEAN THAT THESE WERE NOT PAID OR PAID IN CASH. FURTHER, THE ISSUE IS COVERED AGAINST THE ASSESSEE BY THE ORDER OF TRIBUNAL IN THE CASE OF HIS SISTER CONCERN RELIED BY THE CIT(A) I.E. AYUB BHECHA SHIPPING AND ALLIED SERVICES KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 11 OF 12 & AYUB BAHACHAN (SUP). AS REGARDS DELETION OF ADDITION, THE LD.COUNSEL SUPPORTED THE ORDER OF THE CIT(A). 14. PER CONTRA, THE LD.SR.DR RELIED ON THE ORDER OF THE AO AND SUBMITTED THAT THE EXPENSES WERE REMAINED AS UNPAID, THEREFORE, GENUINENESS OF THE EXPENDITURE CANNOT BE ESTABLISHED. THEREFORE, THE AO WAS CORRECT IN MAKING DISALLOWANCES AND HENCE THE CIT(A) WAS NOT JUSTIFIED IN DELETING THE ADDITION. 15. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL ON RECORD WE FIND THAT IT IS IMPERATIVE OF SUCH TYPE OF EXPENSES REMAINING UNPAID ARE OUTSTANDING FOR 2 OR 3 MONTHS. THE AO HAS STATED IN PARA 5.6 OF HIS ORDER THAT CASH MUST BE PAID TO THESE LABOURERS AND TRUCK DRIVERS FROM SOURCE WHICH ARE NOT DISCLOSED TO THE DATA. THIS, ITSELF STATES THAT THERE IS NO DOUBT IN GENUINENESS OF THE EXPENDITURE BUT AO HAD MADE ESTIMATION OF THE UNDISCLOSED SOURCES FOR SUCH EXPENDITURE. WE FURTHER FIND THAT ON SIMILAR FACTS IN THE CASE OF SISTER CONCERN OF THE ASSESSEE M/S. AYUB BHECHA SHIPPING AND ALLIED SERVICES & AYUB BAHACHAN (SUP) THE ITAT HAD ESTIMATED THE NET PROFIT @1.4%. SIMILARLY, IN THE CASE OF ASSESSEE, THE ITAT HAS ACCEPTED THE PROFIT MARGIN OF KEWAR CARRIER HANDLING & TR. CO. VS. ITO, WARD-1, BHUJ/ITA NOS.55(A)&148(D)AY:2003-04 PAGE 12 OF 12 1.39 % SHOWN BY THE APPELLANT. WE FIND THAT THE CIT(A) HAS CONSIDERED NET PROFIT @2% INSTEAD OF 1.79% SHOWN BY THE ASSESSEE. THEREFORE, THIS GROUND OF APPEAL IS COVERED BY THE DECISION OF TRIBUNAL IN THE CASE OF SISTER CONCERN CITED (SUPRA), ACCORDINGLY WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF CIT(A). THEREFORE, SAME IS UPHELD, CONSEQUENTLY APPEAL OF THE REVENUE AND APPEAL OF THE ASSESSEE ON THIS GROUND IS ACCORDINGLY DISMISSED. 16. IN THE RESULT, APPEAL OF REVENUE AND APPEAL OF THE ASSESSEE IS DISMISSED. 17. THE ORDER PRONOUNCED IN THE OPEN COURT ON 07.12.2018. SD/- SD/- ( .. /C.M. GARG) ( .. / O.P.MEENA) /JUDICIAL MEMBER /ACCOUNTANT MEMBER / RAJKOT, DATED : 7 TH DECEMBER , 2018/ S.GANGADHARA RAO, SR.PS COPY OF ORDER SENT TO- ASSESSEE/AO/PR. CIT/ CIT (A)/ ITAT (DR)/GUARD FILE OF ITAT. BY ORDER / / TRUE COPY / / ASSISTANT REGISTRAR, RAJKOT