VIJAY KEDIA (HUF), Jaipur V. ACIT, Jaipur

ITA 197/JPR/2016

• Counselvise Citation: [2018] 126 COUNSELVISE.COM (IT) 2160 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 10 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 29-01-2018
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: Not Allotted
• Assessment Year: 2007-2008
• Appeal Filed On: 03-03-2016
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Assessee Lawyers: S R SHARMA; R K BHATRA
• Keywords: Bogus purchase; Rejection of books of accounts; Accommodation entries
• Section: 69C

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S, JAIPUR JH FOT; IKY JKO] U;KF;D LNL; ,OA JH FOE FLAG ;KNO] YS[KK LNL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM VK;DJ VIHY LA- @ ITA NO. 197/JP/2016 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2007-08 M/S VIJAY KEDIA (HUF) 1307, KEDIA HOUSE, GOPALJI KA RASTA, JAIPUR. CUKE VS. THE ACIT, CIRCLE-1, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AABHV6449M VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT VK;DJ VIHY LA- @ ITA NO. 248/JP/2016 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2007-08 THE ACIT, CIRCLE-1, JAIPUR. CUKE VS. M/S VIJAY KEDIA (HUF) 1307, KEDIA HOUSE, GOPALJI KA RASTA, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AABHV6449M VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI S.R. SHARMA & SHRI R.K. BHATRA (C.A.) JKTLO DH VKSJ LS @ REVENUE BY : SHRI AJAY MALIK (ADDL. CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 24/01/2018 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT: 29/01/2018 VKNS'K@ ORDER ITA NO. 197& 248/JP/2016 M/S VIJAY KEDIA (HUF) VS. ACIT JAIPUR. 2 PER: VIJAY PAL RAO, J.M. THESE CROSS APPEALS ARE DIRECTED AGAINST THE ORDER DATED 22.01.2016 OF CIT(A), JAIPUR FOR THE ASSESSMENT Y EAR 2007-08. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS:- 1. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE LD. CIT(A) IS WRONG, UNJUST AND HAS ERRED IN LAW IN CONFIRMING FINDING RECORDED BY THE ASSESSING OFFICER THAT PURC HASE AGGREGATING TO RS. 92,60,035/- (WRONGLY COMPUTED BY THE ASSESSING OFFICER AT RS. 85,64,509/-) MADE BY THE A PPELLANT FROM M/S AVI EXPORTS, M/S SUN DIAN AND M/S VITRAG JEWELL S ARE NOT GENUINE AND BOGUS. 2. THE LD. CIT(A) IS FURTHER WRONG AND HAS ERRED IN LAW IN CONFIRMING REJECTION OF BOOKS OF ACCOUNTS OF THE AP PELLANT BY THE ASSESSING OFFICER U/S 145(3) OF THE I.T. ACT, 1961 AND IN UPHOLDING ADDITION TO THE EXTENT OF RS. 13,89,005/- BEING 15% OF ABOVE SAID ALLEGED UNVERIFIABLE PURCHASES, AS TRADING ADDITION U/S 69C OF THE I.T.ACT, 1961. 3. THE APPELLANT CRAVES LEAVE TO ADD TO, AMEND OR M ODIFY THE ABOVE GROUNDS OF APPEAL OR TO WITHDRAW ANY OF THEM. 2. AT THE TIME HEARING, THE LEARNED COUNSEL FOR TH E ASSESSEE HAS STATED AT BAR THAT THE ASSESSEE DOES NOT PRESS GROU ND NO. 1 AND THEREFORE THE SAME MAY BE DISMISSED AS NOT PRESSED. THE LD. DR HAS RAISED NO OBJECTION GROUND NO. 1 OF THE ASSESSEES APPEAL IS DISMISSED AS NOT PRESSED. ACCORDINGLY THE GROUND NO. 1 OF THE ASSESSEES APPEAL IS DISMISSED BEING NOT PRESSED. ITA NO. 197& 248/JP/2016 M/S VIJAY KEDIA (HUF) VS. ACIT JAIPUR. 3 3. GROUND NO. 2 IS REGARDING THE REJECTION OF BOOKS OF ACCOUNTS U/S 145(3) OF THE ACT AND SUSTAINING THE ADDITION TO TH E EXTENT OF 15% OF THE UNVERIFIABLE PURCHASES. 4. WE HAVE HEARD LD. AR AS WELL AS DR AND CONSIDERE D THE RELEVANT MATERIAL ON RECORD. THE AO NOTED THAT THE ASSESSEE HAS SHOWN THE PURCHASE FROM SOME OF THE PARTIES WHO ARE INDULGED IN PROVIDING BOGUS BILLS WITHOUT ACTUAL DELIVERY OF GOODS. THE AO HAS CONSIDERED THE FACTS AS IT CAME OUT DURING THE INVESTIGATION MADE BY THE INVESTIGATION WING IN CASE OF SHRI R.K. JAIN WHO WAS RUNNING M/S AVI E XPORTS, M/S SUN DIAN AND M/S VITRAG JEWELLS. AFTER REJECTING THE BOOKS O F ACCOUNTS, THE ASSESSING OFFICER HAS MADE AN ADDITION OF UNVERIFIA BLE/BOGUS PURCHASE OF RS. 85,64,509/- FROM THESE THREE PARTIES NAMELY M/S AVI EXPORTS, M/S SUN DIAN AND M/S VITRAG JEWELLS. THE ASSESSEE CHALL ENGED THE ACTION OF THE AO BEFORE THE LD. CIT(A), THE LD. CIT(A) THOUGH CONFIRMED THE REJECTION OF BOOKS OF ACCOUNTS U/S 145(3) OF THE AC T HOWEVER, RESTRICTED THE ADDITION TO 15% OF THE ALLEGED BOGUS PURCHASE. 5. HAVING CONSIDERED THE RIVAL SUBMISSIONS AS WELL AS RELEVANT MATERIAL ON RECORD WE NOTE THAT THE ASSESSING OFFIC ER HAS NOT DISPUTED THE SALE OF THE ASSESSEE WHICH IS CORRESPONDING TO THE PURCHASE HOWEVE, THE BOOKS OF ACCOUNTS WERE REJECTED BECAUSE OF THE REASONS ITA NO. 197& 248/JP/2016 M/S VIJAY KEDIA (HUF) VS. ACIT JAIPUR. 4 THAT THAT ASSESSEE HAS MADE PURCHASE FROM THESE THR EE PARTIES WHO WERE INDULGED FOR PROVIDING BOGUS BILLS WITHOUT ANY ACTUAL DELIVERY OF GOODS. THEREFORE, ONCE THE BOOKS OF ACCOUNTS ARE RE JECTED BY THE AO THE INCOME OF THE ASSESSEE IS REQUIRED TO BE COMPUT ED ON ESTIMATED BASIS AND BEST DECISION OF THE AO. THE AO CANNOT MA KE AN ADDITION TO THE BOOK RESULT ON ACCOUNT OF PURCHASE WHICH IS PAR T OF THE TRADING ACCOUNT AND THEREFORE, AFTER REJECTION OF BOOKS OF ACCOUNTS ONLY THE COURSE OF ACTION LEFT WITH THE AO ASSESSEE IS TO ES TIMATE THE INCOME BY APPLYING PROPER GP OR NP RATE. THE LD. AR HAS PLACE D RELIANCE ON THE DECISION OF COORDINATE BENCH OF THIS TRIBUNAL DATED 26.12.2017 IN CASE OF DCIT VS. M/S GEMS PARADIES IN ITA NO. 747/JP2012 . WE FIND THAT THE TRIBUNAL SAID CASE WHILE CONSIDERING AN IDENTICAL I SSUE HAS HELD IN PARA 5 AS UNDER:- 5. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WEL L AS RELEVANT MATERIAL ON RECORD. THE REVENUE IS AGGRIEV ED BY THE IMPUGNED ORDER BY THE LD. CIT(A) WHEREBY THE ADDITI ON MADE BY THE AO EQUIVALENT TO 25% OF THE UNVERIFIABLE PURCH ASE WAS RESTRICTED BY APPLYING THE GP ADDITION @ 25.50%. WE ARE OF THE CONSIDERED VIEW THAT ONCE THE BOOKS OF ACCOUNT ARE REJECTED BY THE AO THEN, THE ONLY COURSE OF ACTION LEFT WITH TH E AO IS TO ASSESS THE INCOME OF THE ASSESSEE ON THE BASIS OF E STIMATE AND BEST JUDGMENT. THE ASSESSING OFFICER AFTER REJECTIO N OF BOOKS OF ACCOUNT HAS FURTHER MADE ADDITION OF 25% OF TAINTED SALES TO THE BOOKS RESULT WHICH IS NOT PERMISSIBLE WHEN THE AO R ESORTED INVOKE THE PROVISIONS OF SECTION 145(3) OF THE ACT. THUS, THIS ITA NO. 197& 248/JP/2016 M/S VIJAY KEDIA (HUF) VS. ACIT JAIPUR. 5 ACTION OF THE AO IS CONTRARY TO THE DECISION OF REJ ECTING THE BOOKS OF ACCOUNTS. ACCORDINGLY, WE DO CONCUR WITH THE VIE W OF THE LD. CIT(A) IN APPLYING THE GP RATE FOR ASSESSMENT OF TH E INCOME OF THE ASSESSEE AFTER THE REJECTION OF BOOKS OF ACCOUN T. THIS TRIBUNAL COMPRISING THE SAME COMBINATION IN CASE OF CIT VS. ALLIED GEMS CORPORATION IN ITA NO. 794/JP/2011 VIDE ORDER DATE D 15.12.2017 CONSIDERING THEN AN IDENTICAL ISSUE HAS HELD IN PAR A 5 AS UNDER:- 5. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WE LL AS RELEVANT MATERIAL ON RECORD. THE ASSESSING OFFICER REJECTED THE BOOKS OF ACCOUNT BY INVOKING THE PROVISIONS OF SECT ION 145(3). THE ISSUE OF REJECTION OF BOOKS OF ACCOUNTS IS INVO LVED IN THE CROSS OBJECTION FILED BY THE ASSESSEE, THEREFORE, W E DEAL WITH THIS ISSUE WHILE DECIDING THE CROSS OBJECTION. ONCE, THE BOOKS OF ACCOUNTS ARE REJECTED BY THE AO THE ONLY COURSE OF ACTION LEFT TO THE AO IS TO ASSESS THE INCOME OF THE ASSESSEE ON T HE BASIS OF BEST JUDGMENT AND GP RATE IS CONSIDERED AS PROPER AND REASONABLE BASIS AND GUIDANCE FOR THE BEST JUDGMENT . ONCE, THE BOOKS RESULT ARE REJECTED THE ASSESSING OFFICER CAN NOT PROCEED TO MAKE AN ADDITION TO THE INCOME OFFERED BY THE ASSES SEE AS PER BOOKS RESULT. HOWEVER, THE AO IN THE CASE OF THE AS SESSEE INSTEAD OF APPLYING THE GP RATE MADE ON ADDITION@ 25% OF TH E PURCHASES TO THE BOOK RESULTS. THIS ACT OF THE ASSESSING OFFI CER ITSELF CONTRADICTS THE DECISION OF REJECTING THE BOOKS OF ACCOUNTS AND BOOKS RESULT. THE TRIBUNAL IN ASSESSEES OWN CASE F OR THE ASSESSMENT YEAR 2006-07 HAS CONSIDERED THIS ISSUE A ND UPHELD THE ORDER OF THE LD. CIT(A) IN PARA 2.20 AND 2.30 A S UNDER:- 2.20 HENCE, THERE ARE CERTAIN CONCERNS FOR WHICH R EVENUE GOT EVIDENCE IN THE FORM OF STATEMENT RECORDED IN RESPE CT OF SUCH PARTIES, OPENING BALANCE IS RS. 37,06,175/- WHILE T HE CLOSING BALANCE IS RS. 42,81,496/-. IT MEANS THAT THERE IS AN ACCRETION OF AMOUNT OF RS. 5.75/- LACS. IT MEANS THAT TO THIS EX TENT, ACCRETION IN PURCHASE IS WITHOUT SUPPORTING THE CORRECT BILLS . OF COURSE, TOTAL OPENTING BALANCE OF ALL PARTIES IS RS. 1,15,43,782/ - AND THE CLOSING BALANCE IS RS. 1,33,36,193/-. HOWEVER, LOOK ING TO THE ACCRETION IN THE CLOSING BALANCE OF THE CONCERNS FO R WHICH ITA NO. 197& 248/JP/2016 M/S VIJAY KEDIA (HUF) VS. ACIT JAIPUR. 6 REVENUE HAS MATERIAL, THE ADDITION CONFIRMED BY THE LD. CIT(A) IS REASONABLE. 2.30 THE HONBLE P & H HIGH COURT IN THE CASE OF UP LAKESH METAL INDUSTRIAL V CIT 177 TAXMAN 298 HELD THAT ISSUE DEC IDED BY THIS IS IN THE REALM OF APPRECIATION EVIDENCE. THE FIND OF TRIBUNAL AS MENTIONED IN THIS JUDGMENT IS AS UNDER:- ' HOWEVER, IN OUR OPINION THE OBSERVATION OF THE ASSE SSING OFFICER THAT THE ASSESSEE WAS PRIMA FACIE REQUIRED TO PROVE THE GENUINENESS OF THE TRANSACTION AND IDENTITY OF THE CREDITORS IS NOT MISPLACED BECAUSE THERE IS NO DISTINCTION LAID BETW EEN THE TRADE CREDITOR AND THE NON-TRADE CREDITOR AND WE ARE FURT HER OF THE OPINION THAT IN CASE THE ASSESSEE CLAIMS LIABILITY OF PAYMENT TO THE TRADE CREDITORS SHOWN IN THE BALANCE-SHEET, THE ASSESSEE IS DEFINITELY REQUIRED TO PRIMA FACIE PROVE THE IDENTI TY OF THE TRADE CREDITORS AS WELL AS THE GENUINENESS OF THE TRANSAC TION. IN THIS CASE, ADMITTEDLY THE ASSESSEE HAS NEITHER BEEN ABLE TO DISCLOSE THE COMPLETE ADDRESSES OF THE TRADE CREDITORS NOR I S ABLE TO GIVE THE COMPLETE ADDRESSES OF THE CONSIGNORS NOR THE NA ME HAS BEEN MENTIONED ON THE CHALLAN FORMS, SO THE VERIFICATION OF THE SAME BY THE ASSESSING OFFICER BECAME TOTALLY IMPRACTICAB LE ON ACCOUNT OF LACK OF THIS COMPLETE INFORMATION SUPPLIED BY TH E ASSESSEE. IT MEANS THAT THE ASSESSEE FAILED IN ESTABLISHING THE GENUINENESS OF THE SO CALLED TRADE CREDITORS APPEARING IN ITS BOOK S OF ACCOUNT. WE ARE FURTHER OF THE OPINION THAT SINCE IN THE INS TANT CASE OF THE ASSESSEE, THE POINT UNDER CONSIDERATION BEFORE US I S REGARDING THE GENUINENESS OF THE LIABILITY AMOUNTING TO RS. 1,75, 26,586 SHOWN BY THE ASSESSEE IN ITS BALANCE-SHEET AS TRADE CREDI TORS, SO IT WAS NOT RELEVANT FOR US TO CONSIDER AS TO WHETHER THE P URCHASES MADE BY THE ASSESSEE WERE GENUINE OR NOT OR TO WHETHER T HE ASSESSEE HAS INFLATED THOSE PURCHASES OR NOT. IT IS ALSO NOT MATERIAL TO CONSIDER WHETHER THE GRS FROM SALE-TAX DEPARTMENT W ERE VERIFIED OR NOT, SO, THE CIT(A) ON CONSIDERING THESE POINTS WAS NOT ITA NO. 197& 248/JP/2016 M/S VIJAY KEDIA (HUF) VS. ACIT JAIPUR. 7 JUSTIFIED IN DELETING THE IMPUGNED ADDITION WITHOUT DISCUSSING AS TO WHETHER THE LIABILITY OF TRADE CREDITORS SHOWN B Y THE ASSESSEE IN THE ABSENCE OF FURNISHING COMPLETE ADDRESSES OF TRADE CREDITORS/CONSIGNORS AND THE PAYMENT VOUCHERS WAS G ENUINE OR NOT.' WHILE EVALUATING THE MATERIAL COLLECTED BY THE REVE NUE ON THE TOUCH STONE ON HUMAN PROBABILITY AND CONSIDERING TH E ACCRETION IN THE CLOSING BALANCE IN RESPECT OF PARTIES FOR WH ICH REVENUE HAS MATERIAL IN THE FORM OF STATEMENT. WE FELL THAT THE LD. CIT(A) WAS REASONABLE IN CONFIRMING THE ADDITION OF RS. 5.00 L ACS. HENCE BOTH THE GROUNDS OF ASSESSEE AS WELL AS REVENUE ARE DISM ISSED. WE FURTHER NOTED THAT WHEN THE CORRESPONDING SALE I S NOT IN DISPUTE THEN THE QUESTION IS ONLY REGARDING THE COR RECT AMOUNT OF PURCHASES AND VERIFICATION OF THE SAME. THE LD. DR HAS RELIED UPON THE VARIOUS DECISIONS OF HONBLE GUJARAT HIGH COURT HOWEVER, WE FIND THAT IN ALL THOSE DECISIONS THERE WAS A FINDING OF FACTS THAT THE ASSESSEE INFLATED THE PURCHASES UPTO 25% AND THEREFORE, IT WAS NOT A CASE OF NON VERIFICATION OF THE PURCHASE AND REJECTION OF BOOKS OF ACCOUNTS BUT THE FACT WA S ESTABLISHED IN THE INVESTIGATION THAT THE ASSESSEE INFLATED THE PURCHASE PRICE AND ACCORDINGLY THE ADDITION OF 25% BEING INFLATED PURCHASES WAS MADE AND UPHELD BY THE TRIBUNAL WHICH WAS AGAIN UPH ELD BY THE HONBLE HIGH COURT. ON THE CONTRARY IN THE CASE OF THE ASSESSEE THE AO NOT GIVEN ANY FINDING OF INFLATED PURCHASES BY THE ASSESSEE BUT DOUBTED THE VERY TRANSACTION OF PURCHA SES DUE TO NON PRODUCTION OF THESE PARTIES BEFORE THE AO. THE AO HAS NOT GIVEN THE FINDING THAT THE PRICES OF THE GOODS WAS INFLATED BY THE ASSESSEE BUT THE AO DOUBTED THE GENUINENESS OF THE PURCHASES ON THE GROUND THAT THE SUPPLIERS WERE FOUND TO BE ACCOMMODATION ENTRIES PROVIDERS. WHEN THE AO REJECT ED THE BOOK RESULTS U/S 145(3) OF THE ACT, THEN THE AO AFTER RE JECTION OF THE BOOKS OF ACCOUNT CAN PROCEED TO MAKE THE ASSESSMENT ON THE BASIS OF BEST JUDGMENT INSTEAD OF RESORTING MAKE TH E ADDITION TO THE BOOK RESULTS. ACCORDINGLY, IN THE FACTS AND CIR CUMSTANCES OF ITA NO. 197& 248/JP/2016 M/S VIJAY KEDIA (HUF) VS. ACIT JAIPUR. 8 THE CASE AND IN VIEW OF THE DECISION OF THIS TRIBUN AL IN ASSESSEES OWN CASE FOR A.Y. 2006-07 WE DO NOT FIND ANY ERROR OR ILLEGALITY IN THE ORDERS OF THE LD. CIT(A) IN RESTRICTING THE ADD ITION TO THE AVERAGE GP RATE BASED ON THE PAST HISTORY. HENCE, T HE GROUNDS RAISED IN THE REVENUE APPEALS ARE REJECTED BEING WI THOUT ANY SUBSTANCE OR MERITS. ACCORDINGLY, IN VIEW OF THE ABOVE FACTS AND CIRCUMS TANCES OF THE CASE AND THE DECISION OF THIS TRIBUNAL IN CASE OF A CIT VS. M/S ALLIED GEMS CORPORATION (SUPRA) THE GROUNDS RAISED BY THE REVENUE IN THIS APPEAL ARE WITHOUT ANY SUBSTANCE OR MERITS. ACCORDINGLY, WE SET ASIDE THE ORDERS OF THE AUTHORI TIES BELOW QUA THIS ISSUE AND DIRECT THE AO TO ASSESSEE THE INCOME OF T HE ASSESSEE ON THE BASIS OF THE AVERAGE GROSS PROFIT, DECLARED AND ADM ITTED BY THE AO OR ATTAINED FINALITY. THE AO TO CONSIDER THE PAST HIST ORY OF THE GP OF THE ASSESSEE FOR ARRIVING TO THE AVERAGE RATE OF GP. 6. THE REVENUE IN THE CROSS APPEAL HAS RAISED THE F OLLOWING GROUND:- WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE AND IN LAW THE LD. CIT(A) HAS ERRED IN SUBSTITUTING THE ADDITION OF RS. 85,64,509/- MADE U/S 69C ON A/C OF UNVERIFIABLE PUR CHASES BY DISALLOWANCE @ 15% OF ACCOUNT OF UNVERIFIABLE PURCH ASES. THUS, IT IS CLEAR THAT THE REVENUE IS AGGRIEVED BY THE ORDER OF THE LD. CIT(A) TO THE EXTENT OF THE ADDITION RESTRICTED FRO M THE TOTAL PURCHASE TO 15%. THIS ISSUE IS COMMON TO THE GROUND NO. 2 OF THE ASSESSEES APPEAL AND ACCORDINGLY, IN VIEW OF OUR FINDINGS ON THIS ISSUE IN ITA NO. 197& 248/JP/2016 M/S VIJAY KEDIA (HUF) VS. ACIT JAIPUR. 9 ASSESSEES APPEAL THE GROUND RAISED BY THE REVENUE STANDS DISPOSED OF IN SAME TERMS. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PARTL Y ALLOWED FOR STATISTICAL PURPOSE AND APPEAL OF THE REVENUE IS DI SMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 29/01/2018 SD/- SD/- FOE FLAG ;KNO FOT; IKY JKO (VIKRAM SINGH YADAV) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 29/01/2018. * SANTOSH. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- M/S VIJAY KEDIA (HUF), JAIPUR. 2. IZR;FKHZ@ THE RESPONDENT- ACIT, CIRCLE-1, JAIPUR. 3. VK;DJ VK;QDR@ CIT 4. VK;DJ VK;QDR@ CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR. 6. XKMZ QKBZY@ GUARD FILE {ITA NO. 197 & 248/JP/2016} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR