Mohinidevi Bhojraj Manchanda, Nashik V. Assistant Commissioner of Income-tax,

ITA 160/PUN/2015

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 1166 (ITAT-PUNE)
• Duration Of Justice: 1 year(s) 5 month(s) 26 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 05-08-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2006-2007
• Appeal Filed On: 09-02-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Reopening of assessment; Accommodation entries; Assessment record; Reassessment proceedings
• Section: 143(3); 142(1); 148

Judgement Text

- IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH SMC , PUNE , BEFORE MS. SUSHMA CHOWLA, JM . / ITA NO. 160 /PN/201 5 / ASSESSME NT YEAR : 20 0 6 - 0 7 MOHINIDEVI BHOJRAJ MANCHANDA PLOT NO.20/21, OPP. HARIVIHAR SOCIETY, SAUBHAGYA NAGAR, NASHIK ROAD, NASHIK 422101 . / APPELLANT PAN: A BFPM2470A VS. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE - 1, NASHIK . / RESPONDENT / APPELLANT BY : SHRI PRAMOD SHINGTE / RESPONDENT BY : SHRI HITENDRA NINAWE / RESPONDENT BY : SHRI HITENDRA NINAWE / DATE OF HEARING : 19 . 0 7 .201 6 / DATE OF PRONOUNCEMENT: 05 . 0 8 .201 6 / O RDER PER SUSHMA CHOWLA, J M : TH IS APPEAL FILED BY THE ASSESSEE IS AGAINST THE ORDER OF CIT (A) - I , NASHIK , DATED 29 . 1 2 .20 1 4 RELATING TO ASSESSMENT YEAR 20 0 6 - 0 7 AGAINST ORDER PASSED UNDER SECTION 14 3(3) R.W.S. 147 OF THE INCOME - TAX ACT , 1961 (IN SHORT THE A CT) . 2 . THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS OF APPEAL: - 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW THE LEARNED LOWER AUTHORITY ERRED IN INITIATING THE REASSESSMENT ITA NO. 160 /PN/20 1 5 MOHINIDEVI BHOJRAJ MANCHANDA 2 PROCEEDINGS UNDER SECTION 147 OF THE INCOME TAX ACT, 1961, BEYOND FOUR YEARS BY IGNORING THE FACT THAT ALL THE MATERIAL FACTS WERE DISCLOSED IN THE RETURN OF INCOME. 2. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW THE LEARNED LOWER AUTHORITY OFFICER HAVE ERRED IN MAKING AN ADDITION OF RS.12,73,833 / - BY TREATING GENUINE INVESTMENT TRANSACTION OF PURCHASE OF SHARE AS NON - GENUINE AND BY DISREGARDING APPELLANT SUBMISSION IN THIS REGARD. 3. THE ASSESSEE HAS ALSO RAISED AN ADDITIONAL GROUND OF APPEAL, WHICH READS AS UNDER: - ON THE FACTS AND IN THE CIRC UMSTANCES OF THE CASE AND IN LAW, THE LEARNED ASSESSING OFFICER ERRED IN NOT PASSING SEPARATE SPEAKING ORDER IN CONSEQUENCES TO OBJECTION RAISED FOR ISSUANCE OF NOTICE U/S 148 OF I.T. ACT, THEREBY HAS VIOLATED THE DIRECTION OF HON. SUPREME COURT IN THE CAS E OF GKN DRIVESHAFT E S (INDIA) LTD VS. ITO, THEREFORE ENTIRE PROCEEDINGS U/S 147 OF I.T. ACT ARE VOID AB INITIO AND NEEDS TO BE QUASHED. 4. THE PRELIMINARY ISSUE RAISED BY THE ASSESSEE IS AGAINST RE - ASSESSMENT PROCEEDINGS INITIATED UNDER SECTION 147 / 148 OF THE ACT. THE ASSESSEE BY WAY OF ADDITIONAL GROUND OF APPEAL HAS OBJECTED TO THE ASSESSMENT ORDER PASSED IN THE CASE, WHEREIN THE ASSESSING OFFICER HAD NOT PASSED A SPEAKING ORDER CONSEQUENT TO THE OBJECTIONS RAISED FOR ISSUANCE OF NOTICE UNDER SECTION 148 OF THE ACT. 5. BRIEFLY, IN THE FACTS OF THE CASE, THE ASSESSEE HAD FURNISHED ORIGINAL RETURN OF INCOME ON 27.10.2006 DECLARING TOTAL INCOME OF RS. 15,81,370/ - . THE ASSESSING OFFICER RECORDED REASONS FOR REOPENING THE ASSESSMENT ON THE BASIS OF INFORMA TION FORWARDED BY CHIEF COMMISSIONER OF INCOME TAX (CENTRAL - 1), MUMBAI THROUGH COMMISSIONER OF INCOME TAX, CENTRAL - IV, MUMBAI, WHEREIN SEARCH ACTION WAS TAKEN IN THE CASE OF M/S. MAHASAGAR SECURITIES & MUKESH CHOKSI GROUP ON 25.11.2009. DURING THE COURSE OF SEARCH, SHRI MUKESH CHOKSI ADMITTED THAT HE AND HIS GROUP WERE ENGAGED IN FRAUDULENT BILLING ACTIVITIES AND IN GIVING ACCOMMODATION ENTRIES. ONE OF THE BENEFICIARIES WHICH WAS IDENTIFIED ITA NO. 160 /PN/20 1 5 MOHINIDEVI BHOJRAJ MANCHANDA 3 BY HIM WAS THE ASSESSEE WHO WAS TRADING IN COMMODITIES ( SPECULATI ON ) AND WAS ALSO A PARTNER IN THE PARTNERSHIP FIRM. ON THE BASIS OF AFORESAID INFORMATION, THE ASSESSING OFFICER WAS OF THE VIEW THAT INCOME TO THE EXTENT OF RS. 5,24, 79 4/ - BEING CHARGEABLE TO INCOME TAX ESCAPED ASSESSMENT WITHIN THE MEANING OF EXPLANATION - 2 TO SECTION 147 OF THE ACT. CONSEQUENTLY, THE ASSESSING OFFICER HAD ISSUE D NOTICE UNDER SECTION 148 OF THE ACT AFTER TAKING PRIOR APPROVAL OF JCIT, RANGE - 1, NASHIK ON 22.03.2013. IN RESPONSE TO THE NOTICE, THE ASSESSEE VIDE LETTER DATED 19.04.2013 COMM UNICATED THAT THE ORIGINAL RETURN OF INCOME FILED ON 27.10.2006 MAY BE TREATED AS RETURN OF INCOME IN RESPONSE TO NOTICE ISSUED UNDER SECTION 148 OF THE ACT. THEREAFTER, NOTICE UNDER SECTION 143(2) OF THE ACT WAS ISSUED TO THE ASSESSEE AND THE ASSESSEE RE QUESTED FOR REASONS FOR REOPENING THE ASSESSMENT UNDER SECTION 147 OF THE ACT WHICH WERE COMMUNICATED TO THE ASSESSEE. THE REASONS FOR REOPENING THE ASSESSMENT ARE ENUMERATED UNDER PARA 2 AT PAGES 2 TO 4 OF THE ASSESSMENT ORDER. THE OBJECTIONS OF THE ASS ESSEE AGAINST REOPENING OF ASSESSMENT ARE ALSO REPRODUCED BY THE ASSESSING OFFICER AT PAGE 4 OF THE ASSESSMENT ORDER. HE FURTHER REJECTS THE OBJECTIONS RAISED BY THE ASSESSEE BECAUSE OF DIFFERENT REASONS AS ENUMERATED AT PAGE 5 OF THE ASSESSMENT ORDER. T HE ASSESSING OFFICER FURTHER VIDE PARA 3 NOTES THAT THE LEARNED AUTHORIZED REPRESENTATIVE FOR THE ASSESSEE ATTENDED FROM TIME TO TIME THEREAFTER AND DISCUSSED THE CASE AND FILED WRITTEN SUBMISSIONS AND THE ASSESSMENT WAS COMPLETED IN THE HANDS OF ASSESSEE UNDER SECTION 143(3) R.W.S. 147 OF THE ACT, WHEREIN THE ADDITION OF RS.12,73,833/ - WAS MADE . 6. BEFORE THE CIT(A), THE ASSESSEE RAISED THE ISSUE ON MERITS AND NO ISSUE WAS RAISED ON JURISDICTIONAL ISSUE THOUGH IN THE WRITTEN SUBMISSIONS THE ITA NO. 160 /PN/20 1 5 MOHINIDEVI BHOJRAJ MANCHANDA 4 ASSESSEE CLAIM ED THAT SINCE ALL THE ENTRIES WERE DULY RECORDED IN HIS BOOKS OF ACCOUNT, THERE IS NO NEED TO ISSUE NOTICE UNDER SECTION 148 OF THE ACT. 7. THE ASSESSEE HOWEVER, BEFORE THE TRIBUNAL HAS RAISED AN ADDITIONAL GROUND OF APPEAL WHICH IS LEGAL IN NATURE AND I N VIEW THEREOF, THE SAME IS ADMITTED. 8. THE LEARNED DEPARTMENTAL REPRESENTATIVE FOR THE REVENUE WAS DIRECTED TO PRODUCE THE ASSESSMENT RECORDS IN VIEW OF ADDITIONAL GROUND OF APPEAL RAISED BY THE ASSESSEE. THE PERUSAL OF ORDER SHEET ENTRIES REFLECTS THA T ON 22.03.2013, THE ASSESSING OFFICER PROPOSED ACTION UNDER SECTION 148 OF THE ACT WHICH WAS SENT TO THE JCIT, WHO IN TURN, APPROVED THE SAME AND THE ASSESSING OFFICER ISSUED NOTICE UNDER SECTION 148 OF THE ACT ON 22.03.2013 ITSELF. FURTHER, BECAUSE OF C HANGE IN THE OFFICER, ANOTHER NOTICE UNDER SECTION 142(1) AND 143(2) OF THE ACT WERE ISSUED FOR FRESH HEARING, IN RESPONSE TO WHICH, THE REPRESENTATIVE OF THE ASSESSEE APPEARED AND FURNISHED WRITTEN SUBMISSIONS AND DOCUMENTS. THEREAFTER, ASSESSMENT PROCEE DINGS WERE TAKEN UP. 9. NOW, THE ASSESSEE S CLAIM BEFORE THE TRIBUNAL IS THAT THE ORIGINAL RETURN OF INCOME WAS FILED ON 27.10.2006. THEREAFTER, NOTICE UNDER SECTION 148 OF THE ACT WAS ISSUED ON 22.03.2013 AND THE ASSESSEE FILED A LETTER DATED 19.04.2013 REQUESTING THE ASSESSING OFFICER TO TREAT THE ORIGINAL RETURN FILED TO BE TREATED AS FILED IN RESPONSE TO THE NOTICE UNDER SECTION 148 OF THE ACT. THE ASSESSEE SOUGHT REASONS FOR REOPENING THE ASSESSMENT WHICH ADMITTEDLY WAS GIVEN TO THE ASSESSEE ON 08.0 7.2013. HE FURTHER OBJECTED TO THE REASONS VIDE LETTER DATED 03.10.2013 . IN THE SAID OBJECTIONS, THE ASSESSEE CLEARLY POINTED OUT THAT THE ENTRIES REFERRED TO IN THE REASONS RECORDED FOR REOPENING THE ASSESSMENT ITA NO. 160 /PN/20 1 5 MOHINIDEVI BHOJRAJ MANCHANDA 5 WERE DULY RECORDED IN THE BOOKS OF ACCOUNT AND THERE WAS NO NEED TO RE OPEN THE ASSESSMENT UNDER SECTION 148 OF THE ACT. HOWEVER, THE ASSESSING OFFICER FAILED TO DISPOSE OF THE OBJECTIONS RAISED BY THE ASSESSEE BEFORE COMPLETING ASSESSMENT ORDER, WHICH WAS PASSED ON 31.01.2014. THE CLAIM OF THE A SSESSEE BEFORE THE TRIBUNAL IS THAT THOUGH THE OBJECTIONS RAISED BY THE ASSESSEE AGAINST THE ISSUE OF NOTICE UNDER SECTION 148 OF THE ACT WERE CONSIDERED BY THE ASSESSING OFFICER, BUT THE SAME WERE DEALT WITH AND COMMUNICATED BY THE ASSESSMENT ORDER PASSED ON 31.01.2014. HOWEVER, PRIOR TO THAT DATE, THERE WAS NO COMMUNICATION OF DISPOSING OF THE OBJECTIONS RAISED BY THE ASSESSEE AGAINST THE ISSUE OF NOTICE UNDER SECTION 148 OF THE ACT. THE LEARNED DEPARTMENTAL REPRESENTATIVE FOR THE REVENUE FAIRLY PRODUCE D THE ORDER SHEET ENTRIES AND POINTED OUT THAT THERE WAS NOTHING ON RECORD. THE LEARNED AUTHORIZED REPRESENTATIVE FOR THE ASSESSEE PLACED RELIANCE ON THE RATIO LAID DOWN BY THE HONBLE BOMBAY HIGH COURT IN V.M. SALGAONCAR SALES INTERNATIONAL VS. ACIT (201 5) 59 TAXMANN.COM 291 (BOM) , WHICH IN TURN, HAD FOLLOWED THE PRINCIPLE LAID DOWN BY THE HONBLE SUPREME COURT IN GKN DRIVESHAFTS (INDIA) LTD. VS. ITO (2003) 259 ITR 19 (SC). 10. THE PERUSAL OF THE JUDGMENT OF HONBLE BOMBAY HIGH COURT IN V.M. SALGAONCAR S ALES INTERNATIONAL VS. ACIT (SUPRA) LAYS DOWN THE JUDICIAL DISCIPLINE TO BE FOLLOWED BY THE ASSESSING OFFICER DURING THE COURSE OF RE ASSESSMENT PROCEEDINGS. THE HONBLE BOMBAY HIGH COURT HAS HELD THAT ONCE THE REASONS HAVE BEEN RECORDED FOR REOPENING THE ASSESSMENT AND PURSUANT TO WHICH NOTICE UNDER SECTION 148 OF THE ACT HAS BEEN ISSUED AND THE ASSESSEE HAS FILED THE RETURN OF INCOME IN RESPONSE THERETO, THEN IN CASE PURSUANT TO FILING OF SAID RETURN OF INCOME, THE ASSESSEE ASKED FOR REASONS FOR ITA NO. 160 /PN/20 1 5 MOHINIDEVI BHOJRAJ MANCHANDA 6 REOPENING THE ASSESSMENT, THE SAME SHOULD BE COMMUNICATED TO THE ASSESSEE. IN CASE, THE ASSESSEE RAISED ANY OBJECTIONS TO THE REASONS RECORDED FOR REOPENING THE ASSESSMENT, THEN THE SAME SHOULD BE DEALT WITH AT THE EARLIEST AND NECESSARILY BEFORE PASSING OF ASSESS MENT ORDER. THE RELEVANT FINDINGS OF THE HONBLE BOMBAY HIGH COURT VIDE PARA 7 ARE AS UNDER: - 7. IT IS A SETTLED POSITION THAT REOPENING OF ASSESSMENT IS NOT TO BE LIGHTLY DONE. IN FACT, IT LEADS TO UNSETTLING SETTLED POSITIONS. THEREFORE, IT CAN ONLY BE DONE BY THE REVENUE SUBJECT TO STRICTLY SATISFYING THE JURISDICTIONAL REQUIREMENT OF SECTION 147 AND 148 OF THE ACT. IT WAS IN THE LIGHT OF THE ABOVE, THAT THE SUPREME COURT IN GKN DRIVESHAFTS (INDIA) LTD. V. ITO [2003] 2 59 ITR 19 /[2002] 125 TAXMAN 963 HAS LAID DOWN A PROCEDURE/ METHOD TO BE FOLLOWED BEFORE REASSESSING AN ASSESSEE UNDER SECTION 147 OF THE ACT. THE APEX COURT HAS FORMULATED THE PROCEDURE TO THE EFFECT THAT WHENEVER A N OTICE TO REOPEN AN ASSESSMENT UNDER SECTION 148 OF THE ACT IS ISSUED TO AN ASSESSEE, THE REASONS RECORDED IN SUPPORT OF THE SAME MUST BE FURNISHED TO THE ASSESSEE ON HIS FURNISHING THE RETURN OF INCOME. THE ASSESSEE WOULD THEN HAVE AN OPPORTUNITY TO OBJECT TO THE REASONS IN SUPPORT OF THE NOTICE FOR REOPENING AN ASSESSMENT AND THE ASSESSING OFFICER ON CONSIDERATION OF THE OBJECTIONS WOULD DISPOSE OF THE OBJECTIONS BY A SPEAKING ORDER. THE ABOVE PROCEDURE IS BEING CONSISTENTLY FOLLOWED IN ALL CASES OF NOTICE S ISSUED UNDER SECTION 148 OF THE ACT SEEKING TO REOPEN ASSESSMENTS. THE PROCEDURE LAID DOWN BY THE APEX COURT IS A VERY SALUTARY PROVISION AS IT ENSURES THAT AN ASSESSEE IS NOT DRAGGED INTO A REASSESSMENT PROCEEDINGS UNNECESSARILY. THEREFORE, BEFORE COMME NCING THE REASSESSMENT PROCEEDINGS, AN ASSESSING OFFICER CAN HAVE A SECOND LOOK AT HIS REASSESSMENT PROCEEDINGS, AN ASSESSING OFFICER CAN HAVE A SECOND LOOK AT HIS REASONS IN THE CONTEXT OF THE OBJECTIONS OF THE ASSESSEE. TO ENSURE THAT THERE IS DUE APPLICATION OF MIND, THE APEX COURT HAS DIRECTED THAT THE OBJECTIONS BE DISPOSED OF BY A SPEAKING ORDER. THUS, THE BASIS OF THE ENTIRE ABOVE PROCEDURE IS AN HONEST AND OBJECTIVE SECOND LOOK AT THE REASONS FOR REOPENING THE ASSESSMENT IN THE CONTEXT OF THE OBJECTIONS. 11. THE HONBLE BOMBAY HIGH COURT HELD THAT BECAUSE OF NON - DISPOSAL O F OBJECTIONS RAISED, ASSESSMENT ORDER MERITS TO BE SET - ASIDE WITH DIRECTIONS TO THE ASSESSING OFFICER TO DISPOSE OF THE OBJECTIONS OF PETITIONER AND ALLOW PERIOD OF FOUR WEEKS FROM THE DATE OF OBJECTIONS ARE DISPOSED OF, TO THE ASSESSEE TO TAKE NECESSARY R EMEDY BEFORE DECIDING THE ISSUE ON MERITS. THE RELEVANT FINDINGS OF THE HONBLE HIGH COURT VIDE PARA 11 READS AS UNDER: - 11. IN THE ABOVE CIRCUMSTANCES, WE SET ASIDE THE ENTIRE ORDER DATED 20/02/2015 DISPOSING OF THE PETITIONER'S OBJECTION AND RESTORE TH E PETITIONER'S OBJECTION DATED 09/02/2015 TO THE IMPUGNED NOTICE BEFORE THE RESPONDENT - REVENUE. HOWEVER, THE RESPONDENTS WILL ASSIGN THIS ISSUE OF OBJECTIONS RAISED BY THE PETITIONER TO THE IMPUGNED NOTICE TO AN OFFICER OTHER THAN THE ASSESSING OFFICER, WH O AUTHORED THE ORDER DATED 20/02/2015 AND THE DEPONENT OF THE AFFIDAVIT DATED 06/05/2015 FILED IN THE COURT. ITA NO. 160 /PN/20 1 5 MOHINIDEVI BHOJRAJ MANCHANDA 7 12. IN THE FACTS OF THE PRESENT CASE, THE ASSESSEE RECEIVED THE REASONS ON 08.07.2013 AS PER COMMUNICATION OF THE ASSESSING OFFICER OF EVEN DATE, COPY OF WHICH IS PLACED AT PAGES 31 AND 32 OF THE PAPER BOOK. THE ASSESSEE VIDE LETTER DATED 03.10.2013 ACKNOWLEDGES THAT SHE HAD RECEIVED THE REASONS RECORDED FOR ISSUANCE OF NOTICE UNDER SECTION 148 OF THE ACT AND SHE OBJECTED TO THE REASONS RECORDED FO R REOPENING OF THE ASSESSMENT AND POINTED OUT THAT THE INVESTMENT IN SHARES WAS FROM EXPLAINED SOURCES AND OTHER OBJECTIONS WERE ALSO RAISED. SHE FURTHER POINTED OUT THAT SINCE ALL THE TRANSACTIONS WERE SHOWN IN THE RETURN OF INCOME EARLIER SUBMITTED AND THE SAME BEING AVAILABLE AT THE TIME OF ISSUE OF NOTICE UNDER SECTION 148 OF THE ACT, THERE WAS NO NEED TO ISSUE NOTICE UNDER SECTION 148 OF THE ACT. THE ASSESSING OFFICER ADMITS THAT THE ASSESSEE HAS RAISED THE OBJECTIONS TO THE ISSUE OF NOTICE UNDER SEC TION 148 OF THE ACT AND ALSO ENUMERATED THE SAID OBJECTIONS IN THE ASSESSMENT ORDER. HOWEVER, THE SAID OBJECTIONS WERE NOT DISPOSED OF BY A SPEAKING ORDER BY THE ASSESSING OFFICER WITHIN SUITABLE TIME FRAME AND NECESSARILY BEFORE COMPLETING THE ASSESSMENT PROCEEDINGS AGAINST THE ASSESSEE. IN VIEW THEREOF AND FOLLOWING THE PRINCIPLE LAID DOWN BY THE HONBLE BOMBAY HIGH COURT IN V.M. SALGAONCAR SALES INTERNATIONAL VS. ACIT (SUPRA) , I HOLD THAT THE ISSUE NEEDS TO BE SET ASIDE TO THE FILE OF ASSESSING OFFICER TO THE STAGE OF FILING OF OBJECTIONS BY THE ASSESSEE. THE ASSESSING OFFICER SHALL DEAL WITH THE OBJECTIONS RAISED BY THE ASSESSEE AGAINST THE REOPENING OF ASSESSMENT UNDER SECTION 148 OF THE ACT AND ALSO PASS NECESSARY ORDER IN THIS REGARD AFTER HEARING THE LEARNED AUTHORIZED REPRESENTATIVE FOR THE ASSESSEE. THEREAFTER, THE ASSESSING OFFICER IS TO ALLOW A PERIOD OF FOUR WEEKS TO THE ASSESSEE TO TAKE ANY SUITABLE REMEDY AS ADVISED. THE ASSESSMENT PROCEEDINGS SHALL BE COMPLETED THEREAFTER. ACCORDINGLY, TH E ISSUE IS SET ASIDE TO THE FILE OF ASSESSING OFFICER. THE ITA NO. 160 /PN/20 1 5 MOHINIDEVI BHOJRAJ MANCHANDA 8 ADDITIONAL GROUND OF APPEAL RAISED BY THE ASSESSEE IS THUS, ALLOWED . I N VIEW OF SETTING ASIDE THE ISSUE OF PASSING SPEAKING ORDER AGAINST THE OBJECTIONS RAISED BY THE ASSESSEE OF REOPENING THE AS SESSMENT UNDER SECTION 148 OF THE ACT, THE OTHER GROUNDS OF APPEAL RAISED BY THE ASSESSEE ARE NOT BEING ADJUDICATED. 1 3 . IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED ON THIS 5 TH DAY OF AUGUST , 201 6 . SD/ - (SUSHMA CHOWLA) / JUDICIAL MEMBER / PUNE ; DATED : 5 TH AUGUST , 201 6 . GCVSR GCVSR / COPY OF THE ORDER IS FORWARDED TO : 1. / THE APPELLANT ; 2. / THE RESPO NDENT; 3. ( ) / THE CIT(A) - I , NASHIK ; 4. / THE CIT - 1 , NASHIK ; 5. 6. , , , - / DR SMC , ITAT, PUNE; / GUARD FILE . / BY ORDER , // TRUE COP Y // / SR. PRIVATE SECRETARY , / ITAT, PUNE