Guru Nanak Public School, New Delhi V. DIT(E), New Delhi

ITA 3268/DEL/2008

• Counselvise Citation: [2009] 115 COUNSELVISE.COM (IT) 1335 (ITAT-DELHI)
• Duration Of Justice: 11 month(s) 19 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-10-2009
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: C
• Next Hearing Date: 25-09-2012
• Assessment Year: 2008-2009
• Appeal Filed On: 03-11-2008
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: MONA MOHANTY
• Assessee Lawyers: P S KOHLI
• Keywords: Retrospective amendment
• Section: 80G; 12A; 12AA

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH C : NEW DELHI BEFORE SHRI D.R.SINGH, JM AND SHRI R.C.SHARMA, AM ITA NOS.3267/DEL/2008 & 3268/DEL/2008 GURU NANAK PUBLIC SCHOOL, WEST AVENUE, PUNJABI BAGH, NEW DELHI. VS. DIRECTOR OF INCOME TAX (EXEMPTION), DELHI. (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI P.S.KOHLI. RESPONDENT BY : SMT.MONA MOHANTY, DR. ORDER PER BENCH : THESE ARE THE APPEALS FILED BY THE ASSESSEE AGAINS T THE ORDER OF DIRECTOR OF INCOME TAX (EXEMPTION), DELHI DATED 22 ND SEPTEMBER, 2008 PASSED U/S 12AA(1)(B) OF THE IT ACT. 2. ASSESSEE IN THESE APPEALS IS AGGRIEVED BY THE OR DER OF DIRECTOR OF INCOME TAX CANCELING REGISTRATION U/S 12A AND WITHDRAWAL O F 80-G EXEMPTION. 3. RIVAL CONTENTIONS HAVE BEEN HEARD AND RECORD PER USED. FACTS IN BRIEF ARE THAT THE ASSESSEE SHRI GURU SINGH SABHA, PUNJABI BA GH DELHI IS THE SOCIETY WHICH WAS FORMED AND REGISTERED WITH REGISTRAR OF SOCIETI ES ON 10.7.1963. GURU NANAK PUBLIC SCHOOL WAS GRANTED REGISTRATION U/S 12A ON T HE BASIS OF SCHEME OF MANAGEMENT. EXEMPTION U/S 80G WAS ALSO GRANTED, WH ICH HAS BEEN RENEWED FROM TIME TO TIME AND UPTO 31.3.2008. THE SCHOOL IS REC OGNIZED AND AFFILIATED TO THE CBSE. THE SCHOOL WAS ALSO GRANTED REGISTRATION U/S 10(22) IN THE PAST, IT HAS CLAIMED EXEMPTION U/S 10(23C) OF IT ACT. DURING TH E COURSE OF PROCEEDINGS U/S 10(23C), THE DIT OBSERVED THAT THE ASSESSEE MEANT O NLY FOR THE MANAGING COMMITTEE OF THE SCHOOL AND THE SCHEME OF MANAGEMEN T DOES NOT BY ITSELF GIVE ITA-3267 & 3268/D/2008 2 RISE TO CREATION OF ANY LEGAL ENTITY, BE IT A TRUST OR AN INSTITUTION. ON THE OTHER HAND, ASSESSEE HAS ADMITTED AND IT IS CLEAR FROM THE MOA OF SHRI GURU SINGH SABHA AND THE SCHEME OF MANAGEMENT THAT SHRI GURU SINGH SABHA IS THE SOCIETY WHICH HAS BEEN SET UP WITH A VIEW TO CARRY OUT ITS OBJECTS ME NTIONED IN CLAUSE 3. IN FURTHERANCE OF THOSE OBJECTS, IT HAS SET UP GURU NA NAK PUBLIC SCHOOL. FOR MANAGING THE OPERATION OF THE SCHOOL, A SEPARATE MA NAGEMENT COMMITTEE HAS BEEN FORMED. A SOCIETY CAN RUN ONE SCHOOL OR TWO SCHOOL S. IT CAN RUN SCHOOL, HOSPITAL AND OTHER INSTITUTIONS. IT CAN ALSO CARRY OUT OTHE R ACTIVITIES IN ADDITION TO RUNNING OF SCHOOLS AND HOSPITALS. REGISTRATION U/S 12A IS NOT GIVEN TO SEPARATE ACTIVITIES OF ANY ASSESSEE. FOR EXAMPLE, A SOCIETY RUNNING TWO S CHOOLS IS NOT REQUIRED TO OBTAIN REGISTRATION U/S 12A SEPARATELY FOR TWO SCHOOLS. R EGISTRATION IS GIVEN TO THE SOCIETY WHICH IS THE OWNER OF THESE SCHOOLS AND RUN THEM. THE DIT(EXEMPTION) OBSERVED THAT THE REGISTRATION U/S 12A WAS ERRONEOU SLY GRANTED TO GURU NANAK PUBLIC SCHOOL, WHICH HAS NO LEGAL EXISTENCE AT ALL. ACCORDING TO HIM, REGISTRATION SHOULD HAVE BEEN REQUESTED BY SHRI GURU SINGH SABHA , WHICH IS A SOCIETY, WHICH WOULD HAVE ENTITLED SHRI GURU SINGH SABHA FOR EXEMP TION OF ITS INCOME U/S 11, NOT ONLY IN RESPECT OF GURU NANAK PUBLIC SCHOOL RUN BY IT, BUT ALSO IN RESPECT OF ITS ALL OTHER CHARITABLE ACTIVITIES. HOWEVER, THIS HAS NOT HAPPENED. 4. IN VIEW OF THE ABOVE, DIT HELD THAT GURU NANAK P UBLIC SCHOOL HAS NO LEGAL EXISTENCE AND IS NOT ENTITLED TO REGISTRATION U/S 1 2A AND EXEMPTION U/S 80G. AGGRIEVED BY THE ORDER OF DIT, THE ASSESSEE IS IN F URTHER APPEAL BEFORE US. 5. AT THE OUTSET, LEARNED AR PLACED ON RECORD ORDER OF THE ITAT PUNE BENCH IN THE CASE OF BHARATI VIDYAPEETH 28 SOT 32 AND C ONTENDED THAT EXACTLY SIMILAR ISSUE WAS DEALT WITH AND IT WAS HELD THAT REGISTRAT ION GRANTED U/S 12A CANNOT BE WITHDRAWN OR CANCELLED BY THE COMMISSIONER BY INVOK ING PROVISIONS U/S 12AA(3) OF THE IT ACT. ON THE OTHER HAND, LEARNED DR RELIE D ON THE ORDER OF DIT(EXEMPTION). ITA-3267 & 3268/D/2008 3 6. WE HAVE CONSIDERED THE RIVAL CONTENTIONS, GONE T HROUGH THE ORDERS OF THE AUTHORITIES BELOW AND FOUND THAT ASSESSEE IS A SOCI ETY REGISTERED UNDER THE SOCIETIES REGISTRATION ACT. IT WAS GRANTED REGISTR ATION U/S 12A AND ALSO EXEMPTION U/S 80G. REGISTRATION U/S 12A WAS WITHDRAWN BY THE DIT BY EXERCISING ITS POWER U/S 12AA(3) OF THE IT ACT. IN CONSEQUENCE OF WITHD RAWAL OF REGISTRATION U/S 12A, THE EXEMPTION GRANTED U/S 80G WAS ALSO WITHDRAWN. ITAT PUNE BENCH IN THE CASE OF BHARATI VIDYAPEETH (SUPRA) HAS ELABORATELY DEALT WITH THE POWER OF THE DIT FOR CANCELLATION OF THE REGISTRATION GRANTED U/S 12A WH EREIN IT WAS OBSERVED THAT REGISTRATION GRANTED UNDER SECTION 12A CANNOT BE WI THDRAWN OR CANCELLED BY THE COMMISSIONER BY INVOKING THE PROVISIONS OF SECTION 12AA(3). A PLAIN READING OF THE PROVISION OF SECTION 12AA(3) SHOWS THAT SECTION 12AA EMPOWERS THE COMMISSIONER TO GRANT THE REGISTRATION IN THOSE CAS ES WHERE THE ASSESSEE APPLIES FOR SUCH REGISTRATION UNDER SUB-SECTION (1) OF SECT ION 12AA. SECTION 12AA(1), ON THE OTHER HAND, PROVIDES THAT THE COMMISSIONER, ON RECEIPT OF AN APPLICATION FOR REGISTRATION OF A TRUST OR AN INSTITUTION MADE UNDE R CLAUSE (A) OR CLAUSE (AA) OF SUB- SECTION (1) OF SECTION 12A, SHALL (A) CALL FOR SU CH DOCUMENTS OR INFORMATION FROM THE TRUST OR INSTITUTION AS HE THINKS NECESSARY IN ORDER TO SATISFY HIMSELF ABOUT THE GENUINENESS OF ACTIVITIES OF THE TRUST OR INSTITUTI ON AND MAY ALSO MAKE SUCH INQUIRIES AS HE MAY DEEM NECESSARY IN THAT BEHALF; AND (B) AFTER SATISFYING HIMSELF ABOUT THE OBJECTS OF THE TRUST OR THE INSTITUTION A ND THE GENUINENESS OF ITS ACTIVITIES, (I) HE SHALL PASS AN ORDER IN WRITING REGISTRATION THE TRUST OR INSTITUTION, OR (II) HE SHALL, IF HE IS NOT SO SATISFIED, PASS AN ORDER IN WRITING REFUSING TO REGISTER THE TRUST OR THE INSTITUTION, AND A COPY OF SUCH AN ORDER SHA LL BE SENT TO THE APPLICANT. A REGISTRATION UNDER SECTION 12AA(1)(B) IS TO BE GRAN TED WHERE THE COMMISSIONER IS SATISFIED ABOUT THE OBJECTS AND THE GENUINENESS OF THE ACTIVITIES CARRIED ON BY THE APPLICANT. SECTION 12AA(3) EMPOWERS THE COMMISSION ER TO CANCEL SUCH REGISTRATION, IF HE IS SATISFIED THAT ACTIVITIES OF THE TRUST OR THE INSTITUTION ARE NOT GENUINE OR ARE NOT BEING CARRIED OUT IN ACCORDANCE WITH THE OBJECTS OF THE TRUST OR INSTITUTION, AS THE CASE MAY BE. THE COMBINED READ ING OF BOTH THE SECTIONS MAKES IT CLEAR THAT REGISTRATION CAN BE CANCELLED ONLY IN THOSE CASES WHERE IT HAS BEEN ITA-3267 & 3268/D/2008 4 GRANTED UNDER SUB-SECTION (1B) OF SECTION 12AA. TH AT SECTION NOWHERE EMPOWERS THE COMMISSIONER TO CANCEL OR WITHDRAW THE REGISTRA TION GRANTED UNDER SECTION 12A. IN THE ABSENCE OF SUCH POWER, THE REGISTRATIO N GRANTED UNDER SECTION 12A CANNOT BE WITHDRAWN OR CANCELLED. 7. FOLLOWING WAS THE PRECISE OBSERVATION OF HONBLE BENCH AT PARA 7 TO 11:- 7. WE HAVE HEARD THE RIVAL CONTENTIONS, PERUSED THE M ATERIAL ON RECORD AND DULY CONSIDERED FACTUAL MATRIX OF THE CA SE AS ALSO THE APPLICABLE LEGAL POSITION. 8. THE PLEA OF THE ASSESSEE MEETS OUR APPROVAL. IN OU R CONSIDERED VIEW, A REGISTRATION GRANTED UNDER SECTION 12A OF T HE ACT CANNOT BE WITHDRAWN OR CANCELLED BY THE CIT BY INVOKING THE P ROVISIONS OF SECTION 12AA(3) OF THE ACT. SECTION 12AA(3) PROVIDE S THAT WHERE A TRUST OR AN INSTITUTION HAS BEEN GRANTED REGISTRATI ON UNDER CLAUSE ( B ) OF SUB-SECTION (1) AND SUBSEQUENTLY THE CIT IS SATI SFIED THAT THE ACTIVITIES OF SUCH TRUST OR INSTITUTION ARE NOT GEN UINE OR ARE NOT BEING CARRIED OUT IN ACCORDANCE WITH THE OBJECTS OF THE T RUST OR INSTITUTION, AS THE CASE MAY BE, HE SHALL PASS AN ORDER IN WRITI NG CANCELLING THE REGISTRATION OF SUCH TRUST OR INSTITUTION. A PLAIN READING OF THIS PROVISION SHOWS THAT SECTION 12AA EMPOWERS THE CIT TO GRANT THE REGISTRATION IN THOSE CASES WHERE THE ASSESSEE APPL IES FOR SUCH REGISTRATION UNDER SUB-SECTION (1) OF SECTION 12AA. SECTION 12AA(1), ON THE OTHER HAND, PROVIDES THAT THE CIT, ON RECEIPT OF AN APPLICATION FOR REGISTRATION OF A TRUST OR INSTITUT ION MADE UNDER CLAUSE ( A ) [OR CLAUSE ( AA ) OF SUB-SECTION (1)] OF SECTION 12A, SHALL( A ) CALL FOR SUCH DOCUMENTS OR INFORMATION FROM THE TRUST OR INSTITUTION AS HE THINKS NECESSARY IN ORDER TO SATISFY HIMSELF ABOUT THE GENUINENESS OF ACTIVITIES OF THE TRUST OR INSTITUTION AND MAY ALSO MAKE SUCH INQUIRIES AS HE MAY DEEM NECESSARY IN THIS BEHALF; AND ( B ) AFTER SATISFYING HIMSELF ABOUT THE OBJECTS OF THE TRUST OR INSTITUTI ON AND THE GENUINENESS OF ITS ACTIVITIES, ( I ) HE SHALL PASS AN ORDER IN WRITING REGISTERING THE TRUST OR INSTITUTION, OR ( II ) SHALL, IF HE IS NOT SO SATISFIED, PASS AN ORDER IN WRITING REFUSING TO REG ISTER THE TRUST OR INSTITUTION, AND A COPY OF SUCH ORDER SHALL BE SENT TO THE APPLICANT. A REGISTRATION UNDER SECTION 12AA(1)( B ) IS TO BE GRANTED WHERE CIT IS SATISFIED ABOUT THE OBJECTS AND THE GENUINENESS OF THE ACTIVITIES CARRIED ON BY THE APPLICANT. SECTION 12AA(3) EMPOWE RS THE CIT TO CANCEL SUCH REGISTRATION IF HE IS SATISFIED THAT AC TIVITIES OF TRUST OR INSTITUTION ARE NOT GENUINE OR ARE NOT BEING CARRIE D OUT IN ACCORDANCE WITH THE OBJECTS OF THE TRUST OR INSTITUTION AS THE CASE MAY BE. THE COMBINED READING OF BOTH THE SECTIONS MAKES IT CLEA R THAT REGISTRATION ITA-3267 & 3268/D/2008 5 CAN BE CANCELLED ONLY IN THOSE CASES WHERE THE REGI STRATION HAS BEEN GRANTED UNDER SUB-SECTION ( 1B ) OF SECTION 12AA. THIS SECTION NOWHERE EMPOWERS THE CIT TO CANCEL OR WITHDRAW THE REGISTRATION GRANTED UNDER SECTION 12A. IN THE ABSENCE OF SUCH P OWER, IN OUR OPINION, THE REGISTRATION GRANTED UNDER SECTION 12A CANNOT BE WITHDRAWN OR CANCELLED. THIS VIEW IS SUPPORTED BY T HE DECISION OF THE TRIBUNAL IN THE CASE OF KAILASHANAND MISSION TRUST V. ASSTT. CIT ( SUPRA ) WHEREIN IT WAS HELD THAT SECTION 12A DOES NOT EMP OWER THE CIT TO WITHDRAW OR CANCEL THE REGISTRATION GRANTED UNDER THE SECTION. THIS VIEW WAS AGAIN TAKEN BY THE TRIBUNAL IN VARIOU S CASES RELIED UPON BY THE LEARNED COUNSEL FOR THE ASSESSEE. HONB LE UTTARANCHAL HIGH COURT, IN THE CASE OF WELHAM BOYS SCHOOL SOCIETY ( SUPRA ) HAS ALSO HELD THAT THE CIT CANNOT WITHDRAW OR CANCEL A REGISTRATION GRANTED UNDER SECTION 12A, AS HE CANNOT BE INFERRED TO HAVE ANY IMPLIED OR INHERENT POWER TO CANCEL THE REGISTRATIO N. WE MAY ALSO ADD THAT PROVISIONS OF SUB-SECTION (3) OF SECTION 1 2AA WERE BROUGHT ON THE STATUTE BOOK WITH EFFECT FROM 1-10-2004 BY F INANCE (NO. 2) ACT, 2004. THE PROVISIONS OF THIS SECTION ARE SUBST ANTIVE IN NATURE SINCE THE SAME AFFECT THE VALUABLE RIGHT OF THE ASS ESSEE AND THEREFORE, IN OUR OPINION ARE PROSPECTIVE AND CANNOT BE GIVEN RETROSPECTIVE EFFECT, IN VIEW OF THE DECISION OF THE SUPREME COUR T IN THE CASE OF SEDCO FOREX INTERNATIONAL DRILL INC. V. CIT [2005] 279 ITR 310 FTN2BHARATI VIDYAPEETH V. ITO.HTM (SC) WHEREIN IT HAS BEEN HELD THAT EVEN THE PROVISIONS OF AN EXPLANATION CANNOT BE GIVEN RETROSPECTIVE EFFECT UNLESS SPECIFICALLY PROVIDED BY THE STATUTE. IT IS NOT THE CASE OF THE REVENUE THAT LEGISLATURE SPECIFICALLY PROVIDED THE RETROSPECTIVE EFFECT OF SUCH PROVISION. THEREFORE, IT IS ALSO TO BE HELD THAT EVEN ON THIS GROUND THE PROVISIONS OF SECTION 12AA(3) CANNO T BE APPLIED TO THE REGISTRATION GRANTED UNDER SECTION 12A OF THE A CT. WE ALSO FIND THAT THE ISSUE IN APPEAL IS SQUARELY COVERED BY A N UMBER OF DECISIONS ON THIS ISSUE BY VARIOUS CO-ORDINATE BENCHES AND TH ERE IS NO CONTRARY DECISION AVAILABLE, SO FAR AS THIS ASPECT OF THE MATTER IS CONCERNED. 9. LEARNED DEPARTMENTAL REPRESENTATIVE HAS STATED THA T SUCH A VIEW WILL MAKE THE PROVISIONS OF THE ACT UNWORKABLE AND THAT THE ONLY WAY TO MAKE THESE PROVISIONS WORKABLE IS TO CONSTRU E THE SCOPE OF SECTION 12AA(3) IN SUCH A MANNER SO AS TO EXTEND IT S SCOPE ALSO TO THE REGISTRATIONS GRANTED UNDER SECTION 12A. WE ARE THUS URGED TO SUPPLANT THE LAW BY SUPPLYING A CASUS OMISSUS . WE ARE NOT PERSUADED BY THIS PLEA EITHER. CASUS OMISSUS, WHICH BROADLY REFERS TO THE PRINCIPLE THAT A MATTER WHICH HAS NOT BEEN PROV IDED IN THE STATUTE BUT SHOULD HAVE BEEN THERE, CANNOT BE SUPPLIED BY U S, AS, TO DO SO WILL BE CLEARLY BEYOND THE CALL AND SCOPE OF OUR DU TY WHICH IS ONLY TO INTERPRET THE LAW AS IT EXISTS. HONBLE SUPREME COU RT, IN THE CASE OF SMT. TARULATA SHYAM V. CIT [1977] 108 ITR 345 (SC) AT P. 356 HAS ITA-3267 & 3268/D/2008 6 OBSERVED AS FOLLOWS : WE HAVE GIVEN ANXIOUS THOUGH T TO THE PERSUASIVE ARGUMENTS..., (WHICH) IF ACCEPTED, WILL CERTAINLY SOFTEN THE RIGOUR OF THIS EXTREMELY DRASTIC PROVISION AND BRIN G IT MORE IN CONFORMITY WITH LOGIC AND EQUITY. BUT, THE LANGUAGE OF SECTIONS ... IS CLEAR AND UNAMBIGUOUS. THERE IS NO SCOPE FOR IMPORT ING INTO THE STATUTE THE WORDS WHICH ARE NOT THERE. SUCH INTERPR ETATION WOULD BE, NOT TO CONSTRUE, BUT TO AMEND THE STATUTE. EVEN IF THERE BE A CASUS OMISSUS , THE DEFECT CAN BE REMEDIED ONLY BY LEGISLATION AN D NOT BY JUDICIAL INTERPRETATION..... THIS WAS CLEARLY A CA SE IN WHICH SUPPLYING A CASUS OMISSUS WOULD HAVE SOFTENED THE RIGOUR OF LAW FOR THE ASSESSEE, AND YET HONBLE SUPREME COURT DECLINE D TO SUPPLY THE CASUS OMISSUS . IN A SITUATION LIKE THE ONE THAT WE ARE IN SEISIN OF, WHERE ASSESSEE WOULD STAND TO A DISADVANTAGE AS A R ESULT OF CASUS OMISSUS BEING SUPPLIED, AT LEAST THE SAME, IF NOT MORE STR INGENT, YARDSTICKS MUST APPLY. WHEN THE HONBLE SUPREME COU RT DECLINES TO SUPPLY CASUS OMISSUS EVEN IN A CASE WHERE THEIR LORDSHIPS HAVE NOTED THAT THE PROVISIONS IN QUESTION ARE EXTREMELY DRASTIC AND SUPPLYING A CASUS OMISSUS WILL MAKE THESE PROVISIONS MORE IN CONFORMITY WITH LOGIC AND EQUITY, IT IS INDEED FUTI LE TO SUGGEST THAT SUCH A CASUS OMISSUS CAN BE SUPPLIED BY THIS TRIBUNAL. WE ARE NOT INCLINED TO ACCEPT THE PLEA CANVASSED BY THE LEARNE D DEPARTMENTAL REPRESENTATIVE TO THE EFFECT THAT WE SHOULD INTERPR ET THE SCOPE OF SECTION 12AA(3) SO AS TO GIVE IT AN EXTENDED MEANIN G BEYOND WHAT IS LAID DOWN BY SPECIFIC WORDS OF THE STATUTE. 10. FOR THE REASONS SET OUT ABOVE, AND RESPECTFULLY FO LLOWING THE DECISIONS OF VARIOUS CO-ORDINATE BENCHES ON THE SCO PE OF POWERS UNDER SECTION 12AA(3), WE HOLD THAT THE IMPUGNED OR DER WAS VITIATED IN LAW INASMUCH AS THE LEARNED CIT DID NOT HAVE POWERS TO CANCEL THE REGISTRATION GRANTED UNDER SECTION 12A. ACCORDINGLY, THE IMPUGNED ORDER IS HEREBY VACATED AND, AS A COROLLAR Y THERETO, THE REGISTRATION GRANTED TO THE ASSESSEE UNDER SECTION 12A STANDS RESTORED. 11. IN THE RESULT, THE APPEAL IS ALLOWED. 8. IN THE INSTANT CASE BEFORE US, THE REGISTRATION GRANTED TO ASSESSEE SOCIETY U/S 12A WAS WITHDRAWN BY DIT(EXEMPTION) BY EXERCISING T HE POWERS CONFERRED U/S 12AA(3) OF IT ACT. IN TERMS OF THE ORDER OF ITAT P UNE BENCH, THERE IS NO SUCH POWER CONFERRED UNDER IT ACT TO DIT(EXEMPTION). AS THE FACTS AND CIRCUMSTANCES OF INSTANT CASE ARE IN PARI-MATERIA, RESPECTFULLY F OLLOWING THE ORDER OF THE COORDINATE BENCH, WE CANCEL THE ORDER PASSED BY THE DIT (EXEMPTION) U/S ITA-3267 & 3268/D/2008 7 12AA(1)(B) CANCELING THE REGISTRATION U/S 12A AND C ONSEQUENTIAL TO IT THE EXEMPTION GRANTED U/S 80-G OF THE IT ACT. 9. IN THE RESULT, BOTH THE APPEALS OF THE ASSESSEE ARE ALLOWED. DECISION PRONOUNCED IN THE OPEN COURT ON 23 RD OCTOBER, 2009. SD/- SD/- (D.R.SINGH) (R.C.SHARMA) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED : 23.10.2009. VK. COPY FORWARDED TO: - 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(A) 5. DR, ITAT DEPUTY REGISTRAR