RATAN LAL RANKA, Jaipur V. DCIT, Jaipur

ITA 332/JPR/2015

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 5270 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 1 month(s) 19 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-05-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Not Allotted
• Assessment Year: 2004-2005
• Appeal Filed On: 06-04-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: G R PAREEK
• Keywords: Unexplained investment; Search and seizure; Opportunity of being heard; Revised return
• Section: 143(3); 133A; 153A; 69

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 VKJ-IH-RKSYKUH] U;KF;D LNL; ,OA JH VH-VKJ-EHUK] YS[KK LNL; DS LE{K BEFORE: SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM VK;DJ VIHY LA- @ ITA NO. 332/JP/2015 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2004-05 RATAN LAL RANKA, 590, ADARSH NAGAR, JAIPUR. CUKE VS. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ L A-@ PAN/GIR NO.: ABUPR 1583 L VIHYKFKHZ @ APPELLANT IZR;FKHZ @ RESPONDENT FU/KZKFJRH DH VKSJ LS @ ASSESSEE BY : SHRI GULSHAN AGARWAL (CA) & SHRI VIJAY GOYAL (CA) JKTLO DH VKSJ LS @ REVENUE BY : SHRI G.R. PAREEK (JCIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 17/05/2016 MN?KKS'K .KK DH RKJH[ K @ DATE OF PRONOUNCEMENT : 25/05/2016 VKNS'K @ ORDER PER: T.R. MEENA, AM THIS IS AN APPEAL FILED BY THE APPELLANT AGAINST TH E ORDER DATED 25/02/2015 PASSED BY THE LEARNED CIT (A), ALWAR FOR A.Y. 2004-05, IN WHICH THE ASSESSEE HAS RAISED SOLE GROUND AS UNDER:- 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CA SE AND IN LAW THE LD CIT(A) ERRED IN CONFIRMING THE IMPOSITI ON OF PENALTY OF RS. 72,599/- U/S 271(1)(C) OF THE INC OME TAX ACT, 1961. ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 2 2. THE SOLE GROUND OF THE ASSESSEES APPEAL IS AGAIN ST CONFIRMING THE PENALTY U/S 271(1)(C) OF THE INCOME TAX ACT, 1961 (I N SHORT THE ACT) AT RS. 72,599/-. A SEARCH AND SEIZURE ACTION U/S 132(1 ) AND SURVEY U/S 133A OF THE ACT WERE CARRIED OUT ON 24/8/2006 AT THE RESI DENCE AND BUSINESS PREMISES OF THE ASSESSEE GROUP OF CASES OF JAIPUR. THE ASSESSEES CASE WAS SCRUTINIZED U/S 153A READ WITH SECTION 143(3) OF THE ACT. THE ASSESSEE FILED RETURN ON 31/10/2006 IN RESPONSE TO NOTICE U/S 153A OF THE ACT AT RS. 31,40,899/-. THE LD ASSESSING OFFICER OB SERVED THAT IN ASSESSMENT ORDER THAT THE ASSESSEE HAD PURCHASED PL OT NO. 23 IN GREEN AVENUE NAGAR, JAIPUR (ANNEXURE-A-53, SEIZED FROM 59 0 ADARSH NAGAR, JAIPUR) FOR RS. 2.20 LACS ON 14/10/2003. IT WAS SUBM ITTED DURING THE ASSESSMENT PROCEEDINGS BY THE ASSESSEE THAT THIS PL OT WAS PURCHASED ON 14/10/2003 THROUGH A BROKER. THE PAYMENT OF RS. 1.50 LACS WAS MADE ON 31/3/2003 AND BALANCE RS. 70,000/- WAS PAID IN F.Y. 2004-05. SINCE THE ASSESSEE HAS NO EVIDENCE IN SUPPORT OF OUTSTANDING AMOUNT OF RS. 70,000/-, THEREFORE, SAME WAS SURRENDERED BY THE ASS ESSEE IN REVISED RETURN FILED ON 23/1/2008. AS PER AGREEMENT, THE PL OT WAS PURCHASED FROM SHRI DINESH CHAND SHARMA FOR RS. 2.15 LACS ON 14/10 /2003. THERE IS NO MENTION OF DATE OF PAYMENT IN THE AGREEMENT DEED/PA TTA. THE ASSESSEE SURRENDERED RS. 70,000/- IN REVISED RETURN FILED ON 23/1/2008 BUT REMAINING AMOUNT OF RS. 1.50 LACS HAD NOT BEEN EXPL AINED WITH EVIDENCE, ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 3 THEREFORE, THE LD ASSESSING OFFICER MADE ADDITION U /S 69 OF THE ACT. THE PENALTY U/S 271(1)(C) FOR FURNISHING OF WRONG PARTIC ULARS AND CONCEALMENT OF RS. 2.20 LACS WAS INITIATED. THIS ADDITION WAS CONF IRMED BY THE LD CIT(A) IN QUANTUM ADDITION. 2.1 BEFORE IMPOSING PENALTY U/S 271(1)(C), THE LD A SSESSING OFFICER GAVE REASONABLE OPPORTUNITY OF BEING HEARD TO THE A SSESSEE. THE ASSESSEE ALSO AVAILED THE OPPORTUNITY VIDE LETTER DATED 15/3 /2011. THE ASSESSEES REPLY HAS BEEN REPRODUCED ON PAGE NO. 2 OF THE PENA LTY ORDER. AFTER CONSIDERING THE ASSESSEES REPLY AND PROVISIONS OF SECTION 271(1)(C) OF THE ACT, THE LD ASSESSING OFFICER HELD THAT IT IS A CLE AR CUT CASE HAD BEEN MADE AGAINST THE ASSESSEE FOR CONCEALMENT OF INCOME AND/ OR FURNISHING OF INACCURATE PARTICULARS OF INCOME FOR THE REASONS DE TAILED IN THE ASSESSMENT ORDER ON THE BASIS OF WHICH THE LD CIT(A)( CENTRAL), JAIPUR HAD ALSO CONFIRMED THE ADDITION. THE ONUS ON THE ASSESSE E TO PROVE THAT THERE WAS NO CONCEALMENT AND/OR FURNISHING OF INACCURATE P ARTICULARS OF INCOME. HOWEVER, IN THE SUBMISSION, THE ASSESSEE HAD NOT BRO UGHT ANY NEW EVIDENCE NOR HAS THE ASSESSEE PUT FORTH ANY NEW ARGU MENT WHEREBY THE ONUS CAST UPON IT IN RESPECT OF ITS INNOCENCE AND R IGHTEOUS CONDUCT IS ESTABLISHED. THE ASSESSEE HAD BEEN UNABLE TO PROVE H IS INNOCENCE WITH EVIDENCE AS REGARDS THE ADDITION SUSTAINED BY THE L D CIT(A). THE CASE LAW RELIED UPON BY THE ASSESSEE ARE NOT SQUARELY APPLIC ABLE ON THE FACTS AND ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 4 CIRCUMSTANCES OF THE CASE. HE FURTHER RELIED ON THE DECISION OF HON'BLE SUPREME COURT IN THE CASE OF UNION OF INDIA VS DHAR MENDRA TEXTILES PROCESSORS 295 ITR 244 (SC) WHEREIN IT HAS BEEN HELD THAT PENALTY U/S 271(1)(C) OF THE ACT IS A CIVIL LIABILITY AND THE WI LLFUL CONCEALMENT IS NOT AN ESSENTIAL INGREDIENT FOR ATTRACTING CIVIL LIABILITY . THEREFORE, HE IMPOSED PENALTY BY OBSERVING THAT THE ASSESSEE HAD FURNISHE D INACCURATE AND/OR CONCEALED PARTICULARS OF INCOME TO THE EXTENT OF AD DITION CONFIRMED BY THE LD CIT(A) AT RS. 1.50 LACS. ACCORDINGLY, HE IMPOSED 100% PENALTY AT RS. 72,599/- OF TAX SOUGHT TO BE EVADED ON CONCEALED IN COME. 3. BEING AGGRIEVED BY THE ORDER OF THE ASSESSING OF FICER, THE ASSESSEE CARRIED THE MATTER BEFORE THE LD CIT(A), WHO HAD CON FIRMED THE PENALTY BY OBSERVING THAT PENALTY IMPOSED BY THE LD ASSESSING OFFICER ON THE BASIS OF INCRIMINATING DOCUMENTS FOUND IN THE COURSE OF SEAR CH REGARDING UNEXPLAINED INVESTMENT IN PLOT FOR WHICH NO SATISFA CTORY EXPLANATION COULD BE FURNISHED BY THE APPELLANT. THE ASSESSEES SUBMIS SIONS WAS THAT A PAYMENT OF RS. 1.50 LACS TO A BROKER FOR PURCHASE O F PLOT, WHICH WAS BY MISTAKE DEBITED TO PLOT NO. 18, AJMER ROAD, JAIPUR IN PLACE OF ADVANCE AGAINST PLOT. DUE TO CERTAIN REASONS THE DEAL FOR T HE PLOT AT GREEN AVENUE COULD NOT BE FINALIZED IN A.Y. 2003-04 AND THE AMOU NT WAS LYING WITH THE BROKER. THE BROKER PURCHASED PLOT NO. C-23, GREEN AV ENUE NAGAR, JAIPUR ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 5 FOR RS. 2.20 LACS ON 14/10/2003 AND UTILIZED ADVANC E OF RS. 1.50 LACS GIVEN IN A.Y. 2003-04 AND BALANCE RS. 70,000/- WERE PAID BY BROKER WHICH WAS PAID BY ASSESSEE TO BROKER IN A.Y. 2005-06. SINC E THE ASSESSEE WAS NOT HAVING EVIDENCE IN SUPPORT OF PAYMENT OF OUTSTA NDING OF RS. 70,000/- AGAINST THIS PLOT IN A.Y. 2004-05, THEREFORE, THE S AME WAS SURRENDERED AS INCOME IN REVISED RETURN FILED ON 23/01/2008. HE FU RTHER HELD THAT THE ASSESSEE FAILED TO FURNISH ANY EVIDENCE EITHER AT T HE STAGE OF ASSESSMENT OR IN THE COURSE OF APPELLATE PROCEEDINGS TO SUBSTA NTIATE THE SEQUENCE OF EVENTS STATED ABOVE. AS NO DOCUMENTARY EVIDENCE COU LD BE SUBMITTED BY THE ASSESSEE REGARDING THE PAYMENT OF RS. 1.50 LACS GIVEN TO BROKER FOR PURCHASES OF PLOT IN F.Y. 2002-03. THE ADDITION IN THE INCOME OF THE ASSESSEE WAS NOT ON ACCOUNT OF VOLUNTARY DISCLOSURE BY THE APPELLANT BUT BECAUSE OF THE COMPULSION ON ACCOUNT OF EVIDENCE IN POSSESSION OF THE INCOME TAX DEPARTMENT. THE APPELLATE CHOSE TO ACCEPT THIS ADDITIONAL INCOME AFTER HAVING BEEN CORNERED BY THE A.O. IN TH E ASSESSEES CASE, EXPLANATION-5 TO SECTION 271(1)(C) OF THE ACT IS AP PLICABLE. THE CASE LAWS CITED BY THE ASSESSEE ARE FOUND DISTINGUISHABLE. HE FURTHER RELIED ON THE DECISION IN THE CASE OF MAK DATA PVT. LTD. VS CIT 35 8 ITR 593 (SC) WHEREIN IT HAS BEEN HELD THAT IF AMOUNT SURRENDERED IN SURVEY IS TO BUY PEACE OF MIND. PENALTY HELD TO BE VALIDLY LEVIED. H E ALSO RELIED VARIOUS CASES AND FINALLY CONFIRMED THE PENALTY IMPOSED BY THE ASSESSING OFFICER. ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 6 4. NOW THE ASSESSEE IS IN APPEAL BEFORE US. THE LD AR OF THE ASSESSEE HAS SUBMITTED THAT THE ASSESSEE HAD FURNISHED EXPLA NATION DURING THE COURSE OF QUANTUM ADDITION AS WELL AS PENALTY PROCEE DINGS THAT RS. 1.50 LACS WERE PAID TO BROKER FOR PURCHASE FOR PLOT IN A. Y. 2003-04, WHICH WAS WRONGLY DEBITED TO PLOT NO. 18, AJMER ROAD, JAIPUR I N PLACE OF ADVANCE AGAINST THE PLOT. PLOT NO. 18 AJMER ROAD, JAIPUR WAS PURCHASED ON 06/4/1995 FOR RS. 1.50 LACS AND THERE IS NO DISPUTE OVER THIS ISSUE. THE PLOT NO. 18, AJMER ROAD, JAIPUR WAS NOT PURCHASED IN A.Y. 2003-04 BUT DEAL FOR THE PLOT AT GREEN AVENUE NAGAR, JAIPUR COU LD NOT BE FINALIZED IN A.Y. 2003-04 AND THE AMOUNT WAS LYING WITH THE BROKER . IN A.Y. 2004-05 ON 14/10/2003, THE BROKER PURCHASED PLOT NO. C-23, GREEN AVENUE NAGAR, JAIPUR FOR RS. 2.20 LACS AND UTILIZED ADVANCE OF RS . 1.50 LACS GIVEN IN A.Y. 2003-04 AND BALANCE AMOUNT OF RS. 70,000/- WAS PAID IN A.Y. 2005-06. SINCE THE ASSESSEE WAS NOT HAVING ANY EVIDENCE IN S UPPORT OF PAYMENT OF OUTSTANDING OF RS. 70,000/- AGAINST THIS PLOT IN A. Y. 2004-05. THEREFORE, THE SAME WAS SURRENDERED AS AN ADDITIONAL INCOME IN REVISED RETURN FILED ON 23/1/2008. THIS EXPLANATION WAS NOT FOUND CONVINC ING TO THE ASSESSING OFFICER IN QUANTUM AS WELL AS PENALTY PROCEEDINGS. TH E LD ASSESSING OFFICER HAS IMPOSED PENALTY U/S 271(1)(C) OF THE AC T ON THE BASIS OF FINDING GIVEN IN QUANTUM PROCEEDINGS AND NO EVIDENC E HAS BEEN ADDUCED DURING THE COURSE OF PENALTY PROCEEDINGS THAT THE A SSESSEE HAS FURNISHED ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 7 INACCURATE PARTICULARS OF INCOME AND CONCEALED THE INCOME. THE QUANTUM PROCEEDINGS ARE NOT BINDING ON PENALTY PROCEEDINGS. THERE MUST BE INDEPENDENT FINDING IN PENALTY ORDER AS HELD BY THE HONBLE CALCUTTA HIGH COURT IN THE CASE OF DURGA KAMAL RICE MILLS VS. CIT (2004) 265 ITR 25 (CAL.). DURING THE COURSE OF SEARCH, NO INCRIMINATI NG DOCUMENTS WERE FOUND THAT THE ASSESSEE HAD PAID THIS AMOUNT OUT OF UNDISCLOSED INCOME. THE ASSESSEES EXPLANATION WAS NOT FOUND FALSE AND HA D NOT DISPROVED BY THE ASSESSING OFFICER BY MERELY REJECTION OF SUBMIS SION OF THE ASSESSEE, NO PENALTY CAN BE IMPOSED U/S 271(1)(C) OF THE ACT. THE PRESUMPTION GIVEN UNDER THE LAW FOR ADDITION U/S 69 IS NOT AVAIL ABLE FOR IMPOSING PENALTY U/S 271(1)(C) OF THE ACT. THE ASSESSEE HAS E XPLAINED THE SOURCE OF INVESTMENT. HE FURTHER ARGUED THAT THERE IS NO WI LLFUL CONSCIOUS DEFAULT ON THE PART OF THE ASSESSEE. IT IS A TECHNICAL NATU RE AND PENALTY COULD NOT BE IMPOSED ON THIS FAULT BY THE ASSESSING OFFICER A S HELD BY THE HONBLE RAJASTHAN HIGH COURT IN THE CASE OF SHIV LAL TAK VS CIT (2001) 251 ITR 373 (RAJ) AND CIT VS HARSHVARDHAN CHEMICALS & MINERA LS LTD. (2003) 133 TAXMAN 320 (RAJ). EVEN IN DEBATABLE ISSUE, NO PENALT Y CAN BE IMPOSED AS HELD BY THE HON'BLE CALCUTTA HIGH COURT IN THE CAS E OF DURGA KAMAL RICE MILLS VS. CIT (SUPRA). HE FURTHER RELIED ON THE DECI SION IN THE CASE OF CIT VS RELIANCE PETROPRODUCTS (P) LTD. 322 ITR 158 (SC) WHEREIN DETAILS ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 8 SUPPLIED BY THE ASSESSEE HAD NOT ERRONEOUS, INCORRE CT OR FALSE, THEREFORE, HE PRAYED TO DELETE THE PENALTY CONFIRMED BY THE LD CIT(A). 5. AT THE OUTSET, THE LD DR HAS VEHEMENTLY SUPPORTE D THE ORDER OF THE LD CIT(A). 6. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON THE RECORD. THERE WAS A SEA RCH SEIZURE OPERATION AT THE RESIDENCE AND SURVEY AT THE BUSINESS PREMISE S OF THE ASSESSEE ON 24/8/2006. THE ORIGINAL RETURN FILED BY THE ASSESSEE U/S 139(1) AT RS. 1,90,899/- ON 30/3/2005. IN RESPONSE TO NOTICE U/S 153A, RETURN WAS FILED AT RS. 31,40,899/- ON 31/10/2006.THE SAME WAS REVISED BY INCLUDING ADDITIONAL INCOME OF RS. 70,000/-, AT RS. 32,10,899 /- ON 23/1/2008. IT IS A FACT THAT THE ASSESSEE HAS EXPLANATION ABOUT THE RE MAINING INVESTMENT MADE IN PLOT NO. 23, GREEN AVENUE NAGAR, JAIPUR, WHI CH IS EVIDENT FROM THE REVISED RETURN ACCEPTED BY THE ASSESSEE BUT THE ASSESSEE COULD NOT SUBSTANTIATE THAT THIS AMOUNT WAS DEBITED IN THE ACC OUNT OF PURCHASE OF PLOT NO. 18, AJMER ROAD, JAIPUR. THE PURCHASE AMOUNT WAS IDENTICAL I.E. RS. 1.50 LACS. THE ASSESSEES SUBMISSION SINCE START ING WAS THAT HE HAD PAID RS. 1.50 LACS TO BROKER IN A.Y. 2003-04 BUT TR ANSACTION COULD NOT BE MATERIALIZED BUT FINALIZED IN A.Y. 2004-05. EVEN TH E ASSESSEE HAS SHOWN THIS PAYMENT OF RS. 70,000/- IN A.Y. 2005-06 WHEREAS IT HAS BEEN TAKEN ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 9 BY THE ASSESSEE IN REVISED RETURN IN A.Y. 2004-05 I .E. YEAR UNDER CONSIDERATION. THE AMOUNT BEING SMALL, THE ASSESSEE HAS NOT CONTESTED SERIOUSLY IN THE QUANTUM PROCEEDINGS AND DECIDED TO PAY TAX ON IT BUT THE ASSESSEE HAD EXPLANATION ABOUT THE INVESTMENTS MADE IN PURCHASE OF PLOT NO. 23 IN GREEN AVENUE NAGAR, JAIPUR. THE LD ASSESS ING OFFICER AS WELL AS LD CIT(A) HAS SIMPLY MENTIONED THAT THERE WAS AN AGRE EMENT OF PLOT WAS PURCHASED FROM SHRI DINESH CHAND SHARMA FOR RS.2.15 LACS ON 14/10/2003 BUT THERE IS NO MENTION OF DATE OF PAYMENT IN THE A GREEMENT DEED/PATTA. IT IS CLEAR FROM THE DOCUMENTS FOUND DURING THE COU RSE OF SEARCH THAT THESE PAYMENTS WERE NOT SPECIFIC WITH REFERENCE TO DA TE OF PAYMENT. THEREFORE, WE HAVE CONSIDERED VIEW THAT THE ADDITION O F RS. 1.50 LACS MADE BY THE ASSESSING OFFICER IN QUANTUM PROCEEDING S IS REASONABLE BUT FOR IMPOSING PENALTY, THE LD ASSESSING OFFICER HAS TO GIVE REASONS THAT THIS INVESTMENT WAS ASSESSEES UNDISCLOSED INCOME EARNED DURING THE YEAR. THERE IS NO MATERIAL WITH THE ASSESSING OFFICER EXCEP T COPY OF AGREEMENT WITH SHRI DINESH CHAND SHARMA FOR RS. 2.15 LACS DATE D 14/10/2003. WE AFTER CONSIDERING THE FACTS AND CIRCUMSTANCES OF TH E CASE HAVE CONSIDERED VIEW THAT WITHOUT ANY SPECIFIC FINDING IN THE PENALTY ORDER, NO PENALTY CAN BE IMPOSED U/S 271(1)(C) AS THE LD ASSESSING OFFICE R HAS IMPOSED PENALTY ON THE BASIS OF QUANTUM ADDITION. FURTHER IT HAS AL SO NOT BEEN HELD IN THE PENALTY ORDER THAT THE ASSESSING OFFICER HAS IMPOSE D THIS PENALTY FOR ITA 332/JP/2015_ RATAN LAL RANKA VS DCIT 10 FURNISHING INACCURATE PARTICULARS OF INCOME OR CONC EALMENT OF INCOME AS CONCLUDED BY THE ASSESSING OFFICER IN THE PENALTY O RDER THAT THE ASSESSEE HAD FURNISHED INACCURATE AND/OR CONCEALED PARTICULA RS OF INCOME TO THE EXTENT OF ADDITION SUSTAINED BY THE LD CIT(A)(CENTRA L), JAIPUR FOR RS. 1.50 LACS. ACCORDINGLY, WE DELETE THE PENALTY CONFIRMED BY THE LD CIT(A). 7. IN THE RESULT, THE ASSESSEES APPEAL IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 25/5/2016. SD/- SD/- VKJ-IH-RKSYKUH VH-VKJ-EHUK (R.P.TOLANI) (T.R. MEENA) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ @ JAIPUR FNUKAD @ DATED:- 25 TH MAY, 2015 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- SHRI RATAN LAL RANKA, JAIPUR. 2. IZR;FKHZ @ THE RESPONDENT- THE DCIT, CENTRAL CIRCLE-2, JAIPUR. 3. VK;DJ VK;QDR @ CIT 4. VK;DJ VK;QDR @ CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ @ DR, ITAT, JAIPUR 6. XKMZ QKBZY @ GUARD FILE (ITA NO. 332/JP/2015) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR