BRANCH MANAGER, PUNJAB NATIONAL BANK, Kota V. JDIT (I & CI), Jaipur

ITA 197/JPR/2017

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 2105 (ITAT-JAIPUR)
• Duration Of Justice: 5 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 22-08-2017
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: SMC
• Next Hearing Date: 03-07-2017
• Assessment Year: misc
• Appeal Filed On: 08-03-2017
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: R A VERMA CIT DHK
• Assessee Lawyers: B L BHOJWANI
• Keywords: Reasonable cause; Non compliance
• Section: 273B; 133(6); 27

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES (SMC), JAIPUR JH HKKXPAN] YS[KK LNL; ] DS LE{K BEFORE: SHRI BHAGCHAND, ACCOUNTANT MEMBER VK;DJ VIHY LA- @ ITA NOS. 197 TO 199/JP/2017 ASSESSMENT YEAR: 2012-13 BRANCH MANAGER, PUNJAB NATIONAL BANK, BHAWANI MANDI, JHALAWAR (RAJ)- 326038. CUKE VS. JOINT DIRECTOR OF INCOME TAX, (I&CI), JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AAACP 0165 G VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI B.L. BHOJWANI (CA). JKTLO DH VKSJ LS @ REVENUE BY : SHRI R.A. VERMA (ADDL.CIT) LQUOKBZ DH RKJH[K @ DATE OF HEARING : 18/08/2017 MN?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 22/08/2017 VKNS'K@ ORDER PER: BHAGCHAND, A.M. THESE ARE THE APPEALS FILED BY THE ASSESSEE AGAINS T THE COMMON ORDER DATED 04/01/2017 OF LD. CIT(A), ALWAR, PERTAINING TO THE ASSESSMENT YEAR 2012-13. THERE IS COMMON ISSUE INVOLVED IN ALL THESE APPEALS AND THE LD. CIT(A) HAS DECIDED THE SAME IN HIS COMBINED ORDER. TH E ASSESSEE HAS TAKEN COMMON GROUNDS IN ALL THESE APPEALS, WHICH IS REPROD UCED HEREUNDER: 1. THAT THE LD. CIT(A) HAS ERRED ON FACTS AND IN L AW IN CONFIRMING PENALTY OF RS. 49,800 LEVIED BY THE ASSESSING OFFIC ER U/S 272(A)(2)(C). ITA 197 TO 199/JP/2017_ BRANCH MANAGER, PNB VS. JDIT(I&CI) 2 2. SINCE, COMMON ISSUES ARE INVOLVED IN ALL THE APP EALS, THEREFORE, ALL THE APPEALS ARE BEING HEARD TOGETHER AND FOR THE SAKE O F CONVENIENCE AND BREVITY, COMMON ORDER IS BEING PASSED. 3. IN ALL THESE APPEALS, THERE ARE ONLY ONE COMMON ISSUE, WHICH IS AGAINST CONFIRMATION OF PENALTY U/S 272A(2)(C) OF THE INCOM E TAX ACT, 1961 (IN SHORT THE ACT). A NOTICE U/S 133(6) OF THE ACT WAS ISSUED TO THE BRANCH MANAGER, PUNJAB NATIONAL BANK, BHAWANI MANDI, KOTA, RAJASTHAN BY THE ITO (INTELLIGENCE), KOTA ON 11/06/2012 WHEREIN THE INFOR MATION UNDER THE CODE 003 TRANSACTION CODE 403, INFORMATION UNDER THE COD E 007 TRANSACTION CODE 410 AND INFORMATION UNDER THE CODE 006 TRANSACTION CODE 409 FOR F.Y. 2011- 12 TO BE FURNISHED BY 09/07/2012. THE ASSESSEE DID NOT FURNISH THE INFORMATION IN COMPLIANCE TO THE NOTICE U/S 133(6) OF THE ACT DATED 11/6/2012. HOWEVER, THE COMPLIANCE WAS MADE AFTER A D ELAY OF 498 DAYS FROM THE DATE PRESCRIBED IN THE NOTICE U/S 133(6) O F THE ACT I.E. 09/07/2012. THE JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE & CRIM INAL INVESTIGATION), JAIPUR IMPOSED PENALTY FOR NON COMPLIANCE OF NOTICE FOR FURNISHING THE INFORMATION UNDER THE DIFFERENT CODES SEPARATELY. 4. THE LD. CIT(A) HAS CONFIRMED THE PENALTIES LEVIED FOR ALL THE THREE YEARS BY HOLDING AS UNDER:- ITA 197 TO 199/JP/2017_ BRANCH MANAGER, PNB VS. JDIT(I&CI) 3 5.3 I HAVE CONSIDERED THE ORDERS PASSED BY THE JDI T(I&CI) AND SUBMISSIONS FILED BY THE APPELLANT. THE FOLLOWING FAC TS HAVE BEEN EMERGED; 1. THAT A NOTICE UNDER SECTION 133(6) OF THE ACT WA S ISSUED BY THE ITO (INTELLIGENCE), KOTA ON 11/06/2012 TO FILE REQU IRED INFORMATION BY 09/07/2012. THE NOTICE REMAIN UN-COM PLIED 2. THAT A PENALTY NOTICE U/S 272A(2)(C) OF THE ACT WAS ISSUED 25/10/2013. IN RESPONSE TO THE NOTICE, THE APPELLAN T HAS SUBMITTED THE INFORMATION ON 20/11/2013. 3. THAT THE JDIT(I&CI) JAIPUR HAS LEVIED PENALTY OF RS. 49,800/- EACH FOR F.Y. 2012-13 WITH RESPECT TO CODE 006 AND TRANSACTION CODE 409, CODE 007 AND TRANSACTION CODE 410, CODE 0 03 AND TRANSACTION CODE 403 AND TOTALING TO RS. ,49,400/- UNDER SECTION 272A(2)(C) OF THE ACT. 5.3.2. I HAVE CONSIDERED THE SUBMISSIONS MADE BY TH E APPELLANT AND THE REASON GIVEN FOR NO-COMPLIANCE OF THE NOTICES S ERVED ON HIM. I HAVE PARTICULARLY NOTED THE FACT THAT THE AP PELLANT HAD IGNORED THE NOTICE SENT U/S 133(6) OF THE ACT ON SE VERAL. IT IS ONLY AFTER THE APPELLANT IS SLAPPED WITH PENALTY NOT ICE THAT HE HAD RESPONDED WITH THE REQUIRED INFORMATION. THEREFOR E, IT IS MY CONSIDERED VIEW THAT THE APPELLANTS REASON FOR NON- COMPLIANCE OF NOTICES SERVED ON HIM U/S 133(6) OF THE ACE IS I N UNCONVINCING. THEREFORE, THE JDITS ORDERS OF LEVYING PENALTY FOR RS. 49,800/- EACH UNDER VARIOUS CODES WITH REGARD TO APPEAL NO. 259/14-15, 260/14-15 AND 261/14-15 UNDER SECTION 27 2A(2)(C) OF THE ACT ARE SUSTAINED. ACCORDINGLY, APPELLANTS GROUND OF APPEALS ON THIS ISSUE ARE DISMISSED. ITA 197 TO 199/JP/2017_ BRANCH MANAGER, PNB VS. JDIT(I&CI) 4 5. NOW THE ASSESSEE IS IN APPEALS BEFORE THE ITAT. WH ILE PLEADING ON BEHALF OF THE ASSESSEE, THE LD AR OF THE ASSESSEE H AS SUBMITTED AS UNDER:- 1.1 A NOTICE UNDER SECTION 133(6) OF THE INCOME TA X ACT, 1961, READ WITH RULE 114E OF THE INCOME TAX RULES, 1962, WAS ISSUED TO T HE APPELLANT BANK BY THE ID. ITO (INTELLIGENCE), KOTA, ON 11.06.2012, FOR FU RNISHING INFORMATION UNDER THE FOLLOWING CODES, BY 09.07.2012 : S. NO. CODE NO. TRANSACTION CODE INFORMATION CALLED FOR 1. 003 403 TIME DEPOSITS EXCEEDING RS 2 LAKHS WITH BANKING COMPANY. 2. 006 409 PAYMENT IN CASH FOR PURCHASE OF BANK DRAFTS OR PAY ORDERS OR BANKERS CHEQUES FROM A BANKING COMPANY OF AN AMOUNT AGGREGATING TO RS. 1,00,000 OR MORE 3. 007 410 DEPOSIT IN CASH AGGREGATING RS. 2,00,000 OR MORE, WITH BANKING COMPANY DURING ANY ONE DAY. THE BANK COULD NOT FURNISH THE REQUIRED INFORMATIO N IN TIME. 1.2 THEREAFTER, THREE SEPARATE PENALTY NOTICES, DAT ED 25.10.2013, UNDER SECTION 272A(2)(C) OF THE INCOME TAX ACT, 1961, WERE ISSUED BY THE ID. JDIT (I & CI), JAIPUR, FOR NON-FURNISHING OF THE INFORMATION UNDER THE AFORESAID THREE CODES. 1.3 AFTER RECEIVING THE PENALTY NOTICES, THE APPELL ANT BANK FURNISHED THE REQUIRED INFORMATION, WHICH WAS AFTER A DELAY OF 49 8 DAYS. 1.4 THE SUBMISSIONS MADE BY THE APPELLANT BANK BEF ORE THE ID. CIT (APPEALS) ARE REPRODUCED ON PG. NOS. 5 & 6 OF THE APPEAL ORDER AN D ARE SUMMARIZED BELOW. THE REQUIRED INFORMATION COULD NOT BE EXTRACTED I GENERATED AT THE BRANCH LEVEL AS THIS NEEDED SOFTWARE SUPPORT AND PE RMISSION OF THE HEAD OFFICE / REGIONAL OFFICE FOR PREPARATION AND E XTRACTION OF THE DATA ITA 197 TO 199/JP/2017_ BRANCH MANAGER, PNB VS. JDIT(I&CI) 5 FROM THE SOFTWARE. THIS INFORMATION, AFTER GETTING THE SUPPORT AND PERMISSION OF THE HEAD OFFICE I REGIONAL OFFICE, WA S FINALLY EXTRACTED I GENERATED IN NOVEMBER, 2013 AND WAS IMMEDIATELY FUR NISHED TO THE AO ON 20.11.2013. THERE WAS THUS A REASONABLE CAUSE FO R THE DELAY IN FURNISHING THE REQUIRED INFORMATION IN RESPONSE TO THE NOTICE ISSUED UNDER SECTION 133(6). THE DELAY WAS NOT INTENTIONAL OR WILLFUL AND PENALTY IMPOSED BY THE AO UNDER SECTION 272A(2)(C) WAS NOT JUSTIFIED. THE FOLLOWING FAVOURABLE CASE LAW WAS CITED : (A) (I) STATE BANK OF INDIA, NTPC BRANCH, KARIMNAGA R DISTRICT V. ADDL. CIT (INT.), HYDERABAD (ITAT HYDERABAD); IT A. NO. 1465/HYD/2014. (II) STATE BANK OF INDIA, METPALLE BRANCH, KARIMNA GAR DISTRICT V. ADDL. CIT (INT.), HYDERABAD (ITAT HYDER ABAD); ITA. NO.1468/HYD/2014. COPY OF THE COMPOSITE ORDER, DATED 30.04.2015, IS ENCLOSED AS ANNEXURE IA. (B) ALLAHABAD BANK, SWAROOP NAGAR, KANPUR V. INCOME TAX OFFICER (INTELLIGENCE)/JT. DIRECTOR OF INCOME TAX (INTELLIG ENCE), KANPUR; (ITAT LUCKNOW). COPY OF THE ORDER, 28.07.2015, IS E NCLOSED AS ANNEXURE IB. 1.5 THE APPELLANT BANK IS A PUBLIC OFFICE AND THE D EFAULT OF THIS NATURE OUGHT TO BE CONSIDERED LIBERALLY. IT HAS BEEN PROVIDED IN SE CTION 273B THAT IN CASE A PERSON ESTABLISHES OR PROVES THAT HE HAD REASONABLE CAUSE FOR THE FAILURE TO COMPLY WITH THE PROVISIONS, THEN NO PENALTY SHALL B E IMPOSABLE ON SUCH PERSON FOR THE SAID FAILURE. IT HAS BEEN HELD IN SE VERAL JUDICIAL PRONOUNCEMENTS THAT WHERE THERE WAS A CASE OF REASO NABLENESS, THERE WAS NO MERIT IN LEVYING THE PENALTY UNDER SECTION 272A( 2). 1.6 HOWEVER, THE ID. JDIT (I & CI), JAIPUR HAS LEVI ED A PENALTY OF RS.49,800 EACH FOR THE AFORESAID THREE CODES BY PASSING THREE SEPA RATE PENALTY ORDERS. ITA 197 TO 199/JP/2017_ BRANCH MANAGER, PNB VS. JDIT(I&CI) 6 2.1 IN SYNDICATE BANK V. ADDL. CIT (2015) TAX PUB(D T) 3614 (HYD-TRIB), THE HONBLE TRIBUNAL OPINED THAT THERE WAS REASONABLE C AUSE FOR NON-COMPLIANCE TO THE NOTICE. CONSIDERING THE FACTS OF THE CASE AN D ALSO THE LAW ON THE SUBJECT, THE PENALTIES LEVIED UNDER SECTION 272A(2) (C) WERE CANCELLED. COPY OF THE JUDGMENT IS ATTACHED HEREWITH AS ANNEXURE II . 2.2 THE HONBLE RAJASTHAN HIGH COURT, IN THE CASE O F CIT V. SUPERINTENDING ENGINEER (2003) 260 ITR 641 (RAJ-HC), HAS MADE THE FOLLOWING OBSERVATIONS: THE APEX COURT IN HINDUSTAN STEEL LTD. V. STATE O F ORISSA (1973) 83 ITR 26 (SC) HAS OBSERVED THAT AN ORDER IMPOSING PENALTY FOR FAILURE TO CARRY OUT A STATUTORY OBLIGATION IS THE RESULT OF A QUASI -CRIMINAL PROCEEDING AND PENALTY WILL NOT ORDINARILY BE IMPOSED UNLESS T HE PARTY OBLIGED EITHER ACTED DELIBERATELY IN DEFIANCE OF LAW OR WAS GUILTY OF CONDUCT CONTUMACIOUS OR DISHONEST, OR ACTED IN CONSCIOUS DI SREGARD OF ITS OBLIGATION. THE APEX COURT FURTHER OBSERVED THAT PE NALTY WILL NOT ALSO BE IMPOSED MERELY BECAUSE IT IS LAWFUL TO DO SO. TH E POWERS ARE TO BE EXERCISED JUDICIOUSLY. THE APEX COURT HELD AS FOLLO WS: 'WHETHER PENALTY SHOULD BE IMPOSED FOR FAILURE TO PERFORM A STATUTORY OBLIGATION IS A MATTER OF DISCRETION OF T HE AUTHORITY TO BE EXERCISED JUDICIALLY AND ON A CONSIDERATION OF A LL THE RELEVANT CIRCUMSTANCES. EVEN IF A MINIMUM PENALTY IS PRESCRI BED, THE AUTHORITY COMPETENT TO IMPOSE THE PENALTY WILL BE J USTIFIED IN REFUSING TO IMPOSE PENALTY, WHEN THERE IS A TECHNIC AL OR VENIAL BREACH OF THE PROVISIONS OF THE ACT OR WHERE THE BR EACH FLOWS FROM A BONA FIDE BELIEF THAT THE OFFENDER IS NOT LI ABLE TO ACT IN THE MANNER PRESCRIBED BY THE STATUTE.' THUS, THE PENALTY UNDER SECTION 272A(2)(C) CANNOT BE LEVIED IN A ROUTINE MANNER. THE DISCRETION VESTED WITH THE AUTH ORITY IS TO BE EXERCISED JUDICIOUSLY ON CONSIDERATION OF ALL THE R ELEVANT CIRCUMSTANCES. A BONA FIDE BREACH CANNOT LEAD TO A PENALTY UNDER SECTION 272A(2)(C). 3.1 AS STATED IN THE PENALTY ORDER, THE NOTICE UNDE R SECTION 133(6) OF THE INCOME TAX ACT, 1961, READ WITH RULE 114E OF THE INCOME TA X RULES, 1962, WAS ISSUED ITA 197 TO 199/JP/2017_ BRANCH MANAGER, PNB VS. JDIT(I&CI) 7 TO THE APPELLANT BANK BY THE ID. ITO (INTELLIGENCE) , KOTA, ON 11.06.2012, FOR FURNISHING INFORMATION UNDER THREE CODES. 3.2 RULE 114E DOES NOT COVER THE INFORMATION CALLED FOR. NOTICE UNDER SECTION 133(6) WAS GENERAL IN NATURE AND WAS NOT IN THE DOM AIN OF THE ID. ITO (INTELLIGENCE), KOTA. THE FOLLOWING EXCERPTS FROM T HE JUDGMENT IN THE CASE OF SYNDICATE BANK (SUPRA) BRING OUT THE EXACT LEGAL PO SITION IN THIS REGARD: 9. AFTER CONSIDERING THE RIVAL CONTENTIONS AND PE RUSING THE CASE LAW RELIED UPON BY THE LEARNED COUNSEL OF THE ASSESSEE, I AM OF THE OPINION THAT THERE IS NO NEED FOR LEVY OF PENALTY I N THE GIVEN CASES. FIRST OF ALL, THE NOTICE ISSUED U/S. 133(6) IS A GE NERAL NOTICE ASKING FOR INFORMATION WHICH IS NOT IN THE DOMAIN OF THE ITO, CIB. THE CBDT ITSELF HAS PRESCRIBED CERTAIN LIMITS FOR CALLING FOR INFOR MATION AND INCOME TAX ACT ALSO PRESCRIBES VARIOUS LIMITS FOR FURNISHI NG INFORMATION ON A REGULAR BASIS FROM THE BANKS IN ANNUAL RETURNS. THE DETAILS ASKED IN VARIOUS CODES IS NEITHER PRESCRIBED BY THE ACT NOR SUPPORTED BY THE BOARDS CIRCULAR. THIS INFORMATION IS SPECIFICALLY A SKED BY ITO, CIB IN A PARTICULAR FORMAT MAY BE ON THE STRENGTH OF INTERNA L INSTRUCTIONS. FOR EXAMPLE, THE TIME DEPOSITS EXCEEDING RS. 2 LAKHS UN DER CODE NO. 003 IS NOT TO BE GENERALLY FURNISHED BY THE BANKS TO TH E DEPARTMENT IN THE PRESCRIBED ANNUAL RETURN, LIKEWISE, OTHER CODES ALS O FOR WHICH DIFFERENT AMOUNTS WERE PRESCRIBED BY THE ACT. THIS INDICATES THAT THIS INFORMATION WAS SPECIFICALLY ASKED FOR BY THE ITO, CIB. 3.3 IT IS PERTINENT TO MENTION THAT SECTION 124(3) WHICH PRESCRIBE THE TIME WITHIN WHICH A PERSON CAN CALL IN QUESTION THE JURISDICTIO N OF AN ASSESSING OFFICER DOES NOT APPLY TO A NOTICE ISSUED UNDER SECTION 133 (6). IT IS, THEREFORE, PRAYED THAT THE PENALTY OF RS. 4 9,800 LEVIED BY THE ID. JCIT (I & CI) UNDER SECTION 272A(2)(C) OF THE INCOME TAX AC T, 1961 IN ALL THE THREE APPEALS AND CONFIRMED BY THE ID. CIT (APPEALS) IS N OT JUSTIFIED AND MAY KINDLY BE DELETED. 4. WITHOUT PREJUDICE TO THE FOREGOING, IT IS SUBMI TTED THAT THERE HAS BEEN A DELAY OF 498 DAYS IN FILING THE INFORMATION UNDER T HREE CODES, NAMELY, 003, ITA 197 TO 199/JP/2017_ BRANCH MANAGER, PNB VS. JDIT(I&CI) 8 006 & 007. PENALTY OF RS. 49,800 HAS BEEN LEVIED BY THE ID. JDIT (I & CI) UNDER SECTION 272A(2)(C) OF THE INCOME TAX ACT, 1961 FOR EACH OF THE THREE CODES SEPARATELY. 4.1 THE INFORMATION RELATING TO THE THREE CODES WAS FURNISHED ON ONE AND THE SAME DATE, NAMELY, 20.11.2013. IN VIEW OF THE OVERL APPING DEFAULT, PENALTY AT BEST SHOULD BE RESTRICTED TO ONLY ONE CODE. 6. ON THE OTHER HAND, THE LD SR. DR HAS RELIED ON T HE ORDER OF THE LD. CIT(A) AND PLEADED THAT THERE IS NO REASONABLE CAUSE FOR NOT LEVYING THE PENALTY FOR NON-COMPLIANCE OF NOTICE U/S 133(6) OF THE ACT. HE ALSO SUBMITTED THAT THE DELAY OF 498 DAYS IS CLEARLY REFLECTS THAT THE BRANCH MANAGER TO WHOM THE NOTICE WAS ISSUED, WAS NOT HAVING ANY RESPECT TO THE LAW AND HE CONTINUED HIS NON-COMPLIANCE FOR MORE THAN 1 YEARS , WHICH COULD HAVE LEAD TO TIME BARRED MANY ENQUIRIES WHICH DEPARTMENT COULD HAVE MADE ON THE BASIS OF INFORMATION. HE PRAYED TO SUSTAIN THE PENA LTIES. 7. I HAVE HEARD BOTH THE SIDES ON THIS ISSUE. I HAV E ALSO CONVINCED THAT THERE WAS INORDINATE DELAY IN COMPLYING THE NOTICE. HOWEVER, I HAVE NOTICED THAT THERE WAS ONLY ONE NOTICE WAS ISSUED BY WHICH THE INFORMATION UNDER DIFFERENT CODES WERE SOUGHT. I AGREE WITH THE CONCLUS ION DRAWN BY THE INCOME TAX AUTHORITIES REGARDING NON-COMPLIANCE OF NOTICE AND NOT HAVING A REASONABLE CAUSE FOR THE NON-COMPLIANCE. HOWEVER, I ALSO NOTICED THAT THERE WAS ONLY ONE NOTICE ISSUED, THEREFORE, THE PENALTY C AN BE LEVIED ONLY FOR NON- COMPLIANCE OF THE NOTICE ONCE AND PENALTY CANNOT BE LEVIED FOR THE ITA 197 TO 199/JP/2017_ BRANCH MANAGER, PNB VS. JDIT(I&CI) 9 INFORMATION SOUGHT UNDER DIFFERENT CODES BY THE SAM E NOTICE. THEREFORE, I SUSTAIN THE PENALTY UP TO RS. 49,800/- IN ALL THE T HREE APPEALS AND THE BALANCE AMOUNT IS DELETED. 8. IN THE RESULT, ALL THE THREE APPEALS OF THE ASSE SSEE ARE PARTLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 22/08/2017. SD/- HKKXPAN (BHAGCHAND) YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ TK;IQJ TK;IQJ TK;IQJ@ @@ @ JAIPUR FNUKAD@ DATED:- 22 ND AUGUST, 2017 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- THE BRANCH MANAGER, PUNJAB NATIONAL B ANK, BHAWANI MANDI, JHALAWAR. 2. IZR;FKHZ @ THE RESPONDENT- THE JDIT, (I&CI), JAIPUR. 3. VK;DJ VK;QDR @ CIT 4. VK;DJ VK;QDRVIHY @ THE 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 TO 199/JP/2017) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR