DHARMA PRODUCTIONS P.LTD, MUMBAI V. DCIT CEN CIR 31, MUMBAI

ITA 2481/MUM/2013

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 83968 (ITAT-MUMBAI)
• Duration Of Justice: 1 year(s) 6 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 29-10-2014
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: D
• Next Hearing Date: 28-10-2014
• Assessment Year: 2007-2008
• Appeal Filed On: 02-04-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: NEIL PHILIP
• Assessee Lawyers: PALLAVI GUDKA
• Keywords: Non-deduction of tax; Wrong claim; Corroborative evidences
• Section: 37(1)

Judgement Text

, IN THE INCOME TAX APPELLATE TRIBUNAL D BENCH, MUMBAI BEFORE HONBLE S/SHRI H.L. KARWA, PRESIDENT AND B. R.BASKARAN (AM) . . , . . , ./I.T.A. NO.2481 & 2482/MUM/2013 ( / ASSESSMENT YEARS :2007-08 & 2008-09) M/S DHARMA PRODUCTIONS PVT. LTD ., 29, JAINS ARCADE, 2 ND FLOOR, 14TH ROAD, KHAR (W), MUMBAI-400052 / VS. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-31, AAYKAR BHAVAN, MUMBAI ( / APPELLANT) .. ( !' / RESPONDENT) ./ $% ./ PAN/GIRNO.: AAACD3889K & / APPELLANT BY : MS.PALLAVI GUDKA !' ' & /RESPONDENT BY : SHRI NEIL PHILIP ( ) ' * + / DATE OF HEARING : 28.10.2014 ,- ' * + /DATE OF PRONOUNCEMENT : 29.10.2014 / O R D E R PER B.R.BASKARAN, ACCOUNTANT MEMBER: BOTH THE APPEALS FILED BY THE ASSESSEE ARE DIRECTE D AGAINST THE ORDERS PASSED BY LD CIT(A)-40, MUMBAI AND THEY RELATE TO T HE ASSESSMENT YEARS 2007- 08 AND 2008-09. SINCE IDENTICAL ISSUES ARE URGED IN THESE APPEALS, THEY WERE HEARD TOGETHER AND ARE BEING DISPOSED OF BY THIS CO MMON ORDER, FOR THE SAKE OF CONVENIENCE. 2. THE ASSESSEE IS ENGAGED IN THE BUSINESS OF PRODU CTION / DISTRIBUTION OF CINEMATOGRAPHIC FILMS. THE ASSESSEE HAD A JOINT VEN TURE AGREEMENT WITH M/S RED CHILLIES ENTERTAINMENT PVT LTD AND AS PER THIS AGREEMENT, THE ASSESSEE WAS REQUIRED TO PAY 50% OF THE PROFIT ACCRUING FROM THE MOVIE KAAL. ACCORDINGLY, IT PAID A SUM OF RS.6,97,471/- AND RS.3,53,995/- RESPE CTIVELY DURING THE YEARS RELEVANT TO THE ASSESSMENT YEARS 2007-08 AND 2008-0 9. THE AO TOOK THE VIEW THAT M/S RED CHILLIES ENTERTAINMENT PVT LTD HAD NO ROLE TO PLAY IN THE PRODUCTION OF THE FILM KAAL AND HENCE THE PAYMENT OF 50% WAS NOT JUSTIFIED. SIMILAR I.T.A. NOS.2481 & 2482/MUM/2013 2 PAYMENT MADE BY THE ASSESSEE IN AY 2006-07 HAD BEEN DISALLOWED AND HENCE THE AO DISALLOWED THE PAYMENTS MADE TO M/S RED CHIL LIES ENTERTAINMENT PVT LTD IN BOTH THE YEARS UNDER CONSIDERATION. IN AY 2006-0 7, THE LD CIT(A) HAD CONFIRMED THE DISALLOWANCE AND HENCE HE, BY FOLLOWI NG THAT ORDER, CONFIRMED THE DISALLOWANCE MADE IN BOTH THE YEARS UNDER CONSIDERA TION. 3. IN AY 2007-08, THE ASSESSEE ITSELF HAD DISALLO WED THE SUM OF RS.6,97,471/- BY INVOKING THE PROVISIONS OF SEC. 40 (A)(IA) FOR NON-DEDUCTION OF TAX AT SOURCE. SINCE THE TDS WAS REMITTED IN AY 2008-0 9, THE ASSESSEE CLAIMED THE ABOVE SAID AMOUNT AS DEDUCTION U/S 40(A)(IA) OF THE ACT. SINCE THE AO HAD DISALLOWED THE ABOVE SAID EXPENSES ON MERITS IN AY 2007-08, HE DID NOT ALLOW THE DEDUCTION CLAIMED IN AY 2008-09. THE LD CIT(A) CONFIRMED THE ACTION OF THE AO. 4. WE HAVE HEARD THE PARTIES AND PERUSED THE RECOR D. AT THE TIME OF HEARING, THE LD A.R SUBMITTED THAT THE DISALLOWANCE MADE IN AY 2006-07 IN RESPECT OF PAYMENT MADE TO M/S RED CHILLIES ENTERTAINMENT PVT LTD HAS SINCE BEEN ALLOWED BY THE TRIBUNAL, VIDE ITS ORDER DATED 18-09-2013 PA SSED IN ITA NO.2480 & 4791/MUM/2013. THE LD A.R ALSO FURNISHED A COPY OF THE TRIBUNAL ORDER. THE OPERATIVE PORTION OF THE SAID ORDER READS AS UNDER: - 6. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WE LL AS RELEVANT MATERIAL ON RECORD. THE ASSESSEE ENTERED INTO AN AG REEMENT DATED 9.8.2004 WITH RCEPL. CLAUSE 5(B) OF THE AGREEMENT W AS SUBSEQUENTLY AMENDED ON 9.8.2004. THIS AGREEMENT IS FOR JOINT PR ODUCTION OF FILM AND SHARING OF NET PROFIT FROM FILM KAAL IN THE RATIO OF 50:50. THE OBLIGATION OF THE PARTIES UNDER THE AGREEMENT IS PROVIDED IN C LAUSE 2 AND 3 AS UNDER: 2. OBLIGATIONS OF RCEPL IT SHOULD BE THE SOLE AND EXCLUSIVE RESPONSIBILITY OF RCEPL. A. TO ALLOW DPPL UNLIMITED USE OF ALL THE CINEMATOG RAPHIC EQUIPMENTS WHICH RCEPL OWNS OR ACQUIRES IN THE FUTU RE FOR THE PURPOSE OF THE PICTURES FREE OF COST. B. TO GIVE CREATIVE, TECHNICAL AND MARKETING INPUT. C. TO ENSURE THAT ALL THE CREATIVE WORK IN CONCEPT, CHARACTERIZATION, DIALOGUE, MUSIC, THEME SONG, TITLE MONTAGE AND ALL VISUALS ETC. ARE ORIGINAL WORK AT ALL TIMES AND THAT NO CREATIVE OR OTHER COPYRIGHT OF ANYONE IN PART OR WHOLE IS CONTRAVENED UNDER ANY CI RCUMSTANCES I.T.A. NOS.2481 & 2482/MUM/2013 3 AND TO ENSURE THE AUTHENTICITY OF ANY DATA/FACTUAL INFORMATION REPRESENTED IN THE PICTURES. D. TO REFRAIN FROM RAISING, INCURRING ANY DEBT OF A NY NATURE WHATSOEVER, OR CREATING ANY LIEN, OR MORTGAGE ON AN Y PART OR WHOLE OF THE PICTURES, AT ALL TIMES AND SPECIFICALLY SI NCE THE ENTIRE FUNDING, IS BEING PROVIDED BY DPPL 3. OBLIGATIONS OF DPPL A. TO BE RESPONSIBLE FOR ALL CREATIVE AND TECHNICAL ASPECTS, OF THE EXECUTION OF THE THE PICTURES FROM EXECUTION TO F INAL DELIVERY, INCLUDING CASTING B. TO PRODUCE THE PICTURES IN ALL RESPECTS. IT SH ALL BE THE SOLE AND EXCLUSIVE RESPONSIBILITY OF DPPL TO FINANCE THE ENT IRE PRODUCTION COST INCLUDING COST OF PUBLICITY OF THE PICTURES AND RCEPL SHALL NOT BE LIABLE OR RESPONSIBLE IN ANY MANNER, FOR THE PAYMENT OF SETTLEMENT OF SUCH COSTS WITH RESPECT TO ANY PARTY AND DPPL HEREBY INDEMNIFIES RCEPL FROM ANY CLAIMS ARISING OR BROUGHT AGAINST RCEPL FOR THE SAME. C. TO ALLOW ACCESS TO RCEPLS REPRESENTATIVE TO ALL LOCATIONS OF SHOOT, MUSIC AND SOUND RECORDING OR POST PRODUCTION . D. TO GIVE REASONABLE NOTICE FOR BOOKING OF CINEMAT OGRAPHIC EQUIPMENTS OWNED BY RCEPL. 7. THE OTHER RELEVANT CLAUSES OF THE AGREEMENT ARE AS UNDER: 4. BOTH THE PARTIES AGREE: A. THAT THEY SHALL PERIODICALLY REVIEW THE PROGRESS AND PRODUCTION OF THE PICTURES. ANY KEY DEVIATIONS TO ARTISTS OR PR ODUCTION SCHEDULE WOULD NEED TO BE INTIMATED BY DPPL TO RCEPL, AS SOO N AS DPPL BECOMES AWARE OF THE SAME. BOTH PARTIES SHALL CONSU LT EACH OTHER AND TAKE IMMEDIATE AND APPROPRIATE CORRECTIVE MEASU RES. B. THE ANNEXURES AS CONTAINED HEREIN BELOW SHALL FO RM AN INTEGRAL PART OF THIS AGREEMENT. C. DPPL WILL SUBMIT TO RCEPL, A FULL STATEMENT OF A CCOUNTS OF THE ENTIRE COST OF PRODUCTION, WITHIN BUT NOT LATER THA N 90 DAYS, FROM THE DATE OF COMPLETION OF THE PICTURES. D. RCEPL AND DPPL MAY JOINTLY OR SEVERALLY EXPLORE MARKETING OPPORTUNITIES FOR ENDORSEMENT OF PRODUCTS OR SERVIC ES FROM ANY POTENTIAL ADVERTISERS, FOR THE PICTURES. THE SOLE DISCRETION ON THE ACCEPTABILITY AND THE PRESENTATION OF SUCH PRODUCTS OR SERVICE ENDORSEMENT SHALL BE OF THE DPPL. ALL SUCH REVENUES ARISING FROM SUCH ENDORSEMENTS SHALL BE TREATED AS OVER ALL REVE NUES OF THE I.T.A. NOS.2481 & 2482/MUM/2013 4 PICTURES WHICH WILL GO TORDS RECOVERING OF COST OF PRODUCTION AND PROFIT SHARING AS ENUMERATED LATER ON IN THE AGREEM ENT. E. DPPL, SHALL, IN CONSULTATION WITH RCEPL, BE ENTI TLED TO SELL OR TO CONCLUDE OR TO ENTER INTO AL CONTRACTS IN RESPECT O F THE SALE DISTRIBUTION, EXHIBITION, AND EXPLOITATION OF THE PICTURES. F. NO HIRE CHARGES WILL BE CHARGED BY RCEPL ON CINE MATOGRAPHIC EQUIPMENTS HIRED BY DPPL. G. THIS AGREEMENT SHALL NOT CONSTITUTE A PARTNERSHI P OR JOINT VENTURE, OR ASSOCIATION OF PERSONS BETWEEN THE PARTIES HERET O. 6. CREDITS A. ADVERTISING, PROMOTION & PUBLICITY : IN ALL ADVE RTISING, PROMOTION, PUBLICITY, BROCHURES, PRESS RELEASE OR MATERIAL THE CREDITS OF THE TWO COMPANIES WILL APPEAR IN EQUAL PROMINENCE AND S TATING SHAH RUKH KHAN AND KARAN JOHAR PRESENTS DPPL/RCEPLS____________ B. IN FILM: (I) THE MOVING LOGOS OF DPPL AND RCEPL WILL APPEAR IN THE BEGINNING. 8. THE EXISTENCE OF THE AGREEMENT BETWEEN THE PARI TIES HAS NOT DISPUTED BY THE AUTHORITIES BELOW BUT THE PAYMENT I N QUESTION HAS BEEN DISALLOWED ON THE GROUND THAT NO SERVICE WAS RENDER ED BY RCEPL AND CONSEQUENTLY IT WAS HELD THAT THE EXPENDITURE WAS N OT FOR THE PURPOSE OF BUSINESS. ANOTHER REASON GIVEN BY THE AO FOR DISALL OWING THE PAYMENT IS THAT IT IS AN APPLICATION OF INCOME. IT IS WORTH NO TING THAT THE ASSESSEE COMPANY IS OWNED BY SHRI KARAN JOHAR AND RCEPL IS O WNED BY SHRI SHAHRUKH KHAN. BOTH SHRI KARAN JOHAR AND SHAHRUKH K HAN ARE KNOWN PERSONALITIES OF INDIAN FILM INDUSTRY. THE AUTHORIT IES BELOW HAVE NOT DISPUTED THE FACT OF PROVIDING SERVICES BY SHRI SHA HRUKH KHAN IN THE PRODUCTION AND MARKETING OF THE FILM KAAL. THE FI LM WAS RELEASED UNDER THE JOINT BANNER OF KARAN JOHAR AND SHAHRUKH KHAN W HICH ITSELF IS A SIGNIFICANT ASPECT OF MARKETING AND PUBLICITY OF TH E FILM. UNDISPUTEDLY MR. SHAHRUKH KHAN HAS PERFORMED THE TITLE SONG IN THE F ILM AND FOR WHICH NO SEPARATE PAYMENT HAS BEEN MADE BY THE ASSESSEE. FUR THER IT IS EVIDENT FROM THE TERMS AND CONDITIONS OF THE AGREEMENT THAT RCEPL SHALL PROVIDE NECESSARY CONTRIBUTION IN THE FIELD OF CONCEPT, CHA RACTERISATION, DIALOGUE, MUSIC, THEME ETC. IN THE PRODUCTION OF THE FILM. TH US, FUNCTIONS ARE CREATIVE IN NATURE AND REQUIRE PERSONAL PROFESSIONAL EXPERTI SE AND THEREFORE, THE CONFIRMATION OF THE PARTY REGARDING RENDERING OF TH ESE SERVICES ITSELF IS A MATERIAL EVIDENCE. IF THE PARTIES TO THE AGREEMENT ADMITTED THE ROLE AND FUNCTION OF CREATIVE WORK IN THE FILM THEN IN THE A BSENCE OF ANY CONTRARY FACT OR MATERIAL, THE CONFIRMATION CANNOT BE DOUBTE D. THE AO AND CIT(A) HAVE PLACED MUCH RELIANCE ON THE FACT THAT THE SERV ICES ARE RENDERED BY MR. SHAHRUKH KHAN AND NOT BY RCEPL. WE DO NOT AGREE WITH SUCH A VIEW WHEN THE SERVICES ARE CREATIVE IN NATURE AND DEMAND PERSONAL EXPERTISE AND TALENT WHICH COULD BE RENDERED BY SOMEBODY ON B EHALF OF THE COMPANY. THEREFORE, WHEN NO SEPARATE PAYMENT WAS MA DE OR ALLEGED TO I.T.A. NOS.2481 & 2482/MUM/2013 5 HAVE BEEN MADE TO MR. SHAHRUKH KHAN FOR THE SERVICE S RENDERED AND THE PARTIES HAVE CONFIRMED THAT ALL THE SERVICES ARE RE NDERED UNDER THE AGREEMENT THEN ONLY INFERENCE CAN BE DRAWN FROM THE GIVEN FACTS AND CIRCUMSTANCES IS THAT THE SERVICES RENDERED BY MR. SHAHRUKH KHAN ARE ON BEHALF OF RCEPL AND UNDER THE CONTRACTUAL OBLIGATIO N. 9. APART FROM THE SERVICES OF CREATIVITY THE ASSESS EE ALSO CLAIMED THAT RCEPL PROVIDED THE CINEMATOGRAPHIC EQUIPMENT FOR TH E PRODUCTION OF THE FILM. THE ASSESSING OFFICER AND CIT(A) REJECTED THE CLAIM ON THE GROUND THAT NO EVIDENCE WAS PRODUCED REGARDING TRANSPORTAT ION OF THE EQUIPMENT TO THE PRODUCTION OR/SHOOTING SITE. IT IS TO BE NOT ED THAT THESE EQUIPMENTS ARE ESSENTIAL AND INEVITABLE FOR PRODUCTION OF THE FILM. THERE CANNOT BE A CASE THAT THE ASSESSEE HAS NOT USED THE EQUIPMENT I N PRODUCTION OF THE FILM. ONE IMPORTANT ASPECT OF THE MATTER IS THAT TH E ASSESSEE HAS NOT BOOKED ANY EXPENDITURE IN RESPECT OF HIRE CHARGES O F THESE VERY EQUIPMENTS. THEREFORE, THE CLAIM CANNOT BE TERM AS BOGUS CLAIM. FURTHER THE ASSESSEE HAS GIVEN THE COMPARATIVE CHART OF THE EQUIPMENT HIRE CHARGES OF VARIOUS FILMS AND CONTENDED THAT THE HIR E CHARGES ARE VERY LESS IN COMPARISON TO THE OTHER FILM. THE CIT(A) HAS GIV EN THE TABLE OF COMPARATIVE HIRE CHARGES AT PAGE 12 OF THE IMPUGNED ORDER AS UNDER: S.NO. FILM RELEASE DATE EQUIPMENT HIRE CHARGE (RS.) PROPERY HIRE CHARGES (RS.) TOTAL RS. 1 KUCH KUCH HOTA HAI 16.10.1998 3006214 3006214 2 KABHI KHUSHI KABHI GAM 14.12.2001 7078219 7078219 3 KAL HO NA HO 27.11.2003 8562198 8562198 4 KALL 29.4.2005 4106788 1421698 5 KABHI ALVIDA NA KEHNA 11.8.2006 6608593 6608593 10. IT IS CLEAR FROM THE ABOVE CHART THAT THE HIRE CHARGES OF EQUIPMENTS FOR THE FILM KAAL IS VERY LESS IN COMPARISON TO THE O THER CONTEMPORARIOUS FILMS. THIS FACT HAS NOT BEEN DISPUTED BY THE REVEN UE. THE AUTHORITIES HAVE REJECTED THE CLAIM OF THE ASSESSEE ON THE GROU ND THAT THE OTHER FILMS ARE HIGH BUDGET FILM IN COMPARISON TO THE FILM KAA L AND THE PAYMENT OF HIRE CHARGES IS NOT ON HOURLY BASIS THEREFORE, THEY CANNOT BE COMPARED. WE DO NOT AGREE WITH THE VIEW OF THE AUTHORITIES BE LOW BECAUSE OF THE REASON THAT THE PRODUCTION EQUIPMENTS ARE BASIC REQ UIREMENT OF ANY FILM AND UTILITY/USE OF THE EQUIPMENTS GENERALLY DOES NO T VARY DUE TO HIGH OR LOW BUDGET OF THE FILM. THE BUDGET OF THE FILM MAIN LY DEPENDS ON OTHER FACTORS LIKE ARTIST WHO PERFORM IN THE FILM, SHOOTI NG SITE AND SUBJECT/THEME OF THE FILM ETC. THE AUTHORITIES BELOW HAVE NOT BRO UGHT ON RECORD AS HOW THE USE OF EQUIPMENTS IN PRODUCTION OF FILM IS DIFF ERENT IN HIGHER BUDGET OR LOW BUDGET MOVIES SO AS TO RESULT A SIGNIFICANT VAR IATION IN THE HIRE CHARGES EXPENSES. FURTHER THE DURATION OF THE FILM REMAINS ALMOST SAME I.E. 2:30 TO 3:00 AND WHEN THE EQUIPMENTS ARE HIRED FOR THE PRODUCTION OF THE FILM THEN THE REASON GIVEN BY AUTHORITIES BELOW IS FLIMSY AND UNCOGENT. THE ASSESSEE PRODUCED THE CONFIRMATION OF RCEPL IN THIS RESPECT AND NO I.T.A. NOS.2481 & 2482/MUM/2013 6 FINDING HAS BEEN GIVEN THAT THE CONFIRMATION IS FAL SE. ONE MORE REASON OF DISALLOWANCE IS WANT OF SUPPORTING EVIDENCE FOR TRA NSPORTATION OF THE EQUIPMENTS. THE ASSESSEE FILED THE BILLS OF TRANSPO RTATION OF EQUIPMENT ISSUED IN THE NAME OF RCEPL. THE GENUINENESS OF THE BILLS IS SUBJECT MATTER OF THE ASSESSMENT PROCEEDINGS OF RCEPL. EVEN OTHERWISE THE AO HAS NOT GIVEN THE FINDING THAT THESE BILLS ARE BOGU S. MOREOVER, THERE IS NO DISPUTE THAT RCEPL HAS SHOWN THIS AMOUNT AS INCOME WHICH IS SUBJECTED TO MAXIMUM RATE OF TAX. THE LD. DR HAS RAISED OBJEC TION OF NON- REGISTRATION OF AGREEMENT IN QUESTION AND REFERRED SECTION 25(1) OF THE CONTRACT ACT. IT IS TO BE NOTED THAT THE REQUIREMEN T OF REGISTRATION OF AN AGREEMENT IS ONLY IN A CASE WHETHER THERE IS NO CON SIDERATION. THEREFORE, THE VALIDITY OF THE AGREEMENT CANNOT BE QUESTIONED MERELY ON THE GROUND THAT IT IS NOT REGISTERED EXCEPT IT IS OTHERWISE RE QUIRED TO BE REGISTERED AS PER THE LAW INFORCE. THEREFORE, WE DO NOT FIND ANY MERITS IN THIS OBJECTION OF LD. DR. THIS PAYMENT IS MADE AGAINST THE SERVICE S PROVIDED BY RCEPL IN CONNECTION WITH THE PRODUCTION OF THE FILM KAAL AND UNDER THE TERMS OF THE AGREEMENT THEREFORE, IT IS AN EXPENDITURE LA ID OUT FOR THE PURPOSE OF BUSINESS. IN VIEW OF THE ABOVE DISCUSSION WE HOLD T HAT THE ASSESSEE HAS ESTABLISHED THAT THE PAYMENT HAS BEEN MADE AS PER T HE AGREEMENT BETWEEN THE PARTIES AND AGAINST THE SERVICES PROVID ED BY RCEPL AND THEREFORE, IS ALLOWABLE U/S 37(1) OF THE INCOME TAX ACT. SINCE THE FACTS ARE IDENTICAL, BY FOLLOWING THE ORD ER PASSED BY THE CO-ORDINATE BENCH (REFERRED SUPRA), WE SET ASIDE THE ORDER OF L D CIT(A) AND DIRECT THE AO TO ALLOW THE DEDUCTION OF PAYMENT MADE TO M/S RED CHIL LIES ENTERTAINMENT PVT LTD IN BOTH THE YEARS UNDER CONSIDERATION. 5. SINCE THE DEDUCTION CLAIMED IN AY 2007-08 IS A LLOWABLE ON MERITS AND SINCE THE ASSESSEE HAD DISALLOWED THE SAME BY INVOK ING THE PROVISIONS OF SEC. 40(A)(IA) OF THE ACT, THE SAME IS ALLOWABLE IN AY 2 008-09 ON THE BASIS OF PAYMENT OF TDS AMOUNT IN THAT YEAR. WE ORDER ACCORDINGLY. 6. IN THE RESULT, BOTH THE APPEALS FILED BY THE A SSESSEE STAND ALLOWED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT ON 29TH OCT, 2014 . ,- ( . /0 1 2 29TH OCT, 2014 - ' 3) 4 SD SD ( . . / H.L. KARWA) ( . . , / B.R. BASKARAN ) / PRESIDENT / ACCOUNTANT MEMBER / ( ) MUMBAI: OCT,2014. . . ./ SRL , SR. PS I.T.A. NOS.2481 & 2482/MUM/2013 7 ! ' / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. !' / THE RESPONDENT. 3. ( 9* ( ) / THE CIT(A)- CONCERNED 4. ( 9* / CIT CONCERNED 5. 6. :; 3 !*< , + < , / ( ) / DR, ITAT, MUMBAI CONCERNED 3 = ) / GUARD FILE. > ( / BY ORDER, TRUE COPY ? $ (ASSTT. REGISTRAR) + < , / ( ) /ITAT, MUMBAI