Appeal details
Counselvise Citation
[2015] 134 COUNSELVISE.COM (IT) 1117 (ITAT-PUNE)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
1 year(s) 8 month(s) 4 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
11-09-2015
Appeal Filed By
Assessee
Order Result
Dismissed
Bench Allotted
B
Next Hearing Date
09-09-2015
Assessment Year
2005-2006
Appeal Filed On
06-01-2014
Judgement Text
] IQ.KS ] IQ.KS ] IQ.KS ] IQ.KS IQ.KS IQ.KSIQ.KS IQ.KS IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH B, PUNE . . , , ' # BEFORE SHRI R.K. PANDA, AM AND SHRI VIKAS AWASTHY, JM . / ITA NO.24/PN/2014 '% % / ASSESSMENT YEAR : 2005-06 LATE SHRI GANGADHAR RAMCHANDRA HARER, L/H SHRI SANTOSH GANGADHAR HARER, LOHAR BUILDING, OPP : TOP UP PETROL PUMP, NAGAR-AURANGABAD ROAD, AHMEDNAGAR 414 001 PAN NO.ACPPH8476E . / APPELLANT V/S TAX RECOVERY OFFICER (IT) AHMEDNAGAR RANGE, AHMEDNAGAR . / RESPONDENT . / ITA NO.25/PN/2014 '% % / ASSESSMENT YEAR : 2005-06 SHRI RANGANATH RAMCHANDRA HARER,LOHAR BUILDING, OPP : TOP UP PETROL PUMP, NAGAR-AURANGABAD ROAD, AHMEDNAGAR 414 001 PAN NO.ACRPH7072A . / APPELLANT V/S TAX RECOVERY OFFICER (IT) AHMEDNAGAR RANGE, AHMEDNAGAR . / RESPONDENT . / ITA NO.26/PN/2014 '% % / ASSESSMENT YEAR : 2005-06 SHRI MADHAV RAMCHANDRA HARER,LOHAR BUILDING, OPP : TOP UP PETROL PUMP, NAGAR-AURANGABAD ROAD, AHMEDNAGAR 414 001 PAN NO.ACPPH8463H . / APPELLANT 2 ITA NOS.24 TO 28/PN/2014 V/S TAX RECOVERY OFFICER (IT) AHMEDNAGAR RANGE, AHMEDNAGAR . / RESPONDENT . / ITA NO.27/PN/2014 '% % / ASSESSMENT YEAR : 2005-06 LATE SMT.ANANJANABAI MOHAN PAWAR, L/H SHRI SURESH MOHAN PAWAR, LOHAR BUILDING, OPP : TOP UP PETROL PUMP, NAGAR-AURANGABAD ROAD, AHMEDNAGAR 414 001 PAN NO.BCYPP1240E . / APPELLANT V/S TAX RECOVERY OFFICER (IT) AHMEDNAGAR RANGE, AHMEDNAGAR . / RESPONDENT . / ITA NO.28/PN/2014 '% % / ASSESSMENT YEAR : 2005-06 SMT. SHANTABAI RAMCHANDRA LOKHANDE, LOHAR BUILDING, OPP : TOP UP PETROL PUMP, NAGAR-AURANGABAD ROAD, AHMEDNAGAR 414 001 PAN NO. AFAPL6179C . / APPELLANT V/S TAX RECOVERY OFFICER (IT) AHMEDNAGAR RANGE, AHMEDNAGAR . / RESPONDENT / ASSESSEE BY : NONE / DEPARTMENT BY : SHRI . B.C. MALAKAR / DATE OF HEARING :09.09.2015 / DATE OF PRONOUNCEMENT:11.09.2015 3 ITA NOS.24 TO 28/PN/2014 / ORDER PER R.K. PANDA, AM : THE ABOVE 5 APPEALS FILED BY THE RESPECTIVE ASSESSES AR E DIRECTED AGAINST THE COMMON ORDER DATED 06-09-2013 OF THE CIT(A )-IT/TP, PUNE RELATING TO A.Y. 2005-06. FOR THE SAKE OF CONVENIENCE, ALL THESE APPEALS WERE HEARD TOGETHER AND ARE BEING DISPOSED OF B Y THIS COMMON ORDER. 2. ALL THESE APPEALS WERE FIXED FOR HEARING FOR THE FIRST TIM E ON 02-12-2014. SINCE NOBODY APPEARED ON THAT DATE THE C ASES WERE ADJOURNED TO 19-03-2015. SINCE NOBODY APPEARED ON TH AT DATE ALSO THE CASES WERE ADJOURNED TO 08-06-2015. SINCE NOBODY APPEARED ON 08-06-2015 FRESH NOTICES WERE ISSUED THROUGH RPAD. THE NOTICES WERE DULY SERVED ON THE ASSESSEE AND THE ACKNOWLEDGE MENTS ARE PLACED ON RECORD. HOWEVER, NEITHER ANYBODY APPEARED ON BEHALF OF THE ASSESSEES NOR ANY PETITION SEEKING ADJOURNMENT OF THE A PPEALS WERE FILED. IT APPEARS THAT THE ASSESSES ARE NOT INTERESTED IN PROSECUTING THESE APPEALS. THEREFORE, WE PROCEED TO DECIDE THE APPE ALS EXPARTE QUA THE ASSESSEE AND AFTER HEARING THE LD. DEPARTMENTA L REPRESENTATIVE. 3. FIRST WE TAKE UP ITA NO.24/PN/2014 IN THE CASE OF L ATE SHRI GANGADHAR RAMCHANDRA HARER AS THE LEAD CASE. THE FACT S IN BRIEF ARE THAT THE ASSESSEE SHRI GANGADHAR RAMCHANDRA HARER AN D HIS FAMILY MEMBERS RECEIVED SALE CONSIDERATION OF RS.2.75 CRORES ON A CCOUNT OF SALE OF AGRICULTURAL LAND SITUATED IN AHMEDNAGAR CITY. HOWE VER, SINCE NO RETURN OF INCOME WAS FILED DISCLOSING THE CAPITAL GAIN FROM THIS TRANSACTION NOTICE U/S.148 WAS ISSUED WHICH WAS DULY SER VED ON THE 4 ITA NOS.24 TO 28/PN/2014 ASSESSEE. IN RESPONSE TO NOTICE U/S.148 THE ASSESSEE FILE D THE RETURN OF INCOME DECLARING NIL INCOME. A NOTE WAS APPENDED BELOW T HE COMPUTATION OF INCOME STATING THAT THE ASSESSEE HAS REC EIVED RS.86,33,333 FROM C&M FARMING LTD. 4. FROM THE VARIOUS DETAILS FURNISHED BY THE ASSESSEE TH E AO NOTED THAT THE MEMBERS OF SHRI S. GANGADHAR HARER HAS GOT SA LE CONSIDERATION ON ACCOUNT OF THE ABOVE LAND AS UNDER : 5. ON BEING CONFRONTED BY THE ASSESSEE IT WAS STATED T HAT THEY ARE TENANTS UNDER BOMBAY TENANCY AND AGRICULTURAL LAND ACT , 1948. ACCORDING TO THE PROVISIONS OF THIS ACT, PERMISSION OF THE COLLECTOR IS REQUIRED U/S 43 AND U/S 64 OF THE BTAL ACT FOR TRAN SFERRING THE PROPERTY. IN VIEW OF THE ABOVE, CAPITAL GAIN TAXABILITY OF LAND WILL ARISE ONLY IN A YEAR IN WHICH THE COLLECTOR GIVES PERMISSION TO T RANSFER THE LAND. FURTHER, AS A 'DEEMED PURCHASER', THE PRICE PAYABLE BY A TENANT TO THE LANDLORD IS DETERMINED BY THE TRIBUNAL UNDER THE B TAL ACT. IN THE ASSESSEES' CASE, PURCHASE OF LAND FROM LAND OWNERS IS STILL PENDING BEFORE THE TRIBUNAL AS PER SECTIONS 32G AND 32M OF THE T ENANCY ACT. FURTHER, SINCE LAND IS SITUATED IN URBAN AREA, THE TENANT CANNOT SELL IT U/S 43C. THE ASSESSEE HAS FILED SUIT IN THE TRIBUNAL AGAINST THIS RESTRICTION ON TRANSFER. THE SUIT IS PENDING IN THE TRIBUNAL. IN VIEW OF THESE FACTS, LAND IS NOT YET TRANSFERRED IN THE ASSESSEES NAME AND THERE IS NO CONSEQUENT TRANSFER TO C & M FARMING LTD ACCORDING TO SR.NO. NAM E OF MEMBER AMOUNT (RS.) 1 RANGANATH RAMCHANDRA HARER 86,33,333 2 LATE GANGADHAR RAMCHANDRA HARER 86,33,333 3 MADHAV RAMCHANDRA HARER 86,33,334 4 SHANTABAI RAMCHANDRA LOKHANDE 8,00,000 5 LATE ANJANABAI MOHAN PAWAR 8,00,000 5 ITA NOS.24 TO 28/PN/2014 THE PROVISIONS OF SECTION 2(47) AND, THEREFORE, CAPITAL GAIN DO ES NOT ARISE IN THE FACTS OF THE CASE. 6. HOWEVER, THE AO DID NOT ACCEPT THE CONTENTION OF TH E ASSESSEE. HE OBSERVED THAT AS PER THE AGREEMENT DATED 13.07.2004 WITH C & M FARMING LTD, MUMBAI, ASSESSEES RECEIVED TOTAL RS 2.75 CR. AT THE TIME OF SIGNING OF AN AGREEMENT, ADVANCE OF TOTAL RS 13 LAKHS WA S GIVEN TO THE ASSESSEES. SUBSEQUENTLY, BEFORE 31.03.2005, THE ASSE SSEES HAVE RECEIVED ENTIRE AMOUNT OF RS 2.75 CR. AFTER RECEIPT OF THIS AMOUNT OF SALE CONSIDERATION, THE ASSESSEES HAVE INVESTED THIS AMOU NT IN PURCHASE OF NEW AGRICULTURAL LANDS, CONSTRUCTION OF NEW HOU SE AND ALSO INCURRED EXPENDITURE ON MARRIAGES OF THEIR CHILDREN AN D USED A PART OF THE AMOUNT TO REPAY THEIR PERSONAL DEBTS. FUR THER, IN THE RETURN OF INCOME BY THE ASSESSEE, IT IS STATED THAT THEY HAVE PAID RS 15 LAKHS TOWARDS COMMISSION FOR SUCH TRANSACTION. HOWEVER, GE NERALLY COMMISSION IS PAID ONLY AFTER FINALIZATION OF THE TRANSACTION. 7. THE AO FURTHER NOTED THAT AS AGREED UPON, THE TOT AL SALE CONSIDERATION OF RS 2,75 CR HAS BEEN RECEIVED BY THE AS SESSES. THEREFORE, NO AMOUNT OF BALANCE IS PENDING WITH THE PURCHA SER COMPANY. APART FROM ABOVE, THE ORIGINAL LAND OWNERS - MR. S AYYED USUF GAFFUR AND MR SAYYED CHAND GAFFUR- HAVE ALREADY DE CLARED THE CAPITAL GAIN FROM THE SALE OF THE ABOVE LAND AND PAID THE T AXES ACCORDINGLY. THE AO ACCORDINGLY DETERMINED THE CAPITAL G AIN OF RS.12,38,526/- IN THE HANDS OF THE ASSESSEE. SIMILAR CAPITAL G AIN HAVE BEEN DETERMINED IN THE HANDS OF THE OTHER FAMILY MEMBERS WHICH IS AS UNDER : SHRI RANGANATH RAMCHANDRA HARER RS.11,29,496/- SHRI MADHAV RAMCHANDRA HARER RS.11,86,767/- LATE SMT.ANJANABAI MOHAN PAWAR RS.3,56,020/- SMT. SHANTABAI RAMCHANDRA LOKHANDE RS.3,49,040/- 6 ITA NOS.24 TO 28/PN/2014 8. BEFORE CIT(A) THE ASSESSEE REITERATED THE SAME ARGUME NTS. HOWEVER, THE CIT(A) WAS ALSO NOT SATISFIED WITH THE EXPLANAT ION GIVEN BY THE ASSESSEE AND IN A CONSOLIDATED ORDER UPHELD THE ACTION OF THE AO BY OBSERVING AS UNDER: 2.8 I HAVE CONSIDERED THE FACTS, PROVISIONS OF THE INC OME TAX ACT, RELEVANT PROVISIONS OF BOMBAY TENANCY AGRICULTURAL LA NDS ACT AS WELL AS THE ARGUMENTS OF THE APPELLANTS. I AM OF THE VIEW THA T CAPITAL GAIN TAX SHOULD BE LEVIED ON THE APPELLANTS. THE REASONS FOR MY DECISION ARE AS UNDER: 2.9 THE APPELLANTS HAVE ARGUED THAT THERE IS NO TRANSF ER WITHIN THE MEANING OF SECTION 2(47). IT NEEDS TO BE APPRECIATED THAT FOR LEVYING OF CAPITAL GAIN TAX, THE ASSESSEE NEED NOT BE THE OWNER O F THE ASSET. SECTION 2(14) OF THE INCOME TAX ACT REQUIRES THAT 'CAPITAL A SSET' SHOULD BE HELD BY THE ASSESSEE. THE WORD 'HELD' IS INTERPRETED BY CALCUTTA HIGH COURT IN THE CASE OF CIT VS. ALL INDIA TEA AND TRADING CO LIMITED (1979) 117 ITR 525 (CAL) AS PHYSICAL, ACTUAL, CONSTRUCTIVE OR SYMBOLIC POSSE SSION OF PROPERTY OF ANY KIND. THE APPELLANTS ARE IN PHYSICAL POSSESSION OF THE LAND. THEREFORE, LAND IS HELD BY THEM AND BEING 'DEEMED PU RCHASER' UNDER THE BTAL ACT BECAUSE THEY HOLD THE 'CAPITAL ASSET', THEY A RE LEGALLY CAPABLE OF TRANSFERRING LAND AND RIGHTS ASSOCIATED WITH THE LAND. 2.10 THE APPELLANTS HAVE STATED THERE IS NO TRANSFER I N TERMS OF PROVISIONS OF SECTION 2(47) OF THE INCOME TAX ACT BECAUSE THEY ARE ONLY 'DEEMED PURCHASER' UNDER THE BOMBAY TENANCY AND AGRICULTURAL LAND ACT. IT IS STATED THAT THE DISPUTE REGARDING THE PURCHASE WITH TH E LANDLORD IS PENDING IN THE COURT. FURTHER, THE DISTRICT COLLECT OR IS YET TO GIVE PERMISSION FOR TRANSFERRING THE LAND ACCORDING TO THE PROVISIONS OF THE BOMBAY TENANCY AND AGRICULTURAL LANDS ACT. 2.11 I HAVE CAREFULLY CONSIDERED THE APPELLANTS' CONT ENTION. IN MY VIEW, THIS IS NOT THE CASE OF TRANSFER OF THE AGRICULTURAL LA ND. IN THIS CASE, THE 'CAPITAL ASSET', WHICH HAS BEEN TRANSFERRED IS THE 'RIG HT TO OBTAIN CONVEYANCE OF IMMOVABLE PROPERTY'. THIS RIGHT HAS BEE N TRANSFERRED BY THE APPELLANTS TO THE PURCHASER- C & M FARMING LIMITE D. THE PERUSAL OF THE PARA 10 OF THE AGREEMENT BETWEEN THE APPELLANTS AND C&M FARMING LIMITED DATED 13.07.2004 SHOW THAT THE APPELLANT HA S UNDERTAKEN TO TRANSFER LAND TO THE PURCHASER OR TO ANYONE NAMED BY THE PURCHASER. IT IS STATED THAT THIS AGREEMENT HAS BEEN MADE IN THE FAVOUR OF THE PURCHASER AND THE LAND CAN BE TRANSFERRED BY THE PURCHASER TO A NYONE ELSE, WHICH WOULD NOT BE OBJECTED TO BY THE SELLERS. FURTHER, THE RIGHT OF RECEIVING COMPENSATION FROM MHADA IN CASE OF ACQUISITION OF LAND HAS BEEN GRANTED TO THE PURCHASER COMPANY IN ACCORDANCE WITH THE PARA 11 OF THE AGREEMENT. 2.12 IN PARA 12 OF THE AGREEMENT, THE SELLERS HAVE UN DERTAKEN TO TRANSFER THE LAND WITHOUT ANY ENCUMBRANCE. THE APPELLANT HAV E ALSO UNDERTAKEN TO COMPLY WITH ALL THE PROCEDURAL REQUIREMENTS FOR GETT ING LAND TRANSFERRED IN THE NAME OF PURCHASER FOR WHICH, AS NOTED BY THE L EARNED AO, THE PURCHASER HAS PAID FULL CONSIDERATION OF RS 2.75 CR TO THE APPELLANT. IN PARA 8 OF THE AGREEMENT IT IS STATED THAT THERE IS A C ERTAINTY OF APPELLANTS PURCHASING LAND FROM THE OWNERS. BECAUSE OF THE CERTAI NTY, THE PURCHASER 7 ITA NOS.24 TO 28/PN/2014 HAS PAID FULL AMOUNT TO THE APPELLANTS AND APPELLANTS HAVE APPLIED THESE AMOUNTS TOWARDS PURCHASE OF OTHER AGRICULTURAL LAND AN D OTHER ASSETS. 2.13 THE ABOVE DISCUSSION MAKES IT CLEAR THAT THE 'CAPI TAL ASSET' TRANSFERRED BY THE APPELLANTS IS NOT AGRICULTURAL LAND BUT 'ASSIGNMENT OF RIGHT TO OBTAIN CONVEYANCE' OF THE AGRICULTURAL LAN D. 'RIGHT TO OBTAIN CONVEYANCE OF IMMOVABLE PROPERTY' IS HELD TO BE CAPI TAL ASSET BY THE JURISDICTIONAL HIGH COURT IN THE CASES OF CIT VS. VIJAY FLEXIBLE CONTAINERS (1990) 186 ITR 693 (BOM) AND CIT VS. TATA SERVICES LT D (1980) 122 ITR 594(BOM). I ALSO DERIVE SUPPORT FROM THE FOLLOWING DE CISIONS: I. RUSTAM SPINNERS PRIVATE LIMITED VS. CIT (1992) 198 ITR 351 (GUJ) II. CIT VS. SMT. LAXMIDEVI RATANI (2008) 296 ITR 363 (MP ) III. CIT VS. H. ANIL KUMAR (2011) 56 DTR 384 (KAR) 2.14 IN VIEW OF THE ABOVE DISCUSSION AND DECISIONS OF TH E JURISDICTIONAL HIGH COURT I HOLD THAT THE LEARNED AO HAS CORRECTLY LEVIED CAPITAL GAINS TAX ON THE APPELLANTS. I CONFIRM THE ADDITION MADE BY THE LEARNED AO. 9. AGGRIEVED WITH SUCH ORDER OF THE CIT(A) THE ASSESSEE IS IN APPEAL BEFORE US WITH THE FOLLOWING GROUNDS : 1. ON THE FACTS AND CIRCUMSTANCES OF THE CASE CIT(A) H AS ERRED IN LAW BY TREATING TRANSFER AS PER SECTION 2(47) OF THE INCO ME TAX ACT. 2. ON THE FACTS AND CIRCUMSTANCES OF THE CASE CIT(A) HA S ERRED IN LAW BY TREATING TRANSFER WHEREAS AS PER BOMBAY TENANCY AND AGRICULTURE LAND ACT 1948 IN SECTION 43 THERE IS CONDITION AND Y EAR OF TAXABILITY IS GIVEN. 3. ON THE FACTS AND CIRCUMSTANCES OF THE CASE CIT(A) HA S ERRED IN LAW BY TREATING TRANSFER WHEREAS AS PER BOMBAY TENANCY AND AGRICULTURE LAND ACT 1948 AS PER SECTION 43C A TENANT CANNOT TRA NSFER A LAND WHICH IS STATED IN MUNICIPAL CORPORATION OF AHMEDNAGAR. 4. ON THE FACTS AND CIRCUMSTANCES OF THE CASE CIT(A) H AS ERRED BY NOT VERIFYING ALL MODES OF TRANSFER MENTIONED IN THE AGREEMENT, NONE OF MODE IS COMPLETE DURING THE SAID ASSESSMENT YEAR. 5. ON THE FACTS AND CIRCUMSTANCES OF THE CASE AGREEMENT IS MADE BY APPELLANT AS DEEMED PURCHASER HENCE MANY LEGAL FORM ALITIES AS PER BOMBAY TENANCY AND AGRICULTURE LAND 1948 HAVE TO BE DONE, WHICH WAS PENDING DURING THE SAID ASSESSMENT YEAR. THIS FACT NOT C ONSIDERED BY CIT(A). 6. ON THE FACTS AND CIRCUMSTANCES OF THE CASE CIT(A) HA S ERRED BY TREATING TRANSFER EVENTHOUGH POSSESSION OF LAND IS STILL W ITH THE APPELLANT. 7. THE APPELLANT CRAVES LEAVE TO ADD, ALTER, AMEND O R DELETE ANY OF THE GROUNDS. (IDENTICAL GROUNDS HAVE BEEN TAKEN BY THE OTHER ASSESSES) 8 ITA NOS.24 TO 28/PN/2014 10. THE LD. DEPARTMENTAL REPRESENTATIVE HEAVILY RELIED ON THE ORDER OF THE AO AND THE CIT(A). 11. WE HAVE CONSIDERED THE ARGUMENTS ADVANCED BY THE LD. DEPARTMENTAL REPRESENTATIVE AND PERUSED THE MATERIAL AV AILABLE ON RECORD. WE FIND THE LD.CIT(A) HAS RIGHTLY OBSERVED THAT T HE ASSESSEE IN THE INSTANT CASE HAVE TRANSFERRED THEIR RIGHT TO OBTAIN THE CONVEYANCE OF IMMOVABLE PROPERTY TO THE PURCHASER C&M FARMING LTD. FURTHER, PARA 10 OF THE AGREEMENT BETWEEN THE ASSESSEES AND C &M FARMING LTD. DATED 13-07-2004 ALSO SHOWS THAT THE ASSESSEES H AVE UNDERTAKEN TO TRANSFER LAND TO THE PURCHASER OR TO ANYONE NAMED BY THE PURCHASER. FURTHER, THE RIGHT OF RECEIVING COMPENSATION FR OM MHADA IN CASE OF ACQUISITION OF LAND HAS BEEN GRANTED TO THE PUR CHASER COMPANY IN ACCORDANCE WITH PARA 11 OF THE AGREEMENT. P ARA 12 OF THE AGREEMENT SAYS THAT THE SELLERS HAVE UNDERTAKEN TO T RANSFER THE LAND WITHOUT ANY ENCUMBRANCE. THE ASSESSEES HAVE ALSO UNDE RTAKEN TO COMPLY WITH ALL THE PROCEDURAL REQUIREMENT FOR GETTING TH E LAND TRANSFERRED IN THE NAME OF THE PURCHASER FOR WHICH HE HA S PAID FULL CONSIDERATION OF RS.2.75 CRORES TO THE RESPECTIVE PARTIES. UNDER THE AFOREMENTIONED CIRCUMSTANCES, WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF THE CIT(A) HOLDING THAT THE CAPITAL ASSET TRANSFER RED BY THE ASSESSES IS NOT AGRICULTURAL LAND BUT ASSIGNMENT OF RIGHT TO OBTAIN THE CONVEYANCE OF THE AGRICULTURAL LAND. THE VARIOUS DEC ISIONS RELIED UPON BY LD.CIT(A) ALSO SUPPORTS THE CASE OF THE REVENUE . UNDER THESE CIRCUMSTANCES, WE FIND NO INFIRMITY IN THE ORDER OF THE CIT(A ). WE ACCORDINGLY UPHOLD THE SAME. THE GROUNDS RAISED BY THE ASSESSEES ARE ACCORDINGLY DISMISSED. 9 ITA NOS.24 TO 28/PN/2014 12. IN THE RESULT, ALL THE APPEALS FILED BY THE RESPECTIVE AS SESSEES ARE DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 11-09-2015. SD/- SD/- ( VIKAS AWASTHY ) ( R.K. PANDA ) ' / JUDICIAL MEMBER / ACCOUNTANT MEMBER IQ.KS PUNE ; # DATED : 11 TH SEPTEMBER, 2015. LRH'K ( )'+ , / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT 3. ( ( ) S / THE CIT(A)-IT/TP, PUNE 4. ( S / THE CIT-, IT/TP, PUNE 5. 6. + ., ., IQ.KS / DR, ITAT, B PUNE; / GUARD FILE. / BY ORDER , + //TRUE C + //TRUE COPY// 2 . / SR. PRIVATE SECRETARY ., IQ.KS / ITAT, PUNE
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