Pushpa Vani,193-C, Civil Lines, Bareilly., Bareilly V. Asstt Commissioner of Income Tax, Bareilly

ITA 227/LKW/2012

• Counselvise Citation: 22723714 RSA 2012
• Duration Of Justice: 3 year(s) 4 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-09-2015
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Next Hearing Date: 18-08-2015
• Assessment Year: 1999-2000
• Appeal Filed On: 27-04-2012
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Section: 69; 148

Judgement Text

1 IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH A, LUCKNOW BEFORE SHRI SUNIL KUMAR YADAV, JUDICIAL MEMBER AND SHRI A.K. GARODIA, ACCOUNTANT MEMBER ITA NO.227/LKW/2012 ASSESSMENT YEAR:1999 - 2000 PUSHPA VANI, 193 - C, CIVIL LINES, BAREILLY. PAN:ACNPV0516D VS. A.C.I.T., CIRCLE - II, BAREILLY. (APPELLANT) (RESPONDENT) APPELLANT BY SHRI RAKESH GARG, ADVOCATE RESPONDENT BY SHRI AMIT NIGAM, D. R. DATE OF HEARING 26/08/2015 DATE OF PRONOUNCEMENT 2 4 /09/2015 O R D E R PER A. K. GARODIA, A.M. THIS IS ASSESSEES APPEAL DIRECTED AGAINST THE ORDER OF LEARNED CIT(A), BAREILLY DATED 27/03/2012 FOR THE ASSESSMENT YEAR 1999 - 2000. 2. IN THIS APPEAL THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS: 1. THE LEARNED CIT(A) HAS GROSSLY ERRED IN ENHANCING THE INCOME OF THE ASSESSEE BY A SUM OF RS.10,30,946/ - THEREBY CONFIRMING AN ADDITION OF RS.14,16,946/ - IN THE HANDS OF THE ASSESSEE. 2. THE LEARNED CIT(A) HAS ERRED IN TREATING THE OPENING BALANCE OF CASH IN HAND ON 01/04/1998 APPEARING IN THE CASH BOOK , AS INCOME OF THE ASSESSEE. 3. THE ENTIRE ADDITION MADE IS UNJUSTIFIED, ILLEGAL AND BAND IN THE EYES OF LAW. 3. LEARNED A.R. OF THE ASSESSEE SUBMITTED BRIEF SYNOPSIS, WHICH ARE REPRODUCED BELOW: 2 THE ASSESSEE IS A LADY, BORN IN 1945 , SHE IS PHYSICALLY HANDICAPPED. SHE LIVES WITH HER BROTHER SHRI GUL VANI ASSESSED TO TAX VIDE PA NO. AELPV0183J, WHO SUPPORTS HER IN ALL RESPECTS (CONFIRMATION FROM GUL VANI ON PAGE 101 OF THE PAPER BOOK). HER FATHER LATE SHRI B.D. VANI WAS A SENIOR OFFIC ER WITH HPCL AND HAD EARNED WELL DURING HIS LIFE TIME. ON HIS DEATH, THE LIQUID ASSETS WERE INHERITED BY THE ASSESSEE. SINCE SHE SUFFERED FROM POLIO SHE DID NOT MARRY AND HAS EVER SINCE WORKED FOR CHARITY. SHE WAS EARLIER EMPLOYED AS A TEACHER AND THEREAFT ER BECAME THE PRINCIPAL OF WOOD ROW SCHOOL SOCIETY, BAREILLY. IN THE YEAR RELEVANT FOR A.Y. 1999 - 2000, SHE WAS AGED 54 YEARS AND HAD NO MAJOR INVESTMENTS. ALL HER SAVINGS WERE HELD BY HER EITHER IN BANK OR IN CASH. HER REMUNERATION RANGED FROM RS. 70,000/ - TO RS.1,00,000 / - PER ANNUM APPROXIMATELY. THE STATEMENT OF AFFAIRS AS ON 01.04.1996 TO 31.03.1998 IS ON PAGES 16 TO 18 OF THE PAPER BOOK. THE STATEMENT OF AFFAIRS AS ON 31.03.1999 AND 31.03.2000 IS ATTACHED. COPY OF THE CASH BOOK AND THE DETAILS OF THE B ANK ACCOUNTS FOR THE PERIOD RELEVANT FOR A.Y. 1999 - 2000 HAVE ALREADY BEEN FILED AND ARE PAGES 32 TO 57 OF THE PAPER BOOK. AS REGARDS, THE OPENING CASH BALANCE OF RS.14,16,946 / - , THE SAME REPRESENTS THE CLOSING BALANCE AS ON 31.03.1998. THE CASH BOOK FOR THE PERIOD 01.04.1997 TO 31.03.1998 IS ON PAGES 13 TO 15 OF THE PAPER BOOK, THE SAME MAY KINDLY BE PERUSED. THE SAME WOULD REVEAL THAT THE ASSESSEE HAS DEPOSITED A SUM OF RS.9,76,790/ - IN THE BANK AND HAS WITHDRAWN A SUM OF RS. 16,08,000/ - FROM THE BANKS I NCLUSIVE OF REFUND OF ADVANCE FOR PURCHASE OF PROPERTY IN THE SAME PERIOD DURING THE ENTIRE YEAR. LEAVING ASIDE THE OPENING CASH BALANCE OF RS.7,95,736/ - AS ON 01.04.1997, (FOR THE MOMENT) THE CASH WITHDRAWN BY THE ASSESSEE DURING THIS PERIOD I.E. 01.04.19 97 TO 31.03.1998 WOULD BE IN EXCESS BY RS.6,31,210/ - WHICH BECOMES THE CASH IN HAND AS ON 31.03.1998 AND OPENING BALANCE OF CASH AS ON 01.04.1998. AS AGAINST THIS, THE AO HAS ADDED A SUM OF RS. 5,87,693/ - BEING DEPOSITS IN BANK. THIS SUBMISSION IS WITHOUT PREJUDICE TO THE ACTUAL CLOSING BALANCE OF RS.14,16,946/ - AS ON 01.04.1998. THE OPENING BALANCE OF RS.14,16,946/ - INCLUDED A SUM OF RS.8,00,000/ - GIVEN AS ADVANCE FOR PURCHASE OF PROPERTY 3 DURING THE PERIOD ENDING ON 31.03.1997, WHICH WAS RECEIVED BACK ON 31.07.1997 (CONFIRMATION ATTACHED). BY REFUND OF THIS AMOUNT, THE CLOSING BALANCE AS ON 31.03.1998 CAME TO BE RS. 14,16,946/ - . THE RETURN OF INCOME FOR THE A.Y. 1999 - 2000 TO 2002 - 03 WERE FILED ON 11.09.2002, MUCH BEFORE THE NOTICE U/S 148 DATED 27.03.2006 WAS ISSUED. IT CANNOT BE SAID THAT THE FILING OF RETURNS WERE AN AFTERTHOUGHT. THE RETURNS HAVING BEING FILED, THE REVENUE COULD HAVE PROCEEDED TO FRAME THE ASSESSMENT IN ACCORDANCE WITH LAW. EVEN IF THE RETURN WAS BELATED, NOTHING PREVENTED THE REVENUE F ROM TAKING ACTION U/S 148 FOR ASSESSMENT YEARS 1995 - 96 TO 1998 - 99 WHEN THE RETURNS FOR AY 1999 - 2000 TO 2002 - 2003 WERE FIRST FILED ON 11.09.2002. (SIX YEARS FROM THE END OF THE ASSESSMENT YEAR) THUS, IT WOULD BE TOO LATE FOR THE DEPARTMENT TO SAY THAT THE P ROCEEDINGS FOR A.Y. 1995 - 96 WERE TIME BARRED. THE SUM AND SUBSTANCE OF THE MATTER IS THAT THE ASSESSEE IS A SELF - EARNING PERSON, AGED 54 YEARS IN THE AY 1999 - 2000 AND WORKING AS PRINCIPAL OF WOOD ROW SCHOOL SOCIETY. SHE HAD NO LIABILITY IN THE PAST NOR DI D SHE EVER HAVE ANY LIABILITY OR ANY FAMILY COMMITMENTS. AS SUBMITTED EARLIER, SINCE SHE WAS PHYSICALLY HANDICAPPED, UNMARRIED, SHE WAS TOTALLY DEPENDENT UPON HER PARENTS AND AFTER THEIR DEMISE ON HER BROTHERS NAMELY SHRI GUL VANI AND LATE PREM VANI. THUS, IT CANNOT BE SAID, THAT THE ASSESSEE COULD NOT HAVE SAVED AMOUNTS AS DEPOSITED BY HER IN HER BANK ACCOUNT. THE ACTION OF CIT(A) OF ENHANCING THE ADDITION OF RS. 5,87,693/ - MADE BY THE AO TO RS.14,16,946/ - IS TOTALLY MISPLACED. THE CIT(A) INSTEAD OF DECIDING AS TO WHETHER THE ADDITION OF RS.5,87,693/ - WAS JUSTIFIED OR NOT WENT AHEAD AND ADDED THE ENTIRE OPENING BALANCE OF RS.14,16,946/ - AS BROUGHT FORWARD FROM EARLIER YEARS AS UNEXPLAINED INCOME OF THE YEAR. IT IS SUBMITTED, THAT THE OPENING BALANCE B ROUGHT FORWARD FROM THE EARLIER YEAR CANNOT BE ADDED AS UNEXPLAINED INCOME OF THE YEAR. THE BALANCE OF CONVENIENCE WEIGHS HEAVILY IN FAVOUR OF THE ASSESSEE FOR THE REASON THAT THE EXPLANATION GIVEN BY THE ASSESSEE HAS NOT BEEN FOUND TO BE FALSE. AT THE SA ME TIME THE AO HAS NOT BROUGHT ANY MATERIAL ON RECORD TO ESTABLISH THAT THE ASSESSEE HAD SOME OTHER SOURCE OF INCOME IN ADDITION TO 4 THE INCOME WHICH SHE RECEIVED FROM WOOD ROW SCHOOL SOCIETY. THE PERIOD OF 30 YEARS FIRST AS A TEACHER AND THEREAFTER AS A PR INCIPAL IS A FAIRLY LONG PERIOD AND CANNOT BE OVERLOOKED, AT THE SAME TIME THE PROBABILITY OF SAVINGS CANNOT BE RULED OUT. IT HAS BEEN HELD BY THE APEX COURT IN THE CASE OF CIT VS NOORJAHAN 237 ITR 570; 'AS POINTED OUT BY THE TRIBUNAL, IN THE CORRESPONDIN G CLAUSE IN THE BILL WHICH WAS INTRODUCED IN PARLIAMENT, THE WORD 'SHALL' HAD BEEN USED BUT DURING THE COURSE OF CONSIDERATION OF THE BILL AND ON THE RECOMMENDATION OF THE SELECT COMMITTEE, THE SAID WORD WAS SUBSTITUTED BY THE WORD 'MAY . THIS CLEARLY INDI CATES THAT THE INTENTION OF PARLIAMENT IN ENACTING SECTION 69 WAS TO CONFER A DISCRETION ON THE INCOME - TAX OFFICER IN THE MATTER OF TREATING THE SOURCE OF INVESTMENT WHICH HAS NOT BEEN SATISFACTORILY EXPLAINED BY THE ASSESSEE AS THE INCOME OF THE ASSESSES AND THE INCOME - TAX OFFICER IS NOT OBLIGED TO TREAT SUCH SOURCE OF INVESTMENT AS INCOME IN EVERY CASE WHERE THE EXPLANATION OFFERED BY THE ASSESSEE IS FOUND TO BE NOT SATISFACTORY. THE QUESTION WHETHER THE SOURCE OF THE INVESTMENT SHOULD BE TREATED AS INCOM E OR NOT UNDER SECTION 69 HAS TO BE CONSIDERED IN THE LIGHT OF THE FACTS OF EACH CASE. IN OTHER WORDS A DISCRETION HAS BEEN CONFERRED ON THE INCOME - TAX OFFICER UNDER SECTION 69 OF THE ACT TO TREAT THE SOURCE OF INVESTMENT AS THE INCOME OF THE ASSESSEE IF T HE EXPLANATION OFFERED BY THE ASSESSEE IS NOT FOUND SATISFACTORY AND THE SAID DISCRETION HAS TO BE EXERCISED KEEPING IN VIEW THE FACTS AND CIRCUMSTANCES OF THE PARTICULAR CASE.' FURTHER, RELIANCE IS PLACED ON THE FOLLOWING DECISIONS: - I ) KAILASH CHAND TRIVE DI VS. DY. CIT, ITA NO. 133/LKW/2013 A.Y. 2009 - 10, DATE OF ORDER: 29.11.2013 II ) DY. CIT VS. SATISH CHANDRA PANDEY, ITA NO. 25/LKW/2010 A.Y. 2001 - 02, DATE OF ORDER: 30.03.2011 III ) ACIT VS. SMT. N. SASIKALA, ITA NO. 435/MDS/197 A.Y. 1991 - 92, DATE OF ORDER: 07.12.2004 IV ) KIRAN DEVI VS. ACIT, ITA NO. 1129/DEL/2008 A.Y. 998 - 99, DATE OF ORDER: 09.02.2010 5 V ) CIT VS. PRAMESHWAR BOHRA, IT APPEAL NO. 7 OF 2003, HIGH COURT OF RAJASTHAN, DATE OF ORDER: 04.01.2007 IN VIEW OF THE ABOVE SUBMISSIONS, IT IS SUBMITTED THAT AG AINST TOTAL WITHDRAWALS AND DEPOSITS MADE IN THE BANK, THE ASSESSEE HAD A BALANCE OF RS.6,31,210 / - LEFT AS ON 31.03.1998 WHICH BECAME THE CASH AVAILABLE AS ON 01.04.1998. THUS, NO PART OF RS. 5,87,693/ - IS UNEXPLAINED. IT IS MOST HUMBLY PRAYED THAT THE ADD ITION MADE BY THE AO AN ENHANCED BY THE CIT(A), MAY KINDLY BE DELETED. COPY OF BALANCE SHEETS AS ON 31.03.1997 TO 31.03.2000 IS ALREADY ON RECORD AND COPY OF THE SAME ALONG WITH COPY OF ACKNOWLEDGMENT OF THE INCOME TAX RETURNS AND COMPUTATION OF INCOME FO R A.Y. 1998 - 99 TO 2000 - 01 IS ATTACHED. 4. HE ALSO SUBMITTED A COPY OF ASSESSEES CASH BOOK FOR THE FINANCIAL YEAR 96 - 97 AND 97 - 98 , WHICH ARE AVAILABLE ON PAGES 10 TO 15 OF THE PAPER BOOK AND SIMILARLY COPY OF CASH BOOK FOR FINANCIAL YEAR 98 - 99 , WHICH IS AVAILABLE ON PAGES 35 TO 42 OF THE PAPER BOOK. HE ALSO SUBMITTED THAT THE COPY OF ASSESSEES BANK ACCOUNT WITH PUNJAB NATIONAL BANK IS ALSO AVAILABLE IN PAPER BOOK. HE FURTHER SUBMITTED THAT THE AVAILABILITY OF THE CASH IN HAND WITH THE ASSESSEE AS O N 01/04/98 OF RS.14,16,946/ - IS SUPPORTED BY THIS EVIDENCE THAT THE ASSESSEE HAD WITHDRAWN MONEY OF RS.8 LAC FROM PNB, RAJENDRA NAGAR BRANCH ON 31/07/97 AND THEREAFTER ALSO , IN THE MONTH OF NOVEMBER 97, THE ASSESSEE HAS WITHDRAWN RS.1 LAC AND IN DECEMBER 9 7 , THE ASSESSEE WITHDRAWN RS.2,15,000/ - FROM THE SAME BANK. IN JANUARY 98, THE ASSESSEE HAS WITHDRAWN RS.1,10,000/ - FROM THE SAME BANK AND IN FEBRUARY 98 , WITHDRAWAL WAS RS.1,83,000/ - AND RS.80,000/ - IN MARCH 98. HE SUBMITTED THEREAFTER THAT DURING THE PE RIOD FROM JULY 97 TO MARCH 98, THE ASSESSEE HAS DEPOSITED MONEY IN VARIOUS BANK ACCOUNTS OF RS.2.39 LAC ONLY AND IN THIS MANNER, THE EXTRA WITHDRAWAL DURING THIS PERIOD AFTER REDUCING DEPOSIT OF CASH DURING THIS PERIOD WAS RS.12.59 LAC. THE OPENING BALANC E AS ON 01/07/97 WAS RS.1,67,946/ - WHICH ALSO INCLUDES WITHDRAWAL 6 FROM BANK OF RS.1.10 LAC IN THE MONTH OF MAY 97. HE SUBMITTED THAT UNDER THESE FACTS, IT HAS TO BE ACCEPTED THAT THE CASH AVAILABLE WITH THE ASSESSEE AS ON 01/04/98 OF RS.14,16,946/ - IS SUP PORTED BY INDEPENDENCE EVIDENCE IN THE FORM OF BANK STATEMENT THAT THE ASSESSEE WAS HAVING THIS MONEY DURING FINANCIAL YEAR 97 - 98 AND THEREFORE, THIS IS NOT PROPER ON THE PART OF LEARNED CIT(A) TO HOLD THAT THE ASSESSEE COULD NOT EXPLAIN THE SOURCE OF OPEN ING CASH IN HAND SHOWN IN THE CASH BOOK. 5. LEARNED D.R. OF THE REVENUE SUPPORTED THE ORDER OF LEARNED CIT(A). 6. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS. WE FIND THAT ADDITION WAS MADE BY THE ASSESSING OFFICER OF RS.5,87,693/ - ON THE BASIS THAT THE AS SESSEE COULD NOT EXPLAIN THE SOURCE OF CASH DEPOSIT IN BANK AND MONEY USED FOR PURCHASE OF FDR. THE DETAILS OF SUCH ADDITION IS AVAILABLE ON PAGES 4 & 5 OF THE ORDER OF CIT(A). AS PER THE SAME, AN AMOUNT OF RS.1 LAC IS ON ACCOUNT OF TRANSFER ENTRY FOR PNB , RAJENDRA NAGAR BRANCH AND THE 2 AMOUNTS OF RS.50,822/ - AND RS.50,871/ - ARE ON ACCOUNT OF FDR MATURITY. THE TOTAL OF THESE THREE AMOUNTS COMES TO RS.2,01,693/ - . AFTER EXCLUDING THIS AMOUNT FROM THE TOTAL ADDITION MADE BY THE ASSESSING OFFICER OF RS.5,87 ,693/ - , IT IS NOTED BY CIT(A) ON PAGE NO. 14 OF HIS ORDER THAT THE ASSESSING OFFICER MADE ADDITION OF RS.3.86 LAC ON ACCOUNT OF UNEXPLAINED DEPOSIT IN BANK ACCOUNT. THIS OBSERVATION WAS MADE BY CIT(A) WHILE MAKING ENHANCEMENT OF RS.10,30,946/ - AND IT IS S TATED BY CIT(A) THAT THE ASSESSEE IS SHOWING OPENING CASH IN HAND AS ON 01/04/98 OF RS.14,16,946/ - AND THE SAME COULD NOT BE EXPLAINED BY THE ASSESSEE AND THEREAFTER , EXCLUDING RS.3.8 LAC ADDED BY ASSESSING OFFICER ON ACCOUNT OF UNEXPLAINED CASH DEPOSIT IN BANK ACCOUNT, ENHANCEMENT IS MADE OF RS.10,30,946/ - . HENCE, IT IS SEEN THAT THE MOOT QUESTION IS WHETHER THE ASSESSEE HAS BEEN ABLE TO EXPLAIN THE SOURCE OF OPENING CASH IN HAND AS ON 01/04/98 SHOWN BY THE ASSESSEE IN HER CASH BOOK, COPY AVAILABLE ON PAG ES 7 35 TO 42 OF THE PAPER BOOK. IF THE SAME IS FOUND PROPER, NEITHER THE ADDITION MADE BY THE A.O. SURVIVES NOR THE ENHANCE MADE BY CIT (A) CAN SURVIVE. IN THIS REGARD, WE FIND THAT AS PER THE COPY OF CASH BOOK FOR THE FINANCIAL YEAR 97 - 98 AVAILABLE ON PA GES 13 TO 15 OF THE PAPER BOOK, THERE IS WITHDRAWAL FROM PNB, RAJENDRA NAGAR BRANCH ACCOUNT NO. 9684 AS UNDER: MONTH AMOUNT(RS.) ------------------- --------------- MAY 97 1,10,000 JULY 97 8,00,000 NOVEMBER 97 1,00,000 DECEMBER 97 2,15,000 JANUARY 98 1,10,000 FEBRUARY 1,83,000 MARCH 98 80,000 --------------- 15,98,000 DEPOSIT IN THE BANK ACCOUNT DURING THE PERIOD FROM JULY 97 TO MARCH 98 IS AS UNDER: MONTH AMOUNT(RS.) ------------------- --------------- JULY 97 25,000 AUGUST 97 10,000 NOVEMBER 97 43,000 DECEMBER 97 1,05,000 JANUARY 98 56,000 ----------- 2,39,000 SURPLUS OF CASH WITHDRAWAL OVER CASH DEPOSIT = RS. 13,59,000/ - 6.1 AS PER THE ABOVE CHART, IT COMES OUT THAT THE SURPLUS OF CASH WITHDRAWAL FROM BANK DURING FINANCIAL YEAR 97 - 98 OVER CASH DEPOSIT IN BANK IN THAT YEAR, AMOUNTS TO RS.13,59,000/ - OUT OF CASH IN HAND SHOWN BY THE ASSESSEE AS ON 01/04/98 AT RS.14,16,946/ - . TH E DIFFERENCE BEING EXCESS OPENING BALANCE OF CASH IN HAND AS ON 01/04/98 OVER AND ABOVE EXTRA CASH WITHDRAWAL FROM BANK DURING FINANCIAL YEAR 97 - 98 RS. 13.59 LACS WAS ONLY 8 RS.57,946/ - . IN OUR CONSIDERED OPINION, THIS MUCH CASH IN HAND IS VERY MUCH POSSIBL E IN THE BEGINNING OF F.Y. 1997 98 FOR A LADY WHO WA S 63 YEARS OLD DURING THE RELEVANT TIME. SINCE THE EXCESS OF CASH WITHDRAWAL OVER AND ABOVE CASH DEPOSIT IN THE BANK DURING FINANCIAL YEAR 97 - 98 IS SUPPORTED BY INDEPENDENT EVIDENCE BEING BANK ACCOUNT , IT CANNOT BE SAID THAT THIS CASH WAS NOT AVAILABLE WITH THE ASSESSEE DURING ASSESSMENT YEAR 97 - 98 AND THEREFORE, EVEN IF THE ASSESSEE IS NOT IN A POSITION TO EXPLAIN THE SOURCE OF SUCH CASH IN HAND OR IN BANK DURING FINANCIAL YEAR 97 - 98, ADDITION MAY BE M ADE AS PER LAW IN ASSESSMENT YEAR 98 - 99 BUT THE SAME CANNOT BE CONSIDERED FOR MAKING ANY ADDITION IN ASSESSMENT YEAR 99 - 2000 AND THE CASH IN HAND SHOWN BY THE ASSESSEE IN PRESENT YEAR OVER AND ABOVE THE SURPLUS OF CASH WITHDRAWAL OVER CASH DEPOSIT IN BANK OF RS.57,946/ - DESERVES TO BE ACCEPTED BEING CASH IN HAND WITH THIS LADY OF 63 YEARS OLD AT THE BEGINNING OF F.Y. 1997 98 AND THEREFORE, IN OUR CONSIDERED OPINION, NO PART OF ADDITION MADE BY THE A.O. AND CONFIRMED BY CIT(A) INCLUDING THE ENHANCEMENT BY HIM IS SUSTAINABLE. WE, THEREFORE, DELETE THE SAME. 7. IN THE RESULT, THE APPEAL OF THE ASSESSEE STANDS ALLOWED. (ORDER WAS PRONOUNCED IN THE OPEN COURT ON THE DATE MENTIONED ON THE CAPTION PAGE) SD/. SD/. (SUNIL KUMAR YADAV) ( A. K. GARODIA ) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 2 4 /09/2015 *SINGH COPY OF THE ORDER FORWARDED TO : 1. THE APPELLANT 2. THE RESPONDENT. 3. CONCERNED CIT 4. THE CIT(A) 5. D.R., I.T.A.T., LUCKNOW ASSTT. REGISTRAR