P.MADHEWARAN, NAMAKKAL V. ACIT CIRCLE-1, NAMAKKAL

ITA 3365/CHNY/2019

• Counselvise Citation: [2022] 106 COUNSELVISE.COM (IT) 3135 (ITAT-CHENNAI)
• Duration Of Justice: 2 year(s) 8 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-08-2022
• Appeal Filed By: Assessee
• Order Result: PartlyAllowed
• Bench Allotted: C
• Assessment Year: 2013-2014
• Appeal Filed On: 15-12-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Business income; Revision of order; Depreciation; Opportunity of being heard; Question of law; Revised return; Unabsorbed depreciation; Set aside
• Section: 32; 28; 44AD; 274; 72; 119

Judgement Text

आयकर अपीलीय अिधकरण,‘सी’ ᭠यायपीठ, चे᳖ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI Įीमहावीर ͧसंह, उपाÚय¢ एवं डॉ दȣपक पी. ǐरपोटे, लेखा सदèय के सम¢ BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENTAND Dr. DIPAK P. RIPOTE, ACCOUNTANT MEMBER आयकर अपीलसं./ITA No.: 3365/CHNY/2019 िनधाᭅरण वषᭅ/Assessment Year: 2013-14 Shri P. Madheswaran, Prop: M/s. PMP Roadlines, No.M-38, Alagunagar, TNHB Colony, Trichy Road, Namakkal – 637 001. PAN: AEXPM 6512N vs. The ACIT, Circle – 1, Namakkal. (अपीलाथᱮ/Appellant) (ᮧ᭜यथᱮ/Respondent) अपीलाथᱮ कᳱ ओर से/Appellant by : Shri G. Baskar, Advocate ᮧ᭜यथᱮ कᳱ ओर से/Respondent by : Shri Sajit Kumar, JCIT स ु नवाई कȧ तारȣख/Date of Hearing : 23.08.2022 घोषणा कȧ तारȣख/Date of Pronouncement :26.08.2022 आदेश /O R D E R PER MAHAVIR SINGH, VICE PRESIDENT: This appeal by the assessee is arising out of the order of Commissioner of Income Tax (Appeals), Salem in ITA No.52/2018- 19 dated 23.10.2019. The assessment was framed by the ACIT, Circle-1, Namakkal for the assessment year 2013-14 u/s.143(3) 2 ITA No.3365/Chny/2019 r.w.s. 263 of the Income Tax Act, 1961 (hereinafter the ‘Act’) vide order dated 25.07.2018. 2. The only issue in this appeal of assessee is as regards to the order of CIT(A) assessing the net profit at 8% on the gross contract receipts and consequential allowance of depreciation of the current year and carried forward depreciation for earlier assessment years i.e A.Y. 2011-12 & 2012-13. For this, assessee has raised various grounds which need not be reproduced. 3. Brief facts are that the assessee is an individual deriving income from receipts on plying of hiring of lorry transport. The assessee filed his return of income on 28.03.2015 admitting total income of Rs.5,63,100/- for assessment year 2013-14. This return of income was e-processed u/s.143(1) of the Act and subsequently assessment was completed u/s.143(3) of the Act originally accepting the net profit estimated from lorry transport business by the assessee at 7.2% as against declare by the assessee at 7.0%. The AO in the original assessment also allowed depreciation including carry forward depreciation. The AO also added some discrepancies of the business receipts at Rs.2,70,936/- and thereby assessed the income at Rs.8,34,040/-. Subsequently, the PCIT, 3 ITA No.3365/Chny/2019 Salem revised the assessment u/s.263 of the Act vide C.No.9544(25)/2017-18/PCIT/SLM dated 21.03.2018 by noting that the assessee has not maintained any books of accounts and net profit should have been added at net of 8% of the gross receipts and even the current depreciation and brought forward depreciation from assessment year 2011-12 and 2012-13 should not have been allowed as the same has not been claimed in the original return of income in view of the decision of Hon’ble Supreme Court in the case of Goetze India Ltd., 284 ITR 323(SC). With these observations, the PCIT directed the AO to reframe the assessment by observing in para 5 as under:- “5. It is seen that the issues discussed above were not considered by the Assessing Officer during the course of assessment proceedings. Therefore, the assessment order passed on 19.01.2016 is set aside u/s 263 of the IT Act, 1961 and the Assessing Officer is directed to complete the assessment afresh in accordance with law and after giving the assessee reasonable opportunity of being heard.” 3.1 Consequent to this, the AO framed the impugned assessment order and by taking the intent of provisions of section 44AD of the Act, assessed the net profit rate at the rate of 8% of the gross contract receipts without allowing depreciation whether current depreciation or carry forward depreciation by observing as under:- “In the present case, the intent of legislation behind the applicability of the section 44AD has to be taken into consideration. The assessee did not 4 ITA No.3365/Chny/2019 maintain his books of account, as was expected of him in the normal course of business. It was failure on his part. In the absence of books of accounts, even the small assessees are supposed to declare a sum equal to 8% of the total or gross receipts in the previous year or, as the case maybe, a sum higher than the aforesaid sum claimed to have been earned by the assessee as their profit and gains chargeable under the head “profits and gains to business and profession”. Estimating the net profit at a rate of 8% in the present case would only mean appropriating the intent of law as laid down by the IT Act, 1961; by applying the same assumptions and not applying the section itself. Hence, the applicability of section 44AD is not relevant for the purpose of this order. 3.2 For disallowing the claim of depreciation, the AO concluded as under:- “In the absence of actual data, the assessee has failed to address the onus on him to perform the duty under the provisions of the Act. The assessing officer hence, has full authority under provisions of law to arrive at a reasonable assumption for the calculation of the due tax to be paid by the assessee. The intention laid down by the legislation under the Income Tax Act, 1961, is being hereby extended to this case and Net Profit at the rate of 8% of the gross receipts after deeming that depreciation has been given full effect is being calculated for the purpose of calculation of the tax liability.” Aggrieved, assessee preferred appeal before the CIT(A). 4. The CIT(A) confirmed the application of profit rate of 8% on the gross receipts and also confirmed the action of the AO in not considering the claim of depreciation of current year and the claim of set off of unabsorbed depreciation brought forward in earlier years by observing in para 8.3 to 9.1 as under:- 5 ITA No.3365/Chny/2019 “8.3 As it can be seen clearly from the provisions of Section 44AD(2), the assessee’s argument that depreciation should be allowed cannot be considered. Hence, this ground of appeal is dismissed. The assessee has relied o the Hon’ble Madras High Court decision in the case of K. Kannan vs. ACIT (220Taxman 250) [2014] in support of his argument that 44 AD should have not been invoked. The Assessing Officer also contended that the assessee relied on various case laws of other Tribunals and High Courts which were also considered by him before making the Assessment Order. The Assessing Officer contended that as the only issue in the assessee's case is of non-maintenance of books of account, the net profit should have been adopted at 8% of the gross receipts. The Assessing Officer also pointed out to the assessee's reliance in the case of Goetze India Ltd (284 ITR 323 (SC) wherein it is. held that filing of revised return is mandatory for making any fresh claims. The Assessing Officer also stated all deductions/expenditures are deemed to have been allowed when income is computed on estimate basis and no further deductions shall be allowed. Having considered all the details before me, I do not find any valid reason to interfere with the order of the Assessing Officer in adopting the business income of the appellant at 8% of gross receipts. Therefore, the action of the Assessing Officer in respect of this ground is upheld. The facts of the case being very different from the case laws relied on by the assessee, the arguments of the assessee cannot be considered. Therefore ground numbers 2 and 3 are dismissed. 9. Ground No.4: Set off of unabsorbed depreciation loss brought forward from earlier years. 9.1. As regards the allowance of depreciation, the appellant argued that from Asst. Year 2002-03, it has been made mandatory to allow depreciation to an assessee even though not claimed deduction in respect of depreciation. From the returns of income for the Asst. Years 2012-13 and 2013-14, it is seen that both the returns were filed well beyond the specified time limit for filing of returns of income for the respective Asst. Years. Therefore, the Assessing Officer has rightly rejected the claims made by the appelant for allowance of depreciation and set off of brought forward loss of earlier years. The arguments of the appellant does not hold water. Therefore, I do not find any valid reason to interfere with the findings of the Assessing Officer in the assessment order. Hence, this ground of appeal is dismissed. Aggrieved, assessee is in appeal before the Tribunal. 6 ITA No.3365/Chny/2019 5. We have heard rival contentions and gone through the facts and circumstances of the case. The undisputed facts are that the assessee is an individual and engaged in the business of transport by plying of lorry. The assessee has gross receipts during the financial year 2012-13 relevant to this assessment year 2013-14 amounting to Rs.13,54,68,125/-. The assessee has disclosed profit rate in his return of income on these gross contract receipts at Rs.5,63,100/- and the net profit rate comes to 7%, as noted by the AO in original assessment order, based on average profit rate of 10.53% admitted for many assessment years. The assessee has filed a comparative chart of net profit and net profit rate before depreciation and net profit rate after depreciation, which reads as under:- Asst Year Sales Net Profit NP before Depn (%) Depn NP after Depn 2011-12 9,33,29,597 49,60,691 11.25 (1,17,13,548) (-)(1.05) 2012-13 8,16,36,491 (28,13,120) 1.05 (44,06,457) (-) 2.97 2013-14 13,54,68,125 4,25,000 3.57 (44,08,927) 0.31 2014-15 * 8,25,000 * * * 2015-16 14,41,71,379 14,56,265 10.14 (1,31,59,009) 1.05 2016-17 1,27,94,190 7,42,172 13.02 (9,24,002) 5.80 * Data not available The assessee also made claim of current depreciation and set off of unabsorbed loss brought forward from earlier years. 7 ITA No.3365/Chny/2019 6. Before us, the ld.counsel for the assessee Shri G. Baskar made four propositions and argued the matter on four propositions. On the other hand, the ld. Senior DR Shri P. Sajit Kumar heavily relied on the assessment order and the order of CIT(A) and stated that once books of accounts are not produced by the assessee or not maintained, the AO has rightly applied profit rate at 8% and he has not applied or invoked the provisions of section 44AD of the Act but normally when profit is estimated in the case of contractors or plying of lorry business, the profit rate applied on gross receipts is 8%. The ld.Senior DR stated that once books of accounts are not maintained, the Revenue is not obliged to allow the claim of depreciation and the authorities below have rightly rejected the claim of allowance of depreciation because in the profit rate of 8%, the expenditure or allowances all are deemed allowances and no further allowance can be made. 6.1 As regards to set-off of unabsorbed depreciation loss brought forward from earlier years i.e., assessment year 2011-12 & 2012- 13, the ld. Senior DR stated that the returns were filed beyond the specified time limit for filing of return of income of the respective assessment years and once the returns filed are belated returns, the loss is automatically not allowed. 8 ITA No.3365/Chny/2019 7. The first proposition raised by ld.counsel is that the provisions of section 44AD of the Act will not apply to the present case and for this, he stated that the provisions of section 44AD of the Act applies where gross receipt is one crore or less in the business of contractor or plying of lorries. Hence, he stated that the provision will not apply to the assessee’s case. For this, he relied on the decision of Hon’ble Madras High Court in the case of K. Kannan vs. ACIT, [2013] 39 taxmann.com 10, wherein the Hon’ble Madras High Court has categorically held that wherever the gross receipts are exceeding Rs.1 crore or in excess of amount prescribed at the relevant point of time, the provisions of section 44AD of the Act will not apply. For this relied on para 6 of the judgment of Hon’ble Madras High Court, which reads as under:- 6. A reading of Section 44 AD of the Income Tax Act, 1961 shows that notwithstanding anything to the contrary contained in Sections 28 to 43C, in the case of eligible assessee having business with a gross receipts not exceeding Rs.40 lakhs, the assessee would be assesed on a presumptive basis, to be taxed at 8% on the total turnover gross receipts in the previous year on account of such business or as the case may be a sum higher than the aforesaid sum claimed to have been earned by the eligible amount under the head "profit and gain of the business or profession". Sub Section (2) states that any deduction allowable under the provisions of Sections 30 to 38, shall, for the purpose of Sub Section (1), be deemed to have been already given full effect to and no further deduction would be allowed under those Sections. In other words, considering the percentage of liability fixed as income on the eligible assessees who are defined under clause (a) Explanation and eligible business defined under Clause (b) Explanation, so long as the gross turnover does not exceed Rs.40 lakhs, the income would be assessed at the specified percentage of the gross turnover. There is no 9 ITA No.3365/Chny/2019 denial of the fact, as is evident from the order of assessment that the assessee's gross contract receipt was Rs.4,02,10,611/- for the assessment year 2006-2007 and Rs.5,34,96,995/- for the assessment year 2007-2008, which means, Section 44 AD of the Act has no relevance. 7.1 When the above proposition was confronted to ld. Senior DR, he could not controvert the above fact situation but only stated that the AO has not applied the provisions of section 44AD of the Act but when his contentions are drawn to the order of CIT(A) that CIT(A) simply applied the provisions of section 44AD(2) of the Act, as noted in para 8.3 of the CIT(A)’s order, which is reproduced in this order at para 4. 7.2 In view of the above facts and circumstances, we are of the view that this issue is covered against Revenue and in favour of assessee by the decision of Hon’ble Madras High Court in the case of K. Kannan, supra and the fact that in the present case, the amount prescribed in the provisions of section 44AD of the Act for this year is Rs.1 crore, whereas gross receipts of assessee being Rs.13,54,68,125/- , which is more than the prescribed limit. Hence, the lower authorities have wrongly taken cognizance of section 44AD of the Act for applying the profit rate. Hence, this proposition will decide in favour of assessee. 10 ITA No.3365/Chny/2019 8. The second proposition argued by ld.counsel for the assessee that the profit rate declared by assessee in the original assessment at 7% and subsequently assessed by the AO at 7.2% is acceptable to the assessee in the absence of books of accounts. The ld.counsel stated that instead of 8%, profit rate should be assessed at 7.2% as assessed by the AO because the assessee has already filed comparative profit rate of earlier years and future years because there cannot be a constant net profit and he drew our attention to the chart filed by him, which is reproduced in above para 5 of this order. The ld. Senior DR could not state much on the applicability of profit rate but only argued that the CIT(A) has rightly upheld the applicability of net profit rate at 8%. 8.1 We have gone through the profit rate adopted by the AO in assessee’s own case in earlier years and future years and noted from the above chart that profit rate varies from 1.05% to 13.02% i.e., profit before depreciation and in this year, the AO in the original assessment has accepted the profit rate at 7.2% and made assessment which was subject matter of revision before PCIT and the AO applied profit rate at 8% in consequence to the order giving effect to revision order passed by PCIT u/s.263 of the Act. In our view, the profit rate accepted by assessee as applied by the AO 11 ITA No.3365/Chny/2019 originally at 7.2% seems to be genuine and reasonable and we upheld the same. The AO is directed to recompute the net profit by applying profit rate at 7.2% of the gross receipts. We direct the AO accordingly. 9. Coming to third proposition of the assessee that after application of profit rate, even though the assessee has not maintained books of accounts, depreciation is to be allowed to the assessee. For this, the ld.counsel for the assessee relied on the following case laws:- (i) High Court of Allahabad in Saraya Engg. Works (P.) Ltd., vs CIT, [1987] 31 Taxman 165 (ii) High Court of Allahabad in CIT vs. Bishambhar Dayal & Co., [1994] 74 Taxman 123 (iii) High Court of Rajasthan in CIT vs. Jain Construction Co., [2000] 110 Taxman 156 (iv) High Court of Punjab & Haryana in CIT vs. Chopra Bros (P) Ltd., [2001] 119 Taxman 866 (v) High Court of Rajasthan in CIT vs. Bhawan va Path Nirman (Bohra) & Co., [2003] 130 Taxman 361 The ld.counsel also relied on the decision of Hon’ble High Court of Madras in the case of K.Kannan, supra wherein Hon’ble High Court has considered applicability of profit rate at 5% of the gross contract receipts. Even the Hon’ble High Court of Rajasthan in the case of Jain Construction Co., supra, has considered an identical issue by 12 ITA No.3365/Chny/2019 considering the Circular issued by CBDT dated 31.08.1965 and allowed the claim of depreciation by considering even the provisions of section 44AD of the Act by observing in para 11 & 12 as under:- 11. It will also be relevant to consider section 44AD, which is a special provision for computing profits and gains of business of civil construction, etc. This provision has been inserted by the Finance Act of 1994 with effect from 1-4-1994. The provision does not have a direct bearing on the controversy involved in the instant case as it pertains to assessment year 1993-94 but it required to be dealt with as it has been referred by the learned counsel for the revenue. Now in case of assessee engaged in business of civil construction or supply of labour for civil construction fixed rate of net profit of 8 per cent has been provided. Proviso to sub-section (2) permits salary and interest paid to the partners deducted from the fixed net profit of 8 per cent subject to the conditions and limits specified in clause (b) of section 40. Thus, there is further simplication and certainty in computation of income. Instructions contained in para 2 of the circular of the year 1965 have been brought in the statute, thereby the doubts, if any, with respect to subject circular have been settled. 12. The Division Bench of this court in CIT v. S.M. Bhatia Associates (1998) 226 ITR 675 (Raj) has held that finding recorded by the Tribunal on appreciation of evidence available on record, is a finding of fact and does not give rise to the question of law for reference under section 256(2) of the Act, and thereby rejected the applications seeking reference of similar questions. In the instant cases, the Tribunal while allowing the appeal has directed the assessing authority to recompute the total income as estimated by him and allow relief on account of payment of interest and claim of depreciation. The finding recorded by the Tribunal is purely a finding of fact, based on proper appreciation of material on record and the evidence produced by the assessee. As no question of law arises out of the order passed by the Tribunal, we find no fault with the order of the Tribunal declining to refer the question for our opinion. 13 ITA No.3365/Chny/2019 9.1 Even this issue was considered by the Hon’ble Punjab & Haryana High Court in the case of Chopra Bros (P) Ltd., supra and held as under:- 15. The contention is untenable. A perusal of section 29 shows that the taxable income has to be computed after taking into consideration the provisions contained in sections 30 to 43. Under section 32, the assessee is entitled to claim depreciation. Under section 144, the Assessing Officer is bound to take into consideration the entire material on the record. Thus, in a case where the assessee makes a specific claim for depreciation and gives the information as required under section 32, the Assessing Officer is bound to take the claim of the assessee into consideration. This consideration of the material should be apparent from the order. There is no room for any assumption. 16. In this context, it deserves notice that with effect from 1-4-1994, the Parliament has made a special provision for computing profits and gains of business of civil construction, etc., by introducing section 44AD. It was, inter alia, provided that in case of an assessee engaged in the business of civil construction or supply of labour for that purpose, 'a sum equal to 8 per cent of the gross receipts paid or payable to the assessee in the previous year on account of such business. . . . shall be deemed to be the profits and gains...chargeable to tax...' In sub-section (2), it has been stipulated that 'any deduction allowable under the provisions of sections 30 to 38 shall, for the purposes of sub-section (1), be deemed to have been already given full effect to and no further deduction under those sections shall be allowed'. Thus, it is only with effect from 1-4-1994 that the Parliament has provided for a fictional assumption that the deduction shall be deemed to have been allowed. This provision clearly militates against the assumption sought to be raised by the counsel for the revenue in the present case. No other point was raised. 17. In view of the above, the question as noticed above, is answered in favour of the assessee. The majority view of the Tribunal is upheld. It is further held that in all cases (relating to the period prior to 1-4-1994) where best judgment assessment is made by fixing a rate of net profit, 14 ITA No.3365/Chny/2019 the assessee's claim for deduction on account of depreciation cannot be deemed to have been considered. It has to be separately taken into account provided the prescribed particulars have been furnished by the assessee. 9.2 We have also gone through the original assessment order and noted that the assessee has made claim of depreciation and the AO has gone into the details of depreciation and allowed depreciation because in the audited accounts(even though no books of account are produced or this is a case of no accounts), assessee has made claim of depreciation which was considered and allowed by the AO. We have considered the above legal proposition and the decisions cited before us of Hon’ble Rajasthan High Court in the case of Jain Construction Co., and the Hon’ble High Court of Punjab & Haryana in the case of Chopra Bros (P) Ltd., supra and are of the considered view that once the assessee’s books of accounts are not available or rejected by the AO, the AO has to estimate the profit rate and thereafter has to allow depreciation as claimed, after verifying the details. In the present case before us, the assessee has made claim and originally, the AO allowed the claim of depreciation that means, the details are available and therefore, we direct the AO to allow the same. This proposition is also allowed in favour of assessee. 15 ITA No.3365/Chny/2019 10. The next proposition argued by ld.Counsel for the assessee is as regards to carry forward of depreciation relevant to assessment years 2011-12 and 2012-13. The ld.counsel for the assessee stated that allowance of depreciation from assessment year 2002-03 is mandatory even though the assessee has claimed or not claimed in the return of income. As regards to the claim of depreciation i.e., carry forward depreciation, the ld.counsel for the assessee drew our attention to the provisions of section 32(2) of the Act and the relevant reads as under:- 32 (2) Where, in the assessment of the assessee, full effect cannot be given to any allowance under sub-section (1) in any previous year, owing to there being no profits or gains chargeable for that previous year, or owing to the profits or gains chargeable being less than the allowance, then, subject to the provisions of sub-section (2) of section 72 and sub- section (3) of section 73, the allowance or the part of the allowance to which effect has not been given, as the case may be, shall be added to the amount of the allowance for depreciation for the following previous year and deemed to be part of that allowance, or if there is no such allowance for that previous year, be deemed to be the allowance for that previous year, and so on for the succeeding previous years. In view of the above, the ld.counsel stated that unabsorbed depreciation of any year becomes part of depreciation of subsequent year by legal fiction and so on but when it becomes part of current year depreciation, it is liable to be set-off against any other income irrespective of the fact that the earlier returns were filed in time or not. He referred to the proposition laid down by the Hon’ble Delhi 16 ITA No.3365/Chny/2019 High Court in the case of CIT vs. Govind Nagar Sugar Ltd., 11 Taxmann.com 274 (Delhi). The ld.counsel drew our attention to para 16 of the judgment, which reads as under:- 16. We have already noted above that Section 32 deals with the different types of depreciation whereas Section 80 deals with carry forward of unabsorbed losses other than losses on account of depreciation. If that was not so, there was no need for legislature to provide specific provision for carrying forward of depreciation under Section 32 of the Act. It has already been noted that in case of Nagapatinam Import (supra), which was relied by our High Court in the case of J.Patel (supra) whereby, it was held that Section 72 contemplates loss other than unabsorbed depreciation and there was a time limit within which loss can be adjusted, whereas in the case of unabsorbed depreciation there is no time limit and further that under the statute there is a separate identity with respect to unabsorbed depreciation though at the time of computation, it becomes a part of loss. 17. From the above, it comes out that the effect of Section 32(2) is that unabsorbed depreciation of a year becomes part of depreciation of subsequent year by legal fiction and when it becomes part of current year depreciation it is liable to be set off against any other income, irrespective of the fact that the earlier years return was filed in time or not. The ld.counsel also relied on this proposition that unabsorbed depreciation although belated filing of return of income, it will not curtail the right of assessee to carry forward and claim the same. For this proposition, he relied on the decision of Hon’ble High Court of Karnataka in the case of Rajeshwari Cotton Ginning vs. ACIT, 88 taxmann.com 483. When these facts were confronted to ld. Senior DR, he could not controvert the same. 17 ITA No.3365/Chny/2019 10.1 After hearing rival contentions and going through the facts and legal position, we direct the AO to treat the unabsorbed depreciation as part of current year depreciation and the same is to be set-off against any other income. Hence, we direct the AO to verify the facts and then allow the claim of assessee accordingly. This issue of assessee’s appeal is allowed subject to verification by the AO. 11. In the result, the appeal filed by the assessee is partly allowed. Order pronounced in the open court on 26 th August, 2022 at Chennai. Sd/- Sd/- (डॉ दीपक पी. ᳯरपोटे) (Dr. DIPAK P. RIPOTE) लेखा सद᭭य/ACCOUNTANT MEMBER (महावीर ᳲसह ) (MAHAVIR SINGH) उपा᭟यᭃ /VICE PRESIDENT चे᳖ई/Chennai, ᳰदनांक/Dated, the 26 th August, 2022 RSR आदेशकᳱᮧितिलिपअᮕेिषत/Copy to: 1. अपीलाथᱮ/Appellant 2. ᮧ᭜यथᱮ/Respondent 3. आयकरआयुᲦ (अपील)/CIT(A) 4. आयकरआयुᲦ /CIT 5. िवभागीयᮧितिनिध/DR 6. गाडᭅफाईल/GF.