Silicon Computech Pvt.Ltd., Ahmedabad V. The Income tax Officer,Ward-8(2), Ahmedabad

ITA 239/AHD/2011

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 76828 (ITAT-AHMEDABAD)
• Duration Of Justice: 3 year(s) 4 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-06-2014
• Appeal Filed By: Assessee
• Bench Allotted: C
• Next Hearing Date: 11-06-2014
• Assessment Year: 2005-2006
• Appeal Filed On: 31-01-2011
• Court: TRIBUNAL
• Department Lawyers: J P JHANGID
• Assessee Lawyers: S N DIVETIA
• Keywords: Unexplained investment; Unexplained expenditure; Bonafide mistake
• Section: 69C

Judgement Text

, , , , IN THE INCOME TAX APPELLATE TRIBUNAL C BENCH, AHMEDABAD 0 00 0 0 00 0 , , , , ! ' ! ' ! ' ! '0 00 0 0 00 0 #' #' #' #', , , , $ $ $ $ % % % % BEFORE SHRI D.K. TYAGI, JUDICIAL MEMBER AND SHRI N.S. SAINI, ACCOUNTANT MEMBER ITA NO. 239/AHD/2011 ASSESSMENT YEAR 2005-06 SILICON COMPUTECH P. LTD. 605, ADITYA, MITHAKALI SIX ROADS, B/H. SARDAR PATEL SEVA SAMAJ, AHMEDABAD. PAN: AAACS1018F VS INCOME TAX OFFICER WARD-8(2) AHMEDABAD. &'/ APPELLANT )&' / RESPONDENT REVENUE BY : SHRI J.P. JHANGID, SR. DR ASSESSEE(S) BY : SHRI S.N. DIVETIA, AR *' + , -$/ // / DATE OF HEARING : 11/06/2014 ./0 , -$ / DATE OF PRONOUNCEMENT : 13/06/2014 1 1 1 1/ // / O R D E R PER SHRI N.S. SAINI, ACCOUNTANT MEMBER: THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST T HE ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS)-XIV, AHMEDABAD DATED 21.12.2010. 2. GROUND NO. 1 OF THE APPEAL IS GENERAL IN NATURE . HENCE, THE SAME REQUIRES NO SEPARATE ADJUDICATION BY US. ITA NO. 239/AHD/2011 SILICON COMPUTECH P. LTD., AHD. FOR A.Y. 2005-06 - 2 - 3. GROUND NO. 2.1 OF THE APPEAL READS AS UNDER: THE LD. CIT(A) HAS GRIEVOUSLY ERRED IN LAW AND FACT S IN UPHOLDING THE VALIDITY OF REASSESSMENT U/S. 147. THE LD. CIT (A) HAS FAILED TO APPRECIATE THAT THE NOTICE FOR REOPENING ASSESSM ENT WAS BAD IN LAW AND ILLEGAL. 4. AT THE TIME OF HEARING, THE AUTHORIZED REPRESEN TATIVE OF THE ASSESSEE SUBMITTED THAT HE IS NOT PRESSING THIS GRO UND OF APPEAL AND ALSO MADE AN ENDORSEMENT TO THE EFFECT ON THE GROUNDS OF APPEAL ATTACHED TO THE MEMO OF APPEAL FILED BEFORE US. THEREFORE, THIS GR OUND OF APPEAL IS DISMISSED AS NOT PRESSED. 5. GROUND NO. 3 OF THE APPEAL IS DIRECTED AGAINST THE ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS) CONFIRMING THE ADDITION OF RS 5.95 LAKHS U/S. 69C OF THE ACT. 6. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESS ING OFFICER OBSERVED THAT THE ASSESSEE HAS CREDITED REPAIRING E XPENSES OF RS 4,70,820/- HE ALSO OBSERVED THAT THE ASSESSEE HAD ISSUED A TDS CERTIFICATE FOR RS 20,190/- ON THE TOTAL AMOUNT OF RS 10,20,000/- WHER EAS THE ASSESSEE HAD DEBITED EXPENSES OF RS 4,25,000/- AT THE END OF THE YEAR. IN REPLY TO SHOW CAUSE NOTICE ISSUED BY THE ASSESSING OFFICER, THE A SSESSEE EXPLAINED THAT THE COMPANY HAD PROVIDED MAINTENANCE CHARGES FOR THE WH OLE FINANCIAL YEAR 2004-05 OF RS 10,20,000/- TO BUSINESS COMMUNICATION (GUJ.) PVT. LTD. THE COMPANY HAD DEDUCTED TDS OF RS 20,910/- FROM THE TO TAL AMOUNT OF RS 10,20,000/- AND PAID IT ON 11.05.2004. COPIES OF TD S DETAILS WERE ALSO FILED BY THE ASSESSEE. IT WAS SUBMITTED THAT THE COMPANY DISCONTINUED MAINTENANCE WORK AND PASSED REVERSE ENTRY ON 28.01. 2005 FOR RS 5,95,000/- BY CREDITING THE MAINTENANCE CHARGES ACC OUNT AND DEBITING THE PARTY ACCOUNT OF BUSINESS COMMUNICATION (GUJ.) PVT. LTD. FURTHER, TDS BEING PAID IN MAY, 2004 COULD NOT BE REVERSED OR RE FUNDED. THEREFORE, TDS CERTIFICATE WAS ISSUED ON THE TOTAL AMOUNT. COPY O F LETTER CONFIRMING ITA NO. 239/AHD/2011 SILICON COMPUTECH P. LTD., AHD. FOR A.Y. 2005-06 - 3 - MAINTENANCE WORK DONE FOR RS 4,25,000/- WHICH WAS D EBITED TO MAINTENANCE CHARGES EXPENSE ACCOUNT AND COPY OF ACCOUNT WAS FIL ED WITH THE ASSESSING OFFICER. THUS, IT WAS POINTED OUT TO THE ASSESSING OFFICER THAT THE ASSESSEE DID NOT CLAIM RS 10,20,000/- FOR MAINTENANCE EXPENS ES. CONFIRMATION LETTER FROM THE COMPANY FOR PASSING REVERSAL ENTRY WAS ALS O FILED WITH THE ASSESSING OFFICER. THE ASSESSING OFFICER DID NOT A CCEPT THE EXPLANATION AND THE EVIDENCES FILED BY THE ASSESSEE FOR THE REASON THAT MODE OF PAYMENT OF RESIDUAL AMOUNT WAS NOT BROUGHT ON RECORD, THE ENTR Y REVERSED WAS AN AFTERTHOUGHT AND CIRCUMSTANCES UNDER WHICH THE ENTR Y WAS CANCELLED AND NO OTHER AMENDED CERTIFICATE WAS ISSUED BY THE ASSESSE E WAS NOT SATISFACTORILY EXPLAINED. HE OBSERVED THAT EXPENSES OF RS 5,95,00 0/- REMAINED UNEXPLAINED. ACCORDING TO THE ASSESSING OFFICER, P ROVISION OF SECTION 69C PROVIDES THAT WHERE IN ANY FINANCIAL YEAR, AN ASSES SEE HAS INCURRED ANY EXPENDITURE AND HE OFFERS NO EXPLANATION ABOUT THE SOURCE OF SUCH EXPENDITURE OR A PART THEREOF OR THE EXPLANATION OF FERED BY HIM IS NOT SATISFACTORY, THE AMOUNT COVERED BY SUCH EXPENDITUR E MAY BE DEEMED TO BE THE INCOME OF THE ASSESSEE FOR SUCH FINANCIAL YEAR. THEREFORE, HE MADE ADDITION OF RS 5.95 LAKHS TO THE INCOME OF THE ASSE SSEE ON ACCOUNT OF UNEXPLAINED INVESTMENT. 7. ON APPEAL, THE COMMISSIONER OF INCOME TAX (APPE ALS) CONFIRMED THE ACTION OF THE ASSESSING OFFICER BY OB SERVING AS UNDER: 4.3 I HAVE CONSIDERED THE FACTS OF THE CASE AND SU BMISSIONS OF THE A.R. CAREFULLY. IT IS SEEN THAT THE APPELLANT FAILE D TO PROVE HOW THE PAYMENT OF RESIDUAL AMOUNT OF RS. 5,95,000/- WAS MA DE. 'THE LD. A.R OF THE APPELLANT STATED THAT EXCEPT FOR THE TDS CER TIFICATE THERE WAS NO MATERIAL ON RECORD TO SHOW THAT THE APPELLANT HAD I NCURRED EXPENDITURE OF RS. 10.20 LAKH. IT WAS FURTHER STATED THAT ONLY AN AMOUNT OF RS. 4,25,000/- WAS PAID AND THE BALANCE AMOUNT OF RS. 5 ,95,000/- WAS NEITHER PAID NOR SUPPOSED TO BE PAID. I DO NOT AGRE E WITH THE CONTENTION OF THE ID. A.R. IF THE BALANCE AMOUNT OF RS. 5,95,000/- WAS NOT PAID THEN WHY SHOULD TDS HAVE BEEN DEDUCTED ON THE SAID AMOUNT. SECTION 194J CLEARLY STATES THAT ANY PERSON NOT BEING AN INDIVIDUAL OR A HUF WHO IS RESPONSIBLE FOR PAYING T O A RESIDENT ANY SUM BY WAY OF FEES FOR PROFESSIONAL OR TECHNICAL SE RVICES SHALL AT THE TIME OF CREDIT OF SUCH SUM TO THE ACCOUNT OF THE PA YEE OR AT THE TIME ITA NO. 239/AHD/2011 SILICON COMPUTECH P. LTD., AHD. FOR A.Y. 2005-06 - 4 - OF PAYMENT THEREOF IN CASH OR BY ISSUE OF A CHEQUE OR DRAFT OR BY ANY OTHER MODE, WHICHEVER IS EARLIER, DEDUCT TDS ON SUC H AMOUNT AS APPLICABLE: HERE THE APPELLANT HAS DEDUCTED TDS ON THE WHOLE AMOUNT AND LATER ON STATED TO BE A MISTAKE WHICH DOES NOT STAND GROUND. DURING THE APPELLATE PROCEEDINGS THE LD. A.R HAS ST ATED THAT THE TDS CERTIFICATE WAS RIGHTLY ISSUED SHOWING REPAIRING CH ARGES OF RS. 10.20 LACS. SINCE THE PAYMENT OF FULL AMOUNT OF RS. 10.20 LACS WAS NOT MADE, THE APPELLANT OUGHT NOT TO HAVE DEDUCTED TDS ON SUCH AMOUNT. THEREFORE UNDER THE GIVEN CIRCUMSTANCES THE A.O. HA S RIGHTLY TREATED THE AMOUNT OF RS. 5,95,000/- AS UNEXPLAINED EXPENSE S AND ADDED THE SAME TO THE INCOME. THE LD. A.R HAS NOT BROUGHT ON RECORD ANY EVIDENCE TO CONTRADICT THE FINDINGS OF THE A.O SUBS EQUENTLY BEFORE ME. 4.4 AS REGARDS THE OBJECTION OF THE APPELLANT THAT THE A.O HAS MENTIONED UNEXPLAINED INVESTMENT IN THE COMPUTATION OF INCOME DOES NOT STAND GROUND SINCE IT IS JUST A TYPOGRAPHICAL E RROR. THE ASSESSING OFFICER HAS ELABORATELY AND CLEARLY EXPLAINED IN TH E BODY OF ORDER THAT THE ADDITION IS MADE U/S 69C TREATING THE AMOUNT OF RS. 5,95,000/- AS UNEXPLAINED EXPENDITURE. THEREFORE, THE ADDITION MA DE BY THE A.O IS HEREBY CONFIRMED. 8. BEING AGGRIEVED BY THE ORDER OF THE COMMISSIONE R OF INCOME TAX (APPEALS), THE ASSESSEE IS IN APPEAL BEFORE US. 9. THE AUTHORIZED REPRESENTATIVE OF THE ASSESSEE S UBMITTED THAT SIMILAR ADDITION WAS MADE IN THE HANDS OF THE BUSIN ESS COMMUNICATION (GUJ.) PVT. LTD. WHO WAS THE PARTY FROM WHOM MAINTE NANCE WORK WAS GOT DONE BY THE ASSESSEE. THE ASSESSING OFFICER TREATE D THE SUM OF RS 5.95 LAKHS AS THE INCOME OF SAID BUSINESS COMMUNICATION (GUJ.) PVT. LTD. THE MATTER TRAVELLED BEFORE THE TRIBUNAL AND THE TRIBUN AL VIDE ORDER DATED 02.12.2011 FOR ASSESSMENT YEAR 2005-06 PASSED IN IT A NO. 404/AHD/2009 DELETED THE ADDITION BY OBSERVING AS UNDER: 5. GROUND NO .3 OF THE APPEAL OF THE ASSESSEE IS A S UNDER: - THE CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS.5,95,000/- ON ACCOUNT OF REPAIRING CHARGES. 6. THE LEARNED COUNSEL FOR THE ASSESSEE SUBMITTED T HAT THIS IS A VERY PECULIAR ADDITION MADE BY THE AO AS THE ASSESS EE HAS SHOWN INCOME FROM REPAIRING CHARGES RECEIVED FROM ITS ASS OCIATE CONCERN AT RS.4,25,000/- AND BY MISTAKE THE TDS WAS MADE ON RS .10,20,000/- ITA NO. 239/AHD/2011 SILICON COMPUTECH P. LTD., AHD. FOR A.Y. 2005-06 - 5 - ON ACCOUNT OF REPAIRING CHARGES AND THE ASSESSEE HA S PASSED THE NECESSARY ENTRIES IN ITS LEDGER ACCOUNT IN THE ACCO UNT OF M/S SILICON COMPUTECH PVT. LTD. [M/S SCPL] CREDITING THEIR ACCO UNT BY THE DIFFERENTIAL AMOUNT OF RS.5,95,000/- ON 31- 08-2004 . THE LEARNED COUNSEL FOR THE ASSESSEE REFERRED TO THE COPY OF AC COUNT OF THE ASSESSEE COMPANY IN THE BOOKS OF M/S SCPL WHEREIN S IMILAR ENTRIES APPEAR AND THEY HAVE PASSED THE DEBIT ENTRIES OF RS .5,95,000/ - TO THE ACCOUNT OF THE ASSESSEE ON 28-01-2005. A COPY OF TH E ACCOUNT OF THE ASSESSEE COMPANY AS WELL AS M/S SCPL HAS BEEN FILED IN THE COMPILATION OF THE ASSESSEE. 7. THE LEARNED DR REFERRED TO PAGE 4 OF THE COMPILA TION FILED BY THE ASSESSEE WHICH IS THE ACCOUNT COPY OF M/S SCPL IN THE BOOKS OF THE ASSESSEE WHEREIN AN AMOUNT OF RS.85,000/- HAS B EEN RECEIVED ON ACCOUNT OF SERVICE CHARGES IN THE MONTH OF APRIL, 2 004 ONWARDS ON MONTHLY BASIS TILL AUGUST, 2004. HE SUBMITTED THAT IF THE AMOUNT OF RS.85,000/- REPRESENTING MONTHLY REPAIRING SERVICE CHARGES IS MULTIPLIED BY 12 CALENDAR MONTHS, AN AGGREGATE COME S TO RS.10,20,000/- ON WHICH THE TDS WAS RIGHTLY DEDUCTE D AND DEPOSITED TO THE CREDIT OF CENTRAL GOVERNMENT. HE SUBMITTED T HAT THE ASSESSEE COMPANY AS WELL AS M/S SCPL ARE RELATED PARTIES AND IT SHOULD BE VERIFIED THAT WHAT AMOUNT HAS BEEN CLAIMED BY M/S S CPL IN THEIR ASSESSMENT AND IF THEY HAVE CLAIMED ONLY RS. 4,25,0 00/-, THEN THE CLAIM OF THE ASSESSEE MAY BE CONSIDERED. 8. THE LEARNED COUNSEL FOR THE ASSESSEE IN HIS REJO INDER SUBMITTED THAT THE P&L ACCOUNT OF M/S SCPL, A COPY OF WHICH I S FILED IN THE COMPILATION BY THE ASSESSEE, CLEARLY SHOWS THE CORR ECT AMOUNT OF REPAIRING SERVICE CHARGES AND THEREFORE NO FURTHER VERIFICATION IS REQUIRED IN THIS CASE. 9. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS. WE FIN D THAT THE ASSESSEE HAS CHARGED THE SUM OF RS.85,000/- PER MON TH FOR SERVICE CHARGES FROM M/S SCPL ON MONTHLY BASIS FROM APRIL, 2004 TO AUGUST, 2004 MAKING A TOTAL OF RS.4,25,000/- AND THE NECESS ARY ENTRIES WERE PASSED IN THE ACCOUNT OF M/S SCPL IN THE BOOKS OF T HE ASSESSEE, A COPY OF WHICH IS FILED IN THE COMPILATION BEFORE US . THE ASSESSEE HAS PASSED DEBIT ENTRY IN THE ACCOUNT OF M/S SCPL OF RS .10,20,000/- ON ACCOUNT OF ESTIMATED INCOME FROM REPAIRING CHARGES FROM M/S SCPL ON 1 ST DAY OF THE ACCOUNTING YEAR I.E. 01-04-2004 ON ESTI MATE BASIS FOR THE WHOLE RELEVANT ACCOUNTING YEAR. HOWEVER, AFTER 31- 08-2004 REPAIRING CHARGES FROM M/S SCPL WERE DISCONTINUED A ND THEREFORE THE NECESSARY ENTRIES OF CANCELLATION OF THE CONTRACT W ERE PASSED ON 31- 08-2004 IN THE BOOKS OF THE ASSESSEE COMPANY IN THE ACCOUNT OF M/S SCPL AND THE DIFFERENTIAL SUM OF RS 5,95,000/- WAS CREDITED TO THEIR ACCOUNT. THE ASSESSEE HAS ALSO FILED THE LEDGER ACC OUNT COPY OF THE ASSESSEE COMPANY IN THE BOOKS OF M/S SCPL WHEREIN S IMILAR ENTRIES WERE PASSED BY M/S SCPL AND THE DIFFERENTIAL AMOUNT OF RS 5,95,000/- WAS DEBITED TO THE ACCOUNT OF ASSESSEE COMPANY ON 2 8-01-2005 AND, THEREFORE, THERE REMAINS NO DISCREPANCY BETWEEN THE ACCOUNT OF THE ASSESSEE COMPANY AND M/S SCPL. MERELY BECAUSE THE T DS WAS ITA NO. 239/AHD/2011 SILICON COMPUTECH P. LTD., AHD. FOR A.Y. 2005-06 - 6 - DEDUCTED AT A HIGHER AMOUNT AND PAID TO THE CREDIT OF THE CENTRAL GOVERNMENT IS NOT A GROUND TO MAKE THE IMPUGNED ADD ITION IN THE HANDS OF THE ASSESSEE COMPANY WITHOUT ANY BASIS. TH E ONLY REASON ADVANCED BY THE AO WHILE MAKING THE ADDITION WAS TH AT IN THE PRESENT CASE TDS HAS BEEN DEDUCTED AND HAS ALSO BEEN PAID T O THE GOVERNMENT ACCOUNT, THUS, INCOME ON ACCOUNT OF REPA IRING OF RS 10,20,000/- HAS ARISEN TO THE COMPANY WHICH HAS NOT BEEN SHOWN CORRECTLY. THIS REASONING OF THE AO IS NOT SUSTAINA BLE IN LAW. THE MISTAKE IN THE ACCOUNT BOOKS OF THE ASSESSEE COMMIT TED BONA FIDE BY THE ASSESSEE IS RECTIFIABLE AT ANY POINT OF TIME. W E FIND THAT THE ASSESSEE COMPANY AS WELL AS ITS GROUP CONCERN M/S S CPL HAS RECTIFIED THE SAME AND HAS PASSED THE NECESSARY ENTRIES IN TH EIR BOOKS OF ACCOUNTS AND, THEREFORE, THERE WAS NO JUSTIFICATION FOR MAKING ANY ADDITION ON THIS COUNT. THE PLEA THAT IT SHOULD BE VERIFIED THAT WHAT AMOUNT HAS BEEN CLAIMED BY M/S SCPL IN THEIR ASSESS MENT IS NOT ACCEPTED FOR THE SIMPLE REASON THAT THE ASSESSEE HA S FILED THE COPY OF P&L ACCOUNT OF M/S SCPL IN ITS COMPILATION BEFORE U S WHICH SHOWS THAT M/S SCPL HAS CLAIMED THE CORRECT AMOUNT OF REPAIRIN G CHARGES PAID. IN THESE FACTS OF THE CASE, WE HOLD THAT THERE IS NO J USTIFICATION FOR MAKING ANY ADDITION ON THIS ACCOUNT. ACCORDINGLY, T HIS ISSUE IS DECIDED IN FAVOUR OF THE ASSESSEE AND THE GROUND NO. 3 OF T HE APPEAL OF THE ASSESSEE IS ALLOWED. 10. RELYING ON THIS ORDER OF THE TRIBUNAL, THE AUT HORIZED REPRESENTATIVE SUBMITTED THAT FOLLOWING THE SAME, T HE ADDITION MADE IN THE HANDS OF THE ASSESSEE SHOULD BE DELETED. 11. THE DEPARTMENTAL REPRESENTATIVE ALSO AGREED WI TH THE ABOVE SUBMISSIONS OF THE AUTHORIZED REPRESENTATIVE. 12. FROM A READING OF THE ABOVE ORDER OF THE TRIBU NAL, WE FIND THAT THE TRIBUNAL IN THE HAND OF THE RECIPIENT OF THE AM OUNT ON ACCOUNT OF REPAIRING CHARGES HAS HELD THAT THERE WAS BONAFIDE MISTAKE COMMITTED BY THE ASSESSEE IN THE BOOKS OF ACCOUNT WHICH WAS RECT IFIABLE AT ANY POINT OF TIME. THE TRIBUNAL FURTHER OBSERVED THAT THE ASSES SEE COMPANY M/S. SILICON COMPUTECH PRIVATE LIMITED HAS RECTIFIED THE SAME AN D PASSED NECESSARY ENTRIES IN THE BOOKS OF ACCOUNT AND HENCE THERE WAS NO JUSTIFICATION FOR MAKING ANY ADDITION ON THIS GROUND. THE TRIBUNAL A FTER PERUSING THE COPY OF PROFIT AND LOSS ACCOUNT OF M/S SILICON COMPUTECH PR IVATE LIMITED ITSELF ITA NO. 239/AHD/2011 SILICON COMPUTECH P. LTD., AHD. FOR A.Y. 2005-06 - 7 - OBSERVED THAT M/S SILICON COMPUTECH PRIVATE LIMITED HAS PAID CORRECT AMOUNT OF REPAIRING CHARGES. IN THE ABOVE FACTS AN D CIRCUMSTANCES, WE ARE OF THE CONSIDERED VIEW THAT THE ADDITION OF RS 5,95 ,000/- U/S. 69C MADE IN THE HANDS OF THE ASSESSEE ON ACCOUNT OF UNEXPLAINED EXPENDITURE UNDER THE HEAD REPAIRING EXPENSES BY LOWER AUTHORITIES WAS NO T JUSTIFIED. WE, THEREFORE, DELETE ADDITION OF RS 5,95,000/- AND ALL OW THIS GROUND OF APPEAL OF THE ASSESSEE. 13. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS P ARTLY ALLOWED. ORDER PRONOUNCED IN THE COURT ON FRIDAY, THE 13 TH OF JUNE, 2014 AT AHMEDABAD. SD/- SD/- (D.K. TYAGI) JUDICIAL MEMBER ( N.S. SAINI) ACCOUNTANT MEMBER AHMEDABAD; DATED 13/06/2014 GHANSHYAM MAURYA, SR. P.S. TRUE COPY 1 , )-2 320- 1 , )-2 320- 1 , )-2 320- 1 , )-2 320-/ COPY OF THE ORDER FORWARDED TO : 1. &' / THE APPELLANT 2. )&' / THE RESPONDENT. 3. !! - *4 / CONCERNED CIT 4. *4() / THE CIT(A)-III, AHMEDABAD 5. 2 7 )-' , , / DR, ITAT, AHMEDABAD 6. 8 9+ / GUARD FILE. 1'* 1'* 1'* 1'* / BY ORDER, : :: :/ // / !; !; !; !; ( DY./ASSTT.REGISTRAR) , , , , / ITAT, AHMEDABAD