The Dy. Commissioner of Income Tax, Circle-2(1)(2), Ahmedabad V. M/s. Mundra Finvest Gujarat Ltd., Ahmedabad

ITA 1844/AHD/2016

• Counselvise Citation: [2022] 103 COUNSELVISE.COM (IT) 8853 (ITAT-AHMEDABAD)
• Duration Of Justice: 6 year(s) 3 month(s) 29 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-11-2022
• Appeal Filed By: Department
• Order Result: PartlyAllowed
• Bench Allotted: A
• Next Hearing Date: 22-08-2022
• Assessment Year: 2012-2013
• Appeal Filed On: 10-07-2016
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Bogus purchase; Corroborative evidences; TDS; Rule 8D; Set aside; CHAPTER IV
• Section: 143(3); 14A; 115JB; 133(6); 13

Judgement Text

आयकर अपीलीय अिधकरण, अहमदाबाद Ɋायपीठ IN THE INCOME TAX APPELLATE TRIBUNAL, ‘’ A” BENCH, AHMEDABAD BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER And SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER आयकर अपील सं./ITA No. 1844/AHD/2016 िनधाŊरण वषŊ/Asstt. Year: 2012-2013 D.C.I.T., Circle-2(1)(2), Ahmedabad. Vs. M/s. Mundra Finvest Gujarat Ltd., 10B, Sumantinagar Society, Nr. Sindhi School, Usmanpura, Ahmedabad-380013. PAN: AABCM0526H (Applicant) (Respondent) Assessee by : Smt. Astha Maniar, A.R Revenue by : Shri Sudhendu Das, Sr.DR सुनवाई की तारीख/Date of Hearing : 23/08/2022 घोषणा की तारीख /Date of Pronouncement: 09/11/2022 आदेश/O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: The captioned appeal has been filed at the instance of the Revenue against the order of the Learned Commissioner of Income Tax (Appeal)-2, Ahmedabad, dated 29/04/2016 arising in the matter of Assessment Order passed under s. 143(3) of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Year 2012-2013. ITA no.1844/AHD/2016 Asstt. Year 2012-13 2 2. The Revenue has raised following grounds of appeal: 1. The Ld.CIT(A) has erred in law and on facts in restricting the disallowance u/s.14A to Rs.71,436/- as against Rs.12,21,613/- on account of which the book profit u/s.115JB has also been reduced to that extent without properly appreciating the facts of the case and the material brought on record. 2. The Ld.CIT(A) has erred in law and on facts in restricting the disallowance on account of bogus purchases to Rs.5,00,000/- as against Rs.2,63,08,871/- made by the AO without properly appreciating the facts of the case and the material brought on record. 3. The Ld.CIT(A) erred in law and facts in deleting the addition of commission expenses amounting to Rs.19,29,530/- made by the AO without appreciating the facts of the case and the material brought on record. 4. On the facts and in the circumstances of the case, the Ld.CIT(A) ought to have upheld the order of the Assessing Officer. 5. It is therefore, prayed that the order of the Ld.CIT(A) may be set aside and that of the Assessing Officer may restored to the above extent. 3. The first issue raised by the revenue is that the Ld. CIT(A) erred in restricting the disallowance made by the AO under the provisions of section 14A r.w. Rule 8D of the Act to Rs. 71,436/- against the amount disallowed by the AO at Rs. 12,21,613/- under normal computation of income as well as under book profit u/s 115JB of the Act. 4. The facts in brief are that the assessee in the present case is a limited company and engaged in the business of trading in Gold, Silver and MCX trading of raw cotton. The assessee in the year under consideration has shown dividend income of Rs. 71,435/- which was claimed as exempted under section 10(34) of the Act. 5. However, the AO found that the assessee has claimed interest expenses to the tune of Rs. 58,93,291/- only. Likewise, the assessee must have incurred administrative expenses for managing the investments shown at Rs. 2,49,57,598/- only. Thus, the AO was of the view that the disallowance needs to be made against ITA no.1844/AHD/2016 Asstt. Year 2012-13 3 the exempted income in the manner provided u/s 14A r.w. Rule 8D of Income tax Rules. Accordingly, the AO worked out the disallowance as under: Sr.No. Particulars Amount (inRs.) 1. Interest Expenses 1096837 2. Administrative Expenses 124775 5.1 Thus, the AO made the disallowance of Rs. 12,21,613/- while computing the income under the normal computation of income as well as while determining the book profit under the provision of section 115JB of the Act. 6. Aggrieved assessee preferred an appeal to the Ld. CIT(A), who has restricted the disallowance to the tune of Rs. 71,436/- being the amount of exempted income. 7. Being aggrieved by the order of the Ld. CIT(A), Revenue is in appeal before us. 8. Both the Ld. AR and Ld. DR, before us vehemently supported the order of the authorities below to the extent favourable to them. 8.1. We have heard the rival contentions of both the parties and perused the materials available on record. There is no ambiguity to the fact that the assessee has claimed exempted income to the tune of Rs. 71,436/- whereas the AO has made disallowances of Rs. 12,21,613/- only. We find that it is settled position of law that the disallowances under section 14A of the Act cannot exceeds the amount of exempted income claimed by the assessee. In holding so, we find support and guidance from judgment of Hon’ble Gujarat High Court in the case of Corrtech Energy Ltd reported in 372 ITR 97 wherein it was held as under: Section 14A(1) provides that for the purpose of computing total income under chapter IV, no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income which does not form part of the total income under the Act. In the instant case, the Tribunal has recorded the finding of fact that the assessee did not make any claim for exemption of any income from payment of tax. It was on this basis that the Tribunal held that disallowance under section 14A could not be made. In the process tribunal relied on the decision of Division Bench of Punjab and Haryana High Court in case of CIT v. Winsome Textile Industries Ltd. [2009] 319 ITR 204 in which also the Court had observed that where the assessee did not make any claim for exemption, section 14A could have no application. ITA no.1844/AHD/2016 Asstt. Year 2012-13 4 8.2. In view of the above we do not find any infirmity in the finding of learned CIT(A) as limiting the disallowances under section 14A of the Act to the extent of exempted income. 8.3. Coming to disallowances/adjustment to the book profit under the provision of clause (f) of the explanation 1 to section 115JB of the Act, we note that the Special Bench of the Hon’ble Delhi Tribunal in the case of ACIT vs. Vireet Investment Pvt. Ltd. reported in 82 Taxmann.com 415 has held that the disallowances made u/s 14A r.w.r. 8D cannot be the subject matter of addition while determining the net profit u/s 115JB of the Act. The relevant portion of the said order is reproduced below: “In view of above discussion, the computation under clause (f) of Explanation 1 to section 115JB(2), is to be made without resorting to the computation as contemplated under section 14A, read with rule 8D of the Income-tax Rules, 1962.” 8.4. The ratio laid down by the Hon’ble Tribunal is squarely applicable to the facts of the case on hand. Thus it can be concluded that the disallowance made under section 14A r.w.r. 8D cannot be resorted while determining the expenses as mentioned under clause (f) to explanation 1 to section 115JB of the Act. 8.5. However, it is pertinent to note that the disallowance needs to be made with respect to the exempted income in terms of the provisions of clause (f) to section 115JB of the Act while determining the book profit. In holding so, we draw support from the judgment of Hon’ble Calcutta High Court in the case of CIT Vs. Jayshree Tea Industries Ltd. in GO No.1501 of 2014 (ITAT No.47 of 2014) dated 19.11.14 wherein it was held that the disallowance regarding the exempted income needs to be made as per the clause (f) to Explanation-1 of Sec. 115JB of the Act independently. The relevant extract of the judgment is reproduced below:- “We find computation of the amount of expenditure relatable to exempted income of the assessee must be made since the assessee has not claimed such expenditure to be Nil. Such computation must be made by applying clause (f) of Explanation 1 under section 115JB of the Act. We remand the matter for such computation to be made by the learned Tribunal. ITA no.1844/AHD/2016 Asstt. Year 2012-13 5 We accept the submission of Mr. Khaitan, learned Senior Advocate that the provision of section 115JB in the matter of computation is a complete code in itself and resort need not and cannot be made to section 14A of the Act.” 8.6. Given above, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High Court in the case of CIT Vs. Jayshree Tea Industries Ltd. (Supra). 8.7. Now the question arises to determine the disallowance as per the clause (f) to Explanation-1 of Sec. 115JB of the Act independently. In this regard, we note that there is no mechanism/ manner given under the clause (f) to Explanation-1 of Sec. 115JB of the Act to workout/ determine the expenses with respect to the exempted income. Therefore in the given facts & circumstances, we feel that ad- hoc disallowance will serve the justice to the Revenue and assessee to avoid the multiplicity of the proceedings and unnecessary litigation. Thus we direct the AO to make the disallowance of 1% of the exempted income as discussed above under clause (f) to Explanation-1 of Sec. 115JB of the Act. We also feel to bring this fact on record that we have restored other cases involving identical issues to the file of AO for making the disallowance as per the clause (f) to Explanation-1 of Sec. 115JB of the Act independently. But now we note that there is no mechanism provided under the clause (f) to Explanation-1 of Sec. 115JB of the Act to make the disallowance independently. Therefore our action for restoring back the issue to the file of AO would unnecessarily cause further litigation. Thus we limit the disallowance on an ad-hoc basis @ 1 % of the exempted income as per the clause (f) to Explanation-1 of Sec. 115JB of the Act. Thus in view of the above the ground of appeal of the Revenue is partly allowed. 9. The second issue raised by the Revenue is that the Ld. CIT(A) erred in restricting the disallowance to Rs. 5,00,000/- against the disallowance made by the AO at Rs. 2,63,08,871/- on account of bogus purchases. ITA no.1844/AHD/2016 Asstt. Year 2012-13 6 10. The assessee in the year under consideration has shown purchases, among other parties, from the following parties as detailed below: Uma Cotton Industries 9796283 Somnath Cottgin(I) Pvt. Ltd. 13812588 11. The AO during the assessment proceedings found certain infirmities in the purchases shown by the assessee from the parties as discussed above. 1. The notices u/s 133(6) of the Act, were issued for verification of the purchases but the same were returned as unserved. 2. The assessee has shown debit notes issued by the party namely Orchid Shipping Pvt. Ltd. which was claimed to be CNF agent whereas in the bill of lading this CNF agent was shown M/s Crescent Shipping Agency(I) Ltd. 3. In the transportation bill issued by Ranjit Transport Co. dated 08.09.2011, it was seen that the goods from Tankara have been transported to Ahmedabad instead of transport them directly to the port for the purpose of export. 4. The Gujarat Commercial Tax Department has cancelled VAT registration No. of Uma Cotton Industries and M/s Somnath Cottgin(I) Pvt. ltd as dealer with effect from 31.03.2014 and 31.03.2012 respectively. 5. The person appeared on behalf of M/s Uma Cotton Industries was neither the partner nor the employee of the party. Likewise, such person Shri Yogesh G Saneter has not produced the details of the purchase stock and the copy of the income tax return. ITA no.1844/AHD/2016 Asstt. Year 2012-13 7 12. In view of the above, the AO was of the view that the purchases shown by the assessee are bogus and therefore he disallowed the same by adding the sum of Rs. 2,63,08,871/- to the total income of the assessee. 13. Aggrieved assessee preferred an appeal to the Ld.CIT(A). 14. The assessee before the Ld. CIT(A), submitted that there was no doubt raised by the AO with respect to the export of the raw cotton which was not possible without the purchase. There were many clinching documentary evidence in the form of export invoices, shipping document, bill of lading and shipping bill along with the bank account statement wherein export proceeds were realized. If the purchases are not allowed than the corresponding sales cannot be possible for such export. 14.1 In the case of non-service of notice u/s 133(6) of the Act, the authorized representative of M/s Uma Cotton Industries appeared before the AO along with the books of accounts. The statement was also recorded u/s 131(1) of the Act, and no doubt of whatsoever was raised by the AO except that the person who appeared was neither the partner nor the employees of M/s Uma Cotton Industries. As such the AO failed to realize that the person namely Shri Yogesh G. Sanetar was the nephew of the managing partner namely Shri Babu A. Patel. The assessee on behalf of M/s Somnath Cottgin (I) Pvt. submitted that due to short notice received at the close of the year, the authorized person cannot appear. However, the copy of confirmation of account as well as bills were produced. Likewise, M/s Cresent Shipping Agency(I) Ltd. is the carrier of the cargo i.e. charter owner of the shipping and it is not the C&F agent as perceived by the AO. 14.2 As such M/s Crescent Shipping Agency(I) Ltd., as the C&F agent of assessee, its job was confined to clearing and loading of the cargo on the ship. With respect to the transport bill shown for the delivery of goods from Tankara to Ahmedabad, the assessee submitted that the goods were actually delivered at the port but due to clerical mistake the destination was shown as Ahmedabad. However, this clerical mistake cannot be made any basis to draw an inference against the assessee. ITA no.1844/AHD/2016 Asstt. Year 2012-13 8 14.3 The assessee also submitted that the purchase was made against form H which was downloaded from the VAT Department which was not doubted by the AO. Therefore no adverse inference can be drawn on the basis to transport bills. 14.4 The cancellation of certificate by the VAT Department of the parties namely M/s Uma cotton Industries and M/s Somnath Cottgin(I) Pvt. Ltd. has no relevance for deciding the issue on hand. There can be various reason for cancellation. However, the purchase were made against the form H which was duly issued by the VAT Department. Furthermore, all the suppliers have confirmed the transaction carried out with the assessee. The assessee also submitted that there was VAT Assessment in the year under consideration wherein all the sales and purchases shown by the assesse were duly exempted vide letter dated 14.03.2016. In view of the above, it cannot be held that the assessee has adopted colorable device by showing the bogus purchase. 15. The Ld. CIT(A) after considering the submission of the assessee has deleted the addition made by the AO in part by observing as under: 5.4 Having considered the facts and submissions, it has been noticed that the AO has noticed that in respect of both the parties the notices issued u7s. 133(6) of I.T. Act have been returned unserved. On the other side, the appellant has submitted the confirmations of the supplier parties and requested the above parties before the AO for verification. In compliance, Shri Yogesh G. Sanepara, a nephew of Managing Partner, Shri Babu A Patef duly authorized on behalf of M7s. Urna Cotton Industries attended before the AO and filed confirmation letter as per the books of account of M7s. Uma Cotton Industries. As per the appellant, the AO recorded the statement also and nothing has been found adversely except to the observation that neither Shri Yogesh was a Partner nor on employee of M7s. Uma Cotton Industries. The AO's observation in this regard would not be enough to form an opinion for declaring the purchases as bogus from Urna Cotton Industries merely that he was not a partner or an employee. Apart from confirmation, copy of bill of sale of cotton and bank statement of the aforesaid party showing credit of the payment received from appellant were submitted. The AO did not controverted the fact of purchases from the said concern. Once, the aforesaid person has attended with the Power of Attorney given by M7s. Uma Cotton Industries, then it was a valid appearance before the AO and the AO's observation in this regard is without any basis. 5.5. With regard to the personal appearance of M/s. Somnath Cottgin Pvt. Ltd., it was not possible due to short span of time granted by the AO, but the confirmation of the said party along with copy of bill of sale of cotton was submitted as per letter dated 30-03-2015. ITA no.1844/AHD/2016 Asstt. Year 2012-13 9 5.6. The AO has made few observations about the discrepancies noticed in the debit notes and transport receipts which have been explained by the appellant in the written submission reproduced under preceding paras and those did not have any material impact of the issue under consideration. Even with regard to the cancellation of the TIN by Gujarat Commercial Tax Dept. of M/s. Uma Cotton Industries on 31-03-2014 and M/s. Somnath Cottgin Pvt. Ltd. from 31-03-2012 would not be material for consideration of the issue involved as those purchases from those parties are prior to the date of cancellation of the TIN. 5.7 On going through the details of purchases of the cotton bale from these two parties and corresponding export of those cotton bales the appellant had derived the gross profit of Rs. 74.62.797/- and net profit of Rs. 60,98,713A on the export of Rs.5,36,46,699/-. Thus, the appellant has derived the gross profit rate of 13.91 % and net profit rate of 11.36% which is fair and reasonable considering. The AO has not quoted even a single instance of any third party whose gross profit rate and net profit rate was higher than the shown by the appellant in its books of account. ***************************************************************** 5.8. For ready reference the working of the gross profit and net profit derived by the appellant on the transactions of purchase from the above two parties and sales thereof is also reproduced as under:- F. Y. 2011-12 Profit and Loss Account (Raw Cotton) Particulars Debit Amount (Rs.) Particulars Credit Amount (Rs.) Purchase raw cotton 46183902.00 Sales Raw Cotton 53646699.00 Gross Profit 7462797.00 Total 53,646,699.00 Total 53,646,699.00 Sales Commission 216000.00 Gross Profit b/f 7462797.00 Transport & forwarding exp. 1148084.00 1364084.00 Net Profit 6098713.00 Total 7,462,797.00 7,462,797.00 5.9. It has been further noticed that the movement of goods from the place of purchase to the port as mentioned with the truck no. in the transport bills and lorry receipt no, which ore properly supported transportation. Thus, there remains no discrepancy on this account. 5.10. In view of the above discussion, the AO's action for making the disallowance of the purchases for the above two parties is totally unjustified and more particularly when corresponding sales / export thereof has been accepted. The AO has not brought anything on record '"^^ "^showing that the purchases were not made from these two parties but third parties, thus there means no doubt for purchases from these. However, because of few minor discrepancies noticed by the AO, 'a lumpsum disallowance of Rs.5.00 lacs is made to plug the leakage of revenue on this account. Thus, the disallowance of Rs.5.00 lacs is confirmed and relief is granted of the balance disallowance of Rs.2,58,08,871/- ITA no.1844/AHD/2016 Asstt. Year 2012-13 10 16. Being aggrieved by the order of the Ld. CIT(A), the revenue is in appeal before us. 17. Both the Ld. DR and Ld. AR, before us relied on the order of the authorities below as favourable to them. 18. We have heard the rival contentions of both the parties and perused the materials available on record. From the preceding discussion, we note that the AO has doubted on the genuineness of the purchases shown by the assessee for the reasons which have been elaborated above and therefore the same was disallowed. However, the Ld.CIT(A), found that the sale was not possible without having the purchase and therefore he allowed the grounds of appeal of the assessee in part. 18.1 Now the controversy arises whether the purchase shown by the assessee is bogus in nature. In this regard we note that the assesse has shown export sales which was duly supported based on form H, bill of lading, shipping bill etc. Likewise, there was received money against such export sales. Thus, all these cumulative informations suggest that the assessee without making the purchase, cannot export the goods. There were various documents filed by the assessee in his form of confirmation, sales bills of the parties. Besides, the authorized representative appeared on behalf of M/s Uma Cotton Industries, all these documents cannot be neglected merely on the reasoning that there was some mismatch in the transport bills as discussed above. Thus, in view of the above, and after considering the facts in totality we do not find any reason to interfere in the order of the Ld. CIT(A), hence the ground of appeal of the revenue is hereby dismissed. 19. The last issue raised by the revenue is that the Ld. CIT(A), erred in deleting the addition made by the AO for Rs. 19,29,530/- on account of commission expenses. ITA no.1844/AHD/2016 Asstt. Year 2012-13 11 20. The assessee in the year under consideration has incurred commission expenses in relation to the export of cotton sales amounting to Rs. 2,16,000/- which were paid to two parties namely Shri Nivas export and Gautam trading Company. Likewise, the assessee has also paid commission to six parties amounting to Rs. 17,13,530/- in relation to the sale of Gold bullion. The assessee to justify the genuineness of the expenses has furnished the copy of the agreement, assessment details of the respective parties, TDS certificate etc. However, the AO found that the assessee failed to provide the details of the services rendered by the commission agent. Accordingly, the AO disallowed the same and added to the total income of the assessee 21. On appeal, the Ld. CIT(A) deleted the addition made by the AO by observing as under: 6.5. Having considered the facts and submission, it has been noticed that the appellant has provided the copies of the debit notes raised by the agents, confirmation of the agents besides copy of Form No. 16A and all these documents contain the full address of the agents and their PAN No., besides the details of their bank account in the case of Gautam Trading Co. The appellant has also made the TDS u/s. 194H of the I.T. Act and deposited the same in the Govt. Account. The commission payments have been made through banking channels and hence genuineness has been duly proved by the appellant. Nothing has been brought on record by the AO through an enquiry that the claim of expenditure was made bogus. 6.6. In view of the overwhelming evidences, the claim of the commission of Rs.2,16,0007- is found genuine and hence disallowance made by the AO is deleted. Thus, ground of appeal is allowed. 6.7. The appellant has taken the ground with regard to the commission payment of Rs.17,13,530/- to six commission agents noted at page No. 13 of the assessment order, for the sale of bullion. The AO observed that the payment to all the parties were made on a single day i.e. 23-02-2012 and these credits were found withdrawn on the next day in the bank accounts of the agents. The AO also observed that no details of the agent specific work have been submitted. Nothing about their educational qualification and their knowledge about the assessee's business has been brought on the record to prove that actual services have been rendered by the agents. Thus, the AO was not satisfied with regard to the genuineness of the claim of commission paid to the above parties. 6.8. On the other side, the appellant has submitted the copies of the debit notes received from the parties, copies of confirmation of account, details of TDS made on the commission payments, TDS certificate copies besides bank statement showing the payment to the agents through banking channels. It was also argued that the commission to the parties were made which was evident from the above said documents. The aforesaid agents have duly confirmed the transactions carried out by them in response to notice u/s. 133(6) of I.T. Act. It also filed the copies of agreements executed with the agents. The commission agents were not related parties as per section 40A(2)(b] of I.T. Act. The appellant also submitted ITA no.1844/AHD/2016 Asstt. Year 2012-13 12 that the commission payment to all the six agents have been accepted in the scrutiny assessment completed by the AO u/s. 143(3) in respect to appellant for Assessment Year 2013-14 and no such disallowance of commission has been made by the AO. 6.9. Having considered the facts and submission, it has been noticed that the appellant has provided the copies of the debit notes raised by the agents, confirmation of the agents besides copy of Form No. 16A and all these documents contain the full address of the agents and their PAN No. etc. The appellant has also made the IDS u/s. 194H of the I.T. Act and deposited the same in the Govt. Account. The commission payments have been made through banking channels and hence genuineness has been duly proved by the appellant. Nothing has been brought on record by the AO through an enquiry that the claim of expenditure was made bogus. Even the AO has accepted the commission payment to these six agents in Assessment Year 2013-14 and no disallowance in this regard have been made. 6.10 In view of the overwhelming evidences as discussed above, the claim of the commission is found genuine and hence disallowance with commission made by the AO is deleted. Thus, ground of appeal is allowed. 22. Being aggrieved by the order of the Ld. CIT(A), the Revenue is in appeal before us. 23. Both the Ld. DR and Ld. AR, before us relied on the order of the authorities below as favourable to them. 24. We have heard the rival contentions of both the parties and perused the materials available on record. Indeed the assessee was able to furnish the necessary supporting evidence relating to the commission expenses in the form of debit note, confirmation, TDS certificate, and agreement bank account statement. Likewise, the commission parties have also confirmed the transaction in response to the notice issued to them u/s 133(6) of the Act. However, all these documentary evidences are not sufficient enough until and unless it is clear based on the evidences that the commission agents have rendered services to the assessee. It is the onus upon the assessee to bring such services based on the cogent materials but we note that there was no evidence brought on record about the services rendered by the commission agent, therefore, we are not inclined to uphold the order of the Ld. CIT(A), on the reasoning that the commission expenses have not been incurred by the assessee wholly and exclusively for the purpose of business. On perusal of the agreement, we note that there were executed on 01/04/2011 and the same were not notarized. Furthermore, most of the payment for the commission was made at ITA no.1844/AHD/2016 Asstt. Year 2012-13 13 the fag end of the Assessment Year though the assessee was carrying out business throughout the year. All these facts strongly suggest that the assessee has manipulated it profit by claiming commission expenses. Hence the ground of Revenue is allowed. 25. In the result, the appeal filed by the Revenue is partly allowed. Order pronounced in the Court on 09/11/2022 at Ahmedabad. Sd/- Sd/- (SIDDHARTHA NAUTIYAL) (WASEEM AHMED) JUDICIAL MEMBER ACCOUNTANT MEMBER (True Copy) (True Copy) Ahmedabad; Dated 09/11/2022 Manish