Deputy Commissioner of Income-tax, V. The Kalwan Merchants Co.op. Bank Ltd., Nashik

ITA 1568/PUN/2014

• Counselvise Citation: [2016] 133 COUNSELVISE.COM (IT) 2762 (ITAT-PUNE)
• Duration Of Justice: 1 year(s) 5 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 04-02-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2010-2011
• Appeal Filed On: 12-08-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: HITENDRA NINAWE
• Keywords: Question of law; Revenue expenditure

Judgement Text

, IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH B, PUNE . . , ! , # $ BEFORE SHRI R.K. PANDA, AM AND SHRI VIKAS AWASTHY, JM . / ITA NO.1568/PN/2014 #& & / ASSESSMENT YEAR : 2010-11 DCIT, CIRCLE-1, NASHIK . / APPELLANT V/S THE KALWAN MERCHANTS CO-OP. BANK LTD., SAPTASHRINGI, MAIN ROAD, A/P. KALWAN, TAL : KALWAN, NASHIK 423501 PAN NO.AAAAT4727G . / RESPONDENT / ASSESSEE BY : SHRI SANKET JOSHI / REVENUE BY : SHRI HITENDRA NINAWE / ORDER PER R.K. PANDA, AM : THIS APPEAL FILED BY THE REVENUE IS DIRECTED AGAINST THE O RDER DATED 19-06-2014 OF THE CIT(A)-I, NASHIK RELATING TO ASS ESSMENT YEAR 2010-11. 2. THE ONLY EFFECTIVE GROUND RAISED BY THE REVENUE READ S AS UNDER: 1. WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE, THE LD.CIT(A)-I, NASHIK WAS JUSTIFIED IN DELETING THE ADDI TION OF RS.17,29,838/- ON ACCOUNT OF AMORTIZATION OF PREMIUM ON GOVT. SECURITIES OF THE NATURE HELD TO MATURITY? / DATE OF HEARING :03.02.2016 / DATE OF PRONOUNCEMENT: 04.02.2016 2 ITA NO.1568/PN/2014 3. FACTS OF THE CASE, IN BRIEF, ARE THAT THE AO DURING TH E COURSE OF ASSESSMENT PROCEEDINGS NOTED FROM THE PROFIT AND LOSS ACCOUNT THAT AN AMOUNT OF RS.17,29,838/- HAS BEEN DEBITED UNDER THE HEAD INVESTMENT PREMIUM AMORTIZATION. ON BEING QUESTIONED BY THE AO, IT WAS SUBMITTED THAT THE ABOVE AMOUNT HAS BEEN CLA IMED AS DEDUCTION FOR AMORTIZATION OF THE GOVERNMENT SECURITIES PR EMIUM WHICH HAS BEEN HELD TO MATURITY (HTM) BY THE BANK OF SU CH SECURITY. IT WAS ARGUED THAT THE CLAIM HAS BEEN MADE A S PER THE GUIDELINES OF RBI WHICH HAS BEEN ISSUED SO THAT THE TRUE AND FAIR PROFITABILITY POSITION OF THE BANK IS REFLECTED. IT WAS FURTHER SUBMITTED THAT THE GUIDELINES ARE MANDATORY FOR THE BANK . IT WAS FURTHER SUBMITTED THAT SIMILAR ISSUE HAD AROSE IN THE PRECEDING YE AR AND THE CIT(A) HAS ALLOWED THE CLAIM OF THE ASSESSEE. 4. HOWEVER, THE AO WAS NOT SATISFIED WITH THE EXPLANATION GIVEN BY THE ASSESSEE AND DISALLOWED THE CLAIM OF RS.17,29,838/-. 5. IN APPEAL THE LD.CIT(A) DELETED THE ADDITION BY OBSERVIN G AS UNDER : 5.4 I HAVE CAREFULLY CONSIDERED THE FACTS OF THE CASE , THE ASSESSMENT ORDER AND THE SUBMISSIONS OF THE APPELLANT. AS REGARDS ADDITION OF RS.17,29,838/- BEING AMOUNT OF AMORTIZATION OF PREMI UM PAID ON GOVERNMENT SECURITIES, THE HONBLE ITAT MUMBAI IN TH E CASE OF ACIT VS. THE BANK OF RAJASTHAN LTD. [(2011) TIOL-35-ITAT-M UMBAI] HAS HELD THAT IN THE CASE OF BANKS, THE PREMIUM PAID IN EXCESS OF THE FACE VALUE OF INVESTMENTS CLASSIFIED UNDER HTM CATEGORY WHIC H HAS BEEN AMORTIZED OVER THE PERIOD TILL MATURITY IS ALLOWABL E AS REVENUE EXPENDITURE SINCE THE CLAIM IS AS PER RBI GUIDELINES AN D THE CBDT ALSO HAS DIRECTED TO ALLOW SUCH PREMIUM. IT HAS ALSO BEEN HE LD IN THE CASE OF CATHOLIC SYRIAN BANK LTD. VS. ACIT THAT AMORTIZATION ON PURCHASE OF GOVT. SECURITIES WAS MADE AS PER THE PRUDENTIAL NORMS OF THE RBI AND THE SAME WAS ALLOWED AS DEDUCTION. THE HON. ITAT, PUNE IN LT.A NO.1439/PN/2011 DATED 28/06/2013 IN THE CASE OF DCIT CIRCLE-1 VS. VISHWAS COOPERATIVE BANK LTD., HAS ALLOWED AMORTIZATIO N OF EXPENSES. THE HON'BLE ITAT HAS RELIED ON THE DECISIONS OF LATUR URBAN CO-OP BANK LTD VS. DCIT IN I.T.A NOS. 778 & 779/PN/2011 DAT ED 31/08/2012 AND RATNAKAR BANK LTD. I.T.A NO.789/PN/2010 DATED 0 8/02/2013. IN VIEW OF THE VARIOUS DECISIONS, THE APPELLANT'S CONTENT ION FOR AMORTIZATION OF PREMIUM PAID IN EXCESS OF THE FACE VA LUE OF THE SECURITY 3 ITA NO.1568/PN/2014 HELD TO MATURITY (HTM) CATEGORY OVER THE PERIOD REM AINING TILL MATURITY SEEMS REASONABLE. AO IS DIRECTED TO ALLOW AMOR TIZATION OF PREMIUM OF RS. 17,29,838/- ON GOVT. SECURITY (HTM) O NLY. GROUND NOS.1 & 2 ARE ALLOWED. 6. AGGRIEVED WITH SUCH ORDER OF THE CIT(A) THE REVENUE IS IN APPEAL BEFORE US. 7. WE HAVE CONSIDERED THE RIVAL ARGUMENTS MADE BY BOTH THE SIDES, PERUSED THE ORDERS OF THE AO AND CIT(A) AND THE P APER BOOK FILED ON BEHALF OF THE ASSESSEE. WE FIND AN IDENTICAL ISSUE H AD COME UP BEFORE THE TRIBUNAL IN THE CASE OF ACIT VS. THE AHMEDNAGAR DISTRICT CENTRAL CO-OP. BANK LTD. THE TRIBUNA L VIDE ITA NO.1983/PN/2013 ORDER DATED 20-02-2015 FOR A.Y. 201 0-11 HAS DECIDED THE ISSUE IN FAVOUR OF THE ASSESSEE AND DISM ISSED THE APPEAL FILED BY THE REVENUE BY OBSERVING AS UNDER : 4. BEFORE US, IT WAS A COMMON POINT BETWEEN THE PART IES THAT SIMILAR ISSUE OF THE ALLOWABILITY OF PREMIUM ON AMORTIZATION OF HTM SECURITIES, AROSE BEFORE PUNE BENCH OF THE TRIBUNAL I N THE CASE OF PUNE DISTRICT CENTRAL CO. OPERATIVE BANK LTD. VS. ADDL.CIT IN ITA NO.1796/PN/2013 RELATING TO ASSESSMENT YEAR 2009-10 VID E ORDER DATED 28TH NOVEMBER 2014, IT WAS HELD AS UNDER:- 10. WE FIND THAT A SIMILAR ISSUE OF ALLOWABILIT Y OR DEDUCTION ON ACCOUNT OF AMORTIZATION OF PREMIUM EXPENDITURE FOR HTM SECURITIES AROSE BEFORE PUNE BENCH OF THE TRIBUNAL IN ASSESSEE S OWN CASE IN ITA NO.1795/PN/2013 RELATING TO ASSESSMENT YEAR 2008-09 VIDE ORDER DATED 22.09.2014 WHEREIN, IT WAS HELD AS UNDER:- 2.1 THE ONLY ISSUE REMAINS IS WITH REGARD TO DISAL LOWANCE MADE BY THE ASSESSING OFFICER OF RS.2,20,68,302/- C LAIMED BY THE ASSESSEE AS AMORTIZATION OF PREMIUM EXPENDITURE FOR HTM SECURITIES BY PAYMENT OF OVER AND ABOVE THE VALUE O F SUCH SECURITIES. THE LEARNED AUTHORIZED REPRESENTATIVE H AS POINTED OUT THAT THIS ISSUE IS COVERED IN FAVOUR OF THE ASS ESSEE BY ORDER OF THE HONBLE BOMBAY HIGH COURT IN THE CASE OF CIT VS. HDFC BANK LTD. (2014) 366 ITR 505 (BOM), WHEREIN TH E HONBLE BOMBAY HIGH COURT ON SIMILAR ISSUE, HELD AS UNDER: AS FAR AS QUESTION (C) IS CONCERNED, WE FIND THAT AN IDENTICAL QUESTION OF LAW WAS FRAMED AND ANSWERED IN FAVOUR O F THE ASSESSEE BY THIS COURT IN ITS JUDGMENT DATED JULY 4 , 2014, IN INCOME TAX APPEAL NO.1079 OF 2012, CIT V. LORD KRIS HNA BANK LTD. (NOW MERGED WITH HDFC BANK LTD.) (2014) 366 IT R 416 (BOM). MR. SURESH KUMAR FAIRLY STATED THAT QUESTION (C) REPRODUCED ABOVE IS COVERED BY THE SAID ORDER. IN V IEW 4 ITA NO.1568/PN/2014 THEREOF, WE ARE OF THE VIEW THAT EVEN QUESTION (C) DOES NOT ARISE ANY SUBSTANTIAL QUESTION OF LAW THAT REQUIRES AN ANSWER FROM US. AND A SIMILAR VIEW HAS BEEN TAKEN BY ITAT, PUNE A BENCH IN THE CASE OF DY.CIT VS. KALLAPPANNA AWADE ICHALKARAN JI JANATA SAHAKARI BANK LTD. IN ITA NO.449/PN/2012 AND ANOTHE R BY OBSERVING AS UNDER: 10. WE HAVE CONSIDERED THE RIVAL ARGUMENTS MADE BY BOTH THE SIDES, PERUSED THE ORDERS OF THE ASSESSING OFFI CER AND THE CIT(A) AND THE PAPER BOOK FILED ON BEHALF OF THE AS SESSEE. WE HAVE ALSO CONSIDERED THE VARIOUS DECISIONS CITED BE FORE US. WE FIND AN IDENTICAL ISSUE HAD COME UP BEFORE THE TRIB UNAL IN THE CASE OF NAHSIK MERCHANT COOPERATIVE BANK LTD. (SUPR A). WE FIND THE TRIBUNAL HAS DISCUSSED THE ISSUE AND DISMI SSED THE GROUNDS RAISED BY THE REVENUE BY HOLDING AS UNDER : 4. AFTER GOING THROUGH RIVAL SUBMISSIONS AND MATER IAL ON RECORD WE FIND THAT WITH THE ADVENT OF SECTION 80P(4) W.E.F. A.Y, 2007-08 HAS CLOSED THE DOORS FOR COOPERATIVE BANKS FOR CLAIMING THE BENEFIT OF DEDUCTION U/S.80P(2)(A)(I) FROM THIS TOTAL INCOME. HOWEVER, THE COOPERATIVE SOCIETY SHOULD NOW BE ENTITLED TO BE ASSESSED AS NORMAL BANKING COMPANY. THE CLAUSE (4) INSERTED IN SECTION 80P HAS TAKEN AW AY THE BENEFIT OF THE ERSTWHILE DEDUCTION AVAILABLE TO COOPERATIVE SOCIETY IN CARRYING ON BUSINESS OF BANK ING OR PROVIDING CREDIT FACILITY TO ITS MEMBERS. THE NE W CLAUSE (4) INSERTED BY THE FINANCE ACT, 2006 W.E.F. 01- 04-2007 READS AS UNDER: ' THE PROVISION OF THE SECTION WAS NOT IN RELATION TO ANY COOPERATIVE BANK OTHER THAN AGRICULTURAL CREDIT SOCIETY OR PRIMARY COOPERATIVE AGRICULTURAL AND RUR AL DEVELOPMENT BANK'. 5. THE INTENTION OF THE PROVISION MAY BE DERIVED MO RE PRECISELY FROM RELEVANT PARA 166 OF THE BUDGET SPEE CH WHICH STATED THAT : 'COOPERATIVE BANKS, LIKE ANY OT HER BANK, ARE LENDING INSTITUTIONS AND SHOULD PAY TAX O N THEIR PROFITS, PRIMARY AGRICULTURAL CREDIT SOCIETIE S (PACS) AND PRIMARY COOPERATIVE AGRICULTURAL AND RURAL DEVELOPMENT BANK (PCARDB) STAND ON A SPECIAL FOOTING AND WILL CONTINUE TO BE EXEMPT UNDER SECTIO N 80P OF THE INCOME TAX ACT. HOWEVER, I PROPOSE TO EXCLUDE ALL OTHER CO-OPERATIVE BANKS FROM THE SCOPE OF THAT SECTION'. ACCORDINGLY, SECTION 80P IS TO BE AMENDED TO GIVE EFFECT TO THE ABOVE PROPOSAL. IT IS ALSO PROPOSED TO AMEND SECTION 2(24) TO PROVIDE THAT PROFITS AND GAINS OF BUSINESS OF BANKING (INCLUDING PROVIDING CREDIT FACILITIES) CARRIED ON BY A CO-OPE RATIVE SOCIETY WITH ITS MEMBERS SHALL BE INCLUDED IN THE DEFINITION OF 'INCOME' (WITH EFFECT FROM 1ST APRIL, 2007)'. 6. COOPERATIVE BANK UNLIKE OTHER COMMERCIAL BANKS ARE SUBJECTED TO DUAL CONTROL FROM BOTH RBI AS WELL AS FROM STATE COOPERATIVE DEPARTMENT. THE ACCOUNTING TREATMENT FOR A COOPERATIVE BANK IS THEREFORE A RES ULT OF GUIDELINES FROM BOTH THE CONTROLLING AUTHORITIES . 5 ITA NO.1568/PN/2014 ORDINARILY A DEDUCTION IS NOT AVAILABLE TO AN ASSES SEE UNLESS SPECIFICALLY PROVIDED UNDER THE ACT. THIS IS IRRESPECTIVE OF ACCOUNTING TREATMENT PROVIDED BY TH E ASSESSEE IN ITS BOOKS OF ACCOUNTS. BUT AT THE SAME TIME IT WAS WELL SETTLED THAT DEDUCTION EXPRESSLY MENTIO NED UNDER THE ACT ARE NOT EXHAUSTIVE AND PROFIT IS TO B E DERIVED ACCORDING TO ORDINARY COMMERCIAL PRINCIPLES . AS PER THE EXTANT RBI GUIDELINES DATED 01-07-2009 T HE INVESTMENT PORTFOLIO OF THE BANKS IS REQUIRED TO BE CLASSIFIED UNDER 3 CATEGORIES VIZ., HELD THE MATURI TY HTM), HELD FOR TRADING (HFT) AND AVAILABLE FOR SALE (AFS). THE VALUE OF EACH KIND OF INVESTMENT IS TO B E DONE IN THE FOLLOWING MANNER: SR.NO. CLASSIFICATION VALUATION NORMS OF INVESTMENT . 1.. 2.. 3.. 7. IN PARA (VII) OF THE CBDT INSTRUCTION NO.17 OF 2 008 DATED 26.11.2008, ON 'ASSESSMENT OF BANK - CHECK LI ST FOR DEDUCTION, STATES AS UNDER: 'AS PER RBI GUIDELINES..' 8. THE ITAT, MUMBAI BENCH, IN THE CASE OF ACIT VS. THE BANK OF RAJASTHAN LTD. (2011) TIOL- 35-ITAT-MUMBAI, HAS HELD THAT IN CASE OF BANKS, THE PREMIUM PAID IN EXCESS OF FACE VALUE OF INVESTMENTS CLASSIFIED UNDE R HTM CATEGORY WHICH HAS BEEN AMORTISED OVER THE PERIOD TILL MATURITY IS ALLOWABLE AS REVENUE EXPENDITURE SINCE THE CLAIM IS AS PER RBI GUIDELINE S AND CBDT ALSO HAS DIRECTED TO ALLOW SUCH PREMIUM. I T HAS ALSO BEEN HELD IN THE CASE OF CATHOLIC SYRIAN B ANK LTD. VS. ACIT THAT AMORTIZATION ON PURCHASE OF GOVERNMENT SECURITIES WAS MADE AS PER PRUDENTIAL NORMS OF THE RBI AND SAME WAS ALLOWABLE DEDUCTION. IN VIEW OF ABOVE, ASSESSEE WAS JUSTIFIED IN CONTEND ING FOR AMORTIZATION OF PREMIUM PAID IN EXCESS OF FACE VALUE OF SECURITIES HELD TO MATURITY (HTM) CATEGORY OR PERIOD REMAINING TILL MATURITY WAS FOUND REASONABLE BY THE CIT(A). ACCORDINGLY ADDITION OF RS.17,91,659 /- MADE BY THE ASSESSING OFFICER BY DISALLOWING AMOUNT TOWARDS AMORTIZATION OF GOVERNMENT SECURITIES (HMT) WAS DELETED. THIS REASONED FACTUAL AND LEGAL FINDING OF THE CIT(A) NEEDS NO INTERFERENCE FROM OU R SIDE. WE UPHOLD THE SAME. 9. AS A RESULT, THE APPEAL FILED BY THE REVENUE IS DISMISSED. 10.1 RESPECTFULLY FOLLOWING THE DECISION OF THE COO RDINATE BENCH OF THE TRIBUNAL AND IN ABSENCE OF ANY CONTRARY MATERIA L BROUGHT TO OUR NOTICE AGAINST THE ABOVE CITED DECISION WE FIND NO INFIRMITY IN THE ORDER OF THE LD.CIT(A) DELETING THE ADDITION. ACCOR DINGLY, THE ORDER OF THE LD.CIT(A) IS UPHELD AND THE GROUNDS RAISED BY T HE REVENUE ARE DISMISSED. 2.2 NOTHING CONTRARY HAS BEEN BROUGHT TO OUR KNOWLE DGE ON BEHALF OF THE REVENUE. FACTS BEING SIMILAR, SO FOLLOWING THE SAME REASONING WE HOLD THAT IN CASE OF BANKS, THE PREMIUM PAID IN EXC ESS OF FACE VALUE OF 6 ITA NO.1568/PN/2014 INVESTMENTS CLASSIFIED UNDER HTM CATEGORY WHICH HAS BEEN AMORTISED OVER THE PERIOD TILL MATURITY IS ALLOWABLE AS REVEN UE EXPENDITURE SINCE THE CLAIM IS AS PER RBI GUIDELINES AND CBDT A LSO HAS DIRECTED TO ALLOW SUCH PREMIUM. IN VIEW OF ABOVE, THE ASSESSEE IS JUSTIFIED IN CONTENDING THAT THE AMORTIZATION OF PREMIUM IN EXCE SS OF FACE VALUE SECURITIES AS HTM, PERIOD REMAINING DIFFERENCE WAS FOUND REASONABLE. ACCORDINGLY, THE DISALLOWANCE OF RS.2,20,68,302/- M ADE BY THE ASSESSING OFFICER CLAIMED AS AMORTIZATION OF PREMIU M EXPENDITURE FOR HTM SECURITIES BY PAYMENT OF PREMIUM OVER AND ABOVE THE FACE VALUE OF SUCH SECURITIES IS DIRECTED TO BE ALLOWED. 11. THE HONBLE BOMBAY HIGH COURT IN CIT VS. HDFC B ANK (SUPRA) HELD THAT THE ASSESSEE THEREIN WAS ENTITLED TO DEDU CTION WITH RESPECT TO THE DIMINUTION IN THE VALUE OF INVESTMENTS AND A MORTIZATION OF PREMIUM ON INVESTMENTS HELD TO MATURITY ON THE GROU ND OF MANDATE OF THE RBI GUIDELINES. THE ISSUE RAISED IN THE PRES ENT APPEAL IS IDENTICAL TO THE ISSUE BEFORE THE PUNE BENCH OF THE TRIBUNAL IN THE ASSESSEES OWN CASE FOR ASSESSMENT YEAR 2008-09 AND HONBLE BOMBAY HIGH COURT IN CIT VS. HDFC BANK (SUPRA). WE HOLD THAT AMORTIZATION OF PREMIUM EXPENDITURE FOR SECURITIES HELD TO MATURITY IN VIEW OF RBI GUIDELINES ARE ALLOWABLE BUSINESS EX PENDITURE IN THE CASE OF ASSESSEE. THE GROUNDS OF APPEAL NO.1 AND 2 RAISED BY THE ASSESSEE ARE THUS, ALLOWED. 5. WE FURTHER FIND THAT THE HONBLE BOMBAY HIGH COU RT IN CASE OF HDFC BANK LTD. (SUPRA) IN INCOME TAX APPEAL NO.330 OF 201 2 VIDE ORDER DATED 23.07.2014, ON A SIMILAR ISSUE ON ACCOUNT OF DED UCTION WITH RESPECT TO DIMINUTION IN THE VALUE OF INVESTMENT AND AMORTIZATION OF PREMIUM ON INVESTMENT (HELD TO MATURITY) AFTER REFER RING TO THE MANDATE OF THE RBI GUIDELINES, AND THE DECISION OF TH E HONBLE SUPREME COURT IN THE CASE OF SOUTHERN TECHNOLOGIES VS. JCIT, (2010) 320 ITR 577 (SC) HAD DISMISSED THE APPEAL FILED BY THE REVENUE. 6. THE ISSUE ARISING IN THE PRESENT APPEAL IS IDENTICAL TO THE ISSUE DECIDED BY THE PUNE BENCH OF THE TRIBUNAL IN THE CA SE OF PUNE DISTRICT CENTRAL CO. OPERATIVE BANK LTD. (SUPRA) AND ALSO THE HONBLE BOMBAY HIGH COURT IN THE CASE OF HDFC BANK LTD. (SUPRA), AN D FOLLOWING THE SAME PARITY OF REASONING, WE HOLD THAT THE ASSESSEE IS ENT ITLED TO THE DEDUCTION OF RS.60,00,000/- BEING THE PREMIUM ON AMO RTIZATION OF SECURITIES. ACCORDINGLY, WE HEREBY AFFIRM THE ACTION OF CIT(A) IN DELETING THE DISALLOWANCE OF RS.60,00,000/- REPRESENTI NG AMORTIZATION OF PREMIUM PAID ON GOVERNMENT SECURITIES UNDER THE H TM CATEGORY. THUS ON THIS ASPECT, REVENUE FAILS. 8. RESPECTFULLY FOLLOWING THE DECISION OF THE COORDINATE BENCH OF THE TRIBUNAL CITED (SUPRA) AND IN ABSENCE OF ANY CONTRARY MATERIAL BROUGHT TO OUR NOTICE, WE FIND NO INFIRMITY IN THE ORDER OF THE CIT(A). ACCORDINGLY, THE SAME IS UPHELD AND THE GROUND RAISED BY THE REVENUE IS DISMISSED. 7 ITA NO.1568/PN/2014 9. IN THE RESULT, THE APPEAL FILED BY THE REVENUE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 04-02-2016. SD/- SD/- ( VIKAS AWASTHY ) ( R.K. PANDA ) JUDICIAL MEMBER ACCOUNTANT MEMBER PUNE ; DATED : 04 TH FEBRUARY, 2016. ) *#,! -! / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT 3. THE CIT(A ) - I, NASHIK 4. 5. 6. THE CIT-I, NASHIK $ ''(, (, / DR, ITAT, B PUNE; - / GUARD FILE. / BY ORDER , $ ' //TRUE COPY// // TRUE COPY // // $ ' //TRUE C // /0 ' ( / SR. PRIVATE SECRETARY (, / ITAT, PUNE