SHRI NARESH JAJOO, JAIPUR V. INCOME TAX OFFICER, WARD-7-2, JAIPUR

ITA 258/JPR/2018

• Counselvise Citation: [2018] 119 COUNSELVISE.COM (IT) 4813 (ITAT-JAIPUR)
• Duration Of Justice: 7 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-10-2018
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: SMC
• Assessment Year: 2013-2014
• Appeal Filed On: 26-02-2018
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: J C KULHARI JCIT DHK
• Keywords: Cost of acquisition; Valuation report

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, 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. 258/JP/2018 FU/KZKJ.K O'KZ@ ASSESSMENT YEAR : 2013-14 NARESH JAJOO, GA-62, BHAWANI NAGAR, SIKAR ROAD, JAIPUR. CUKE VS. INCOME TAX OFFICER WARD 7(2), JAIPUR. TAN/PAN NO.: AAUPJ 9813 E VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI P.C. PARWAL (CA) JKTLO DH VKSJ LS@ REVENUE BY : SHRI J.C. KULHARI (JCIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 17/10/2018 MN?KKS'K.KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 23/10/2018 VKNS'K@ ORDER PER: VIJAY PAL RAO, J.M. THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER DATED 16/01/2018 OF LD. CIT (A)-3, JAIPUR FOR THE A.Y. 201 3-14. THE ASSESSEE HAS RAISED FOLLOWING GROUNDS OF APPEAL: 1. THE LD. CIT(A) HAS ERRED ON FACTS AND IN LAW IN CONFIRMING THE ACTION OF A.O. IN RESTRICTING THE CLAIM OF COST OF IMPROVE MENT AT RS. 7,38,924/- AS AGAINST RS. 22,38,924/- CLAIMED BY TH E ASSESSEE AND THUS, SUSTAINING THE ADDITION OF RS. 15 LACS IN THE SHORT TERM CAPITAL GAIN DECLARED BY THE ASSESSEE ON SALE OF FLAT. 2. THE ASSESSEE CARVES TO AMEND, ALTER AND MODIFY A NY OF THE GROUNDS OF APPEAL. 3. THE APPROPRIATE COST BE AWARDED TO THE ASSESSEE. ITA 258/JP/2018_ NARESH JAJOOO VS ITO 2 2. THE ONLY ISSUE ARISES IN THIS APPEAL OF THE ASSES SEE IS RESTRICTING THE DISALLOWANCE WHILE COMPUTING SHORT TERM CAPITAL GAIN ARISING FROM SALE OF FLAT. THE ASSESSEE IS AN INDIVIDUAL AND CA BY PROFES SION. THE ASSESSEE SOLD FLAT NO. 107 AND 108 AT C-2, SAWAI JAI SINGH HI GHWAY, BANI PARK, JAIPUR ON 27/11/2012 FOR A CONSIDERATION OF RS. 75. 00 LACS. THE ASSESSEE CLAIMED COST OF ACQUISITION OF RS. 42,29,450/- AS WE LL AS COST OF IMPROVEMENT OF RS. 22,28,924/-. THE COST OF IMPROVEM ENT COMPRISING OF COST OF RENOVATION AND ANTERIOR WORK, COST OF BORROWI NG FOR ACQUISITION OF FLAT, INTEREST ON THE LOAN AND BROKERAGE ON SALE OF FLAT. THE ASSESSING OFFICER HAS ALLOWED THE DEDUCTION ON ACCOUNT OF COST OF IMPROVEMENT ONLY TO THE EXTENT OF RS. 7,38,924/- AND THE BALANCE AMO UNT OF RS. 15.00 LACS WAS DISALLOWED. 3. THE ASSESSEE CHALLENGED THE ACTION OF ASSESSING O FFICER BEFORE THE LD. CIT(A) BUT COULD NOT SUCCEED. 4. BEFORE US, THE LD AR OF THE ASSESSEE HAS SUBMITT ED THAT: THERE IS NO DISPUTE AS TO THE FACT THAT AFTER THE PURCHASE OF FLAT THE ASSESSEE HAS INCURRED EXPENDITURE ON RENOVATION AND INTERIOR WORK. THIS IS ACCEPTED BY THE AO ALSO WHEN HE HAS A LLOWED DEDUCTION OF RS.7,38,924/- ON THIS ACCOUNT. THE FAC T THAT THE FLAT WAS SOLD WITH COMPLETE FURNITURE & FIXTURES IS EVID ENT FROM THE SALE DEED (PB 102). THEREFORE, THE ISSUE IN THE PRE SENT CASE IS WHETHER THE AO IS JUSTIFIED IN DISALLOWING THE CLAI M OF EXPENDITURE ITA 258/JP/2018_ NARESH JAJOOO VS ITO 3 TO THE EXTENT OF RS.15 LACS WHILE COMPUTING THE SHO RT TERM CAPITAL GAIN. THE ASSESSEE HAS INCURRED EXPENDITURE ON RENO VATION & INTERIOR WORK AT RS.15,30,426/-. THE DETAIL OF THE SAME IS AT PB 13. OUT OF THIS AMOUNT, EXPENDITURE OF RS.3,45,605/-IS PAID BY CHEQUE WHICH IS INCURRED ON PURCHASE OF ITEMS LIKE TILES, PLYWOOD, ELECTRONIC ITEMS, HARDWARE & FITTINGS, TRANSFORMER CHARGES AND AIR CONDITIONERS (PB 25-27).THESE PAYMENTS ARE VERIFIAB LE FROM THE BANK STATEMENT PLACED AT PB 31-78.THE EXPENDITURE O F RS.10,13,556/- HAS BEEN INCURRED IN CASH ON CURTAIN S, PAINT WORK, SANITARY FITTINGS, CARPENTER WORK AND POP WORK WHIC H IS DULY SUPPORTED BY THE BILLS AND RECEIPTS PLACED AT PB 15 -24.THE OBSERVATION OF THE LOWER AUTHORITIES THAT THE BILLS WERE ISSUED JUST BEFORE/ AFTER SALE OF FLAT WHICH INDICATE THAT THE BILLS ARE FABRICATED AS A PERSON WHO INTEND TO SALE HIS FLAT WOULD NOT S PEND MONEY ON RENOVATION IS IRRELEVANT IN AS MUCH AS THE WORK OF RENOVATION WAS STARTED FROM APRIL, 2012 FOR WHICH PAYMENT WAS MADE FROM TIME TO TIME BETWEEN APRIL, 2012 TO NOV., 2012. THE ASSE SSEE AS AN EVIDENCE OF EXPENDITURE HAS REQUIRED THESE PERSONS TO FURNISH THE BILLS ALONG WITH THE RECEIPT OF PAYMENT MADE TO THE M WHICH THEY HAVE PREPARED AFTER THE SALE OF THE FLATBUT THIS IN NO WAY CAN LEAD TO A CONCLUSION THAT THE BILLS ARE FABRICATED. THE REMAINING CASH PAYMENT OF RS.1,71,265/- HAS BEEN INCURRED ON PURCH ASE OF TELEVISION, WASHING MACHINE, CAMERA, LCD, REFRIGERA TOR, GEYSER AND WATER PURIFIER. THE SOURCE OF THE ENTIRE CASH P AYMENT OF RS.11,84,821/- IS WITHDRAWAL FROM THE BANK ACCOUNT AS EVIDENT FROM THE CASH FLOW STATEMENT PLACED AT PB 14A.IT MA Y ALSO BE NOTED THAT ASSESSEE HAS GOT VALUATION OF EXPENSES I NCURRED ON FURNISHING OF FLAT FROM AN APPROVED VALUER. COPY OF VALUATION REPORT IS AT PB 79-91. FROM THE SAME IT CAN BE NOTE D THAT THE VALUER HAS CLEARLY SPECIFIED THE RENOVATION AND MOD IFICATION WORK ITA 258/JP/2018_ NARESH JAJOOO VS ITO 4 DONE ON FLAT ON WHICH EXPENDITURE IS ESTIMATED AT R S.11,80,000/-. THUS, THE ENTIRE COST OF RENOVATION & INTERIOR WORK INCURRED BY THE ASSESSEE IS FULLY VERIFIABLE. THE ASSESSEE HAS PURCHASED THE FLAT BY TAKING LOAN TAKEN FROM SBI, JAIPUR FOR RS.30,50,000/- ON 31.07.2010. AFTER PURCHASE OF THE FLAT, THE LOAN TAKEN FROM SBI WAS REPAID BY TAK ING LOAN OF RS.64,77,000/- FROM ICICI BANK (PB 29-30). IN RESPE CT OF THE LOAN RAISED FROM ICICI, ASSESSEE INCURRED EXPENSES OF RS .1,67,736/- (PB 13, 29-30) ON ACCOUNT OF PROCESSING OF LOAN, IN SURANCE AND PREPAYMENT PENALTY. THEREFORE, THESE EXPENDITURE IN CURRED IN RELATION TO THE PURCHASE/ SALE OF FLAT IS AN ALLOWA BLE DEDUCTION FOR WORKING OUT THE CAPITAL GAIN ON SALE OF FLAT. IN RESPECT OF THE INTEREST EXPENDITURE OF RS.3,08, 250/- CLAIMED BY THE ASSESSEE, THE SAME IS NOT ALLOWABLE FOR WORKING OUT THE SHORT TERM CAPITAL GAIN ON SALE OF FLAT AND THEREFORE, TO THAT EXTENT THE CLAIM MADE BY THE ASSESSEE IS WITHDRAWN. THE ASSESS EE HAS PAID BROKERAGE OF RS.1,50,000/- TO MUKESH KHANDELWAL THR OUGH CHEQUE AND RS.82,512/- TO AJAY SHARMA BY CASH. COPY OF BRO KERAGE BILL IS AT PB 92-93. THE BROKERAGE EXPENSES HAVE NOT BEEN D ISPUTED BY THE LOWER AUTHORITIES. THEREFORE, THESE EXPENDITURE INCURRED IN CONNECTION WITH THE SALE OF FLAT IS AN ALLOWABLE DE DUCTION U/S 48 IN COMPUTING THE SHORT TERM CAPITAL GAIN. 5. ON THE OTHER HAND, THE LD DR HAS SUBMITTED THAT THE ASSESSEE HAS CLAIMED COST OF IMPROVEMENT WHICH INCLUDES THE COST OF FURNITURE, TV, OTHER FITTINGS AND FIXTURES FOR WHICH THE EXPENDITUR E WAS INCURRED ONLY IN THE MONTH OF OCTOBER & NOVEMBER, 2012 WHEREAS THE SA ID FLAT WAS SOLD ITA 258/JP/2018_ NARESH JAJOOO VS ITO 5 BY THE ASSESSEE ON 27/11/2012. THEREFORE, IT IS APP ARENT FROM THE RECORD THAT WHEN THE ASSESSEE HAD ALREADY DECIDED TO SELL T HE FLAT THEN THE CLAIM OF THE ASSESSEE IS NOTHING BUT AN AFTERTHOUGHT ATTE MPT TO REDUCE THE TAX LIABILITY BY CLAIMING THIS BOGUS EXPENDITURE. THE AS SESSEE HAS CLAIMED THIS EXPENDITURE AS INCURRED PRIOR TO THE SALE, HOWEVER, THE PAYMENTS ARE SHOWN TO BE MADE SUBSEQUENTLY WHICH CLEARLY SHOWS THA T IT WAS AN AFTERTHOUGHT ATTEMPT TO AVOID THE TAX ON THE SHORT TERM CAPITAL GAIN ARISING FROM THE SALE OF THE FLATS IN QUESTION. HE HAS RELIED UPON THE ORDERS OF THE AUTHORITIES BELOW. 6. WE HAVE HEARD THE RIVAL SUBMISSIONS AS WELL AS TH E RELEVANT MATERIAL ON RECORD. THE ASSESSEE PURCHASED THE FLATS IN QUESTION ON 25/8/2010 FOR A CONSIDERATION OF RS. 42,29,450/- AN D THESE FLATS WERE SOLD VIDE SALE DEED DATED 27/11/2012 FOR A CONSIDERATION OF RS. 75.00 LACS. THUS, THE CAPITAL GAIN ARISING FROM THESE TRANSACTIO NS OF PURCHASE AND SALE WAS OFFERED TO TAX AS SHORT TERM CAPITAL GAIN A FTER CLAIMING A FURTHER DEDUCTION OF COST OF IMPROVEMENT OF RS. 22,38,924/- . THE DETAILS OF COST OF IMPROVEMENT ARE AS UNDER: LESS:- COST OF IMPROVEMENT:- COST OF RENOVATION & INTERIOR WORK RS.15,30,426/- COST OF BORROWING FOR ACQUISITION OF FLAT RS.1,67 ,736/- INTEREST COST RS.3,08,250/- BROKERAGE ON SALE OF FLAT RS.2,32,512 /- ITA 258/JP/2018_ NARESH JAJOOO VS ITO 6 FROM THE DETAILS FILED BY THE ASSESSEE IN SUPPORT O F THE CLAIM WE NOTE THAT THE COST OF RENOVATION AND INTERIOR WORK OF RS. 15,3 0,426/- INCLUDES THE COST OF T.V., SOFA SET/FURNITURE AND OTHER FITTINGS AND FIXTURES. SO FAR AS THE COST ON RENOVATION OF THE FLAT IS CONCERNED, WE ARE OF THE CONSIDERED VIEW THAT THE WORK CARRIED OUT BY THE ASSESSEE FOR RE NOVATION INCLUDING PAINTING AND OTHER WORK OF TILES AND FITTINGS, THE S AME IS AN ALLOWABLE CLAIM AS PART OF COST OF IMPROVEMENT WHILE COMPUTIN G THE CAPITAL GAIN. HOWEVER, THE COST OF TV, FURNITURE AND OTHER ITEMS WH ICH ARE NOT PART OF THE FLAT CANNOT BE CONSIDERED AS COST OF IMPROVEMEN T OF THE IMMOVABLE PROPERTY. THEREFORE, THE MOVABLE ITEMS WHICH ARE INDE PENDENT ASSETS CANNOT BE CONSIDERED AS COST OF IMPROVEMENT OF THE FLAT AND THEREFORE, THE SAID EXPENDITURE WILL NOT PARTAKE THE CHARACTER OF IMPROVEMENT OR RENOVATION. HENCE TO THE EXTENT OF THE CLAIM FOR PU RCHASING OF SOFA SET, DINING TABLE AND OTHER FURNITURE INCLUDING DOUBLE B ED, TV ETC., THE SAME IS NOT AN ALLOWABLE EXPENDITURE FOR THE PURPOSE OF COMP UTING THE CAPITAL GAIN ARISING FROM SALE OF FLAT. FURTHER WE FIND THAT THE BILLS FURNISHED BY THE ASSESSEE ON ACCOUNT OF PURCHASE OF FURNITURE AT PAGE 22 OF THE PAPER BOOK IS DATED 27/12/2012 WHEREAS THE FLAT WAS ALREADY SOLD VIDE SALE DEED DATED 27/11/2012. HENCE, THIS EXPENDITURE WAS I NCURRED POST SALE OF THE FLATS IN QUESTION. ACCORDINGLY, THE EXPENDITURE TO THE EXTENT OF RS. 4,11,720/- AS PER THE BILL DATED 27/11/2012 AT PAGE 22 OF THE PAPER BOOK ITA 258/JP/2018_ NARESH JAJOOO VS ITO 7 IS NOT ALLOWABLE AND TO THAT EXTENT, WE CONFIRM THE O RDERS OF THE AUTHORITIES BELOW. 6.1 THE OTHER EXPENDITURE ON ACCOUNT OF RENOVATION A ND ANTERIOR WORK HAS BEEN CLAIMED BY THE ASSESSEE BY FURNISHING ONLY THE BILLS. ALL THESE BILLS ARE NOT MATCHING WITH THE SALE TRANSACTION RAT HER MOST OF THE BILLS ARE EITHER AT THE TIME OF SALE OF SUBSEQUENT TO THE SAL E TRANSACTION. ONLY SOME BILLS ARE PRIOR TO THE SALE TRANSACTION AND THEREFO RE, TO THE EXTENT OF RENOVATION WORK, WHICH IS TO THE STRUCTURE OF THE FL ATS, THE SAME IS ALLOWABLE AS COST OF IMPROVEMENT. HENCE, THE ASSESSI NG OFFICER IS DIRECTED TO RECOMPUTED THE COST OF RENOVATION AND INTERIOR A FTER CONSIDERING THE VARIOUS EXPENDITURES, WHICH WERE INCURRED ON CARRYING OUT THE RENOVATION WORK MUCH PRIOR TO THE SALE TRANSACTION. 6.2 THE NEXT CLAIM OF THE ASSESSEE IS REGARDING THE COST OF ACQUISITION AND INTEREST AS WELL AS ON BORROWINGS. THE LD AR HAS REFERRED TO THE LOAN ACCOUNT OF ICICI BANK TO SHOW THAT THE ASSESSEE HAS PAID THESE EXPENDITURE ON THE LOAN TAKEN FOR ACQUISITION OF TH E FLATS IN QUESTION, HOWEVER, WE NOTE THAT THIS LOAN WAS TAKEN FROM ICICI B ANK ONLY IN THE YEAR 2012 AND NOT AT THE TIME OF PURCHASE OF FLATS ON 25/8/2010. THE LD AR HAS SUBMITTED THAT THE EARLIER THE ASSESSEE TOOK LOAN FROM SATE BANK OF INDIA (SBI) FOR PURCHASE OF THESE FLATS AND THE SAID LOAN WAS ITA 258/JP/2018_ NARESH JAJOOO VS ITO 8 TRANSFERRED TO ICICI BANK BY WHICH THE ASSESSEE REPA ID THE LOAN OF THE SBI AND THEREFORE, THE EXPENDITURE INCURRED IN THAT PROCESS ALONGWITH INTEREST HAS BEEN CLAIMED BY THE ASSESSEE. SINCE NO DOCUMENT HAS BEEN FILED BY THE ASSESSEE REGARDING THE LOAN FROM THE S BI AND THEREFORE, IN ABSENCE OF THE RELEVANT RECORD, WE CANNOT GIVE A CON CLUSIVE FINDING ON THIS ISSUE. ACCORDINGLY, WE SET ASIDE THIS ISSUE OF COST OF BORROWINGS FOR ACQUISITION OF FLAT AND COST OF INTEREST TO THE REC ORD OF THE ASSESSING OFFICER FOR PROPER VERIFICATION AND EXAMINATION OF THE RECORD TO BE FILED BY THE ASSESSEE AND THEN DECIDE THE SAME. WE MAKE IT C LEAR THAT IF THE ORIGINAL LOAN WAS TAKEN BY THE ASSESSEE FOR ACQUISIT ION OF THE FLATS IN QUESTION THEN THE COST OF INTEREST AND OTHER COST O F BORROWING FOR CLOSURE OF THE LOAN CAN BE ALLOWED SUBJECT TO THE CONDITION THAT THE SAME CLAIM WAS NOT MADE BY THE ASSESSEE IN THE EARLIER YEARS AG AINST THE PROFESSIONAL INCOME. 6.3 THE LAST CLAIM IS BROKERAGE PAID BY THE ASSESSEE ON SALE OF THE FLATS. THE ASSESSEE HAS CLAIMED PAYMENTS OF BROKERAG E TO TWO BROKERS WHEREAS THE TRANSACTION OF SALE IS ONE TRANSACTION T HROUGH ONE SALE DEED. THE ASSESSEE CLAIMED THAT A BROKERAGE OF RS. 1,50,00 0/- WAS PAID TO ONE SHRI MUKESH KHANDELWAL. THE PAYMENT OF THE SAID AMOUN T WAS MADE THROUGH CHEQUE DATED 30/3/2013. THE OTHER CLAIM OF R S. 82,512/- OF ITA 258/JP/2018_ NARESH JAJOOO VS ITO 9 BROKERAGE PAID TO SHRI AJAY SHARMA IN CASH. BOTH BI LLS ARE DATED 05/11/2012 WHEREAS THE ASSESSEE CLAIMED TO HAVE PAID THE BROKERAGE OF RS. 1.50 LACS ON 30/3/2013 WHICH IS AFTER MORE THAN FOUR MONTHS FROM THE DATE OF SALE OF FLATS ON 27/11/2012. WE FURTHER NOT E THAT IN THE BANK ACCOUNT OF THE ASSESSEE, THE SAID CHEQUE OF PAYMENT OF BROKERAGE OF RS. 1.50 LACS WAS SHOWN AS WITHDRAWAL, THEREFORE, IT IS NOT CLEAR WHETHER IT IS SELF WITHDRAWAL OF AMOUNT THROUGH CHEQUE OR THE AMOUN T WAS PAID THROUGH CHEQUE TO THE OTHER PARTY AND THE CHEQUE WAS CLEARED AND CREDITED IN THE ACCOUNT OF THE OTHER PARTY. SINCE T HE BILLS AND PAYMENTS ARE NOT MATCHING WITH THE SALE TRANSACTION, THEREFOR E, IN ABSENCE OF THE VERIFICATION OF THE FACT WHETHER THE CHEQUE WAS ACTUA LLY CREDITED IN THE ACCOUNT OF THE BROKER, THIS ISSUE CANNOT BE DECIDED CONCLUSIVELY. ACCORDINGLY, WE SET ASIDE THIS ISSUE TO THE RECORD OF THE ASSESSING OFFICER FOR VERIFICATION OF THE FACT WHETHER THIS AMOUNT OF RS. 1.50 LACS WAS CREDITED IN THE BANK ACCOUNT OF THE BROKER OR NOT. THE OTHER CLAIM OF BROKERAGE OF RS. 82,512/- IS ALSO REQUIRED TO BE VE RIFIED, THOUGH, WE ARE NOT CONVINCED WITH THE CLAIM OF THE ASSESSEE ON TWO C OUNTS (I) THE BILL WAS RAISED PRIOR TO THE SALE TRANSACTION AND (II) IN PRACTICE, THE BROKERAGE IS NOT PAID TO MULTIPLE BROKERS WHEN THE TRANSACTION IS ONLY ONE. HOWEVER, SINCE THE FACT OF PAYMENT OF BROKERAGE WAS NOT PROPE RLY VERIFIED, ITA 258/JP/2018_ NARESH JAJOOO VS ITO 10 THEREFORE, IN THE INTEREST OF JUSTICE, WE SET ASIDE THIS ISSUE TO THE RECORD OF THE ASSESSING OFFICER FOR VERIFICATION AND ADJUDICA TION. 7. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PAR TLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 23/10/2018. 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:- 23 RD OCTOBER, 2018 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- SHRI NARESH JAJOO, JAIPUR. 2. IZR;FKHZ @ THE RESPONDENT- THE ITO WARD 7(2), 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. 258/JP/2018) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR