ACIT, JHUNJHUNU V. PARUL CONSTRUCTION COMPANY, JHUNJHUNU

ITA 339/JPR/2016

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 1800 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 8 month(s) 20 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 28-12-2017
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: Not Allotted
• Assessment Year: 2011-2012
• Appeal Filed On: 07-04-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: K L MULCHANDANI
• Assessee Lawyers: R A VERMA CIT DHK
• Keywords: Rejection of books of accounts; Depreciation; Opportunity of being heard
• Section: 142(1); 144

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S, JAIPUR JH HKKXPUN] YS[KK LNL; ,OA JH DQY HKKJR] U;KF;D LNL; DS LE{K BEFORE: SHRI BHAGCHAND, AM AND SHRI KUL BHARAT, JM VK;DJ VIHY LA-@ ITA NO. 275/JP/2016 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2011-12. M/S PARUL CONSTRUCTION COMPANY V. & P.O., KODESAR, JHUNJHUNU. CUKE VS. ACIT, JHUNJHUNU CIRLCE-JHUNJHUNU. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. AACFP 3708 N VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT VK;DJ VIHY LA-@ ITA NO. 339/JP/2016 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2011-12. ACIT, JHUNJHUNU CIRLCE-JHUNJHUNU. CUKE VS. M/S PARUL CONSTRUCTION COMPANY V. & P.O., KODESAR, JHUNJHUNU. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. AACFP 3708 N VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT JKTLO DH VKSJ LS@ REVENUE BY : SHRI K.L MULCHANDANI (C.A.) FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI R.A. VERMA (ADDL. CIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 26.12.2017. ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 28.12.2017 VKNS'K@ ORDER PER BENCH THESE APPEALS FILED BY THE ASSESSEE AND THE REVENUE ARE DIRECTED AGAINST THE ORDER OF LD. CIT (A)-3, JAIPUR DATED 07/01/2016 PER TAINING TO A.Y. 2011-12. THE GROUNDS OF ASSESSEES APPEAL ARE READS AS UNDER :- 1. UNDER THE FACTS AND CIRCUMSTANCES, THE HONBLE CIT(A) HAS CONFIRMED THE ADDITION ON ESTIMATION BASIS WITHOUT GIVING ANY JUSTIFICATION, REASONABLENESS AND PAST HISTORY OF THE CASE. THE C IT(A) HAS WRONGLY DISALLOWED CONTRACT EXPENSES A SUM OF RS. 10,00,000 .00 2 ITA NO. 275 & 339/JP/2016. M/S PARUL CONSTRUCTION COMPANY. 2. UNDER THE FACTS AND CIRCUMSTANCES, THE HONBLE C IT(A) HAS LEGALLY AND FACTUALLY ERRED BY CONFIRMING DISALLOWANCE ON INTER EST PAID TO VARIOUS FINANCIAL INSTITUTIONS A SUM OF RS. 6,02,135.00 PAI D BY THE ASSESSEE ON VARIOUS LOAN TAKEN ON PLANT AND MACHINERY ETC. WITH OUT APPRECIATING FACTS OF THE CASE. 3. THE ASSESSEE MAY CRAVE TO AMEND, ALTER, MODIFY O R RAISE ANY OTHER GROUND OF APPEAL. THE GROUNDS OF REVENUES APPEAL ARE READS AS UNDER: - 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CA SE THE CIT(A) HAS ERRED IN ALLOWING RELIEF OF RS. 41,62,853/- IN RESPECT OF DISALLOWANCE OF CONTRACT EXPENSES DESPITE LOW NET P ROFIT DECLARED FROM CONTRACT RECEIPTS AND NOT FURNISHING OF REQUIRED DE TAILS AND EVIDENCE BY THE ASSESSEE. 2. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E THE CIT(A) HAS ERRED IN ALLOWING RELIEF TO THE ASSESSEE TO THE EXTENT OF RS. 41,62,853/- EVEN THOUGH SHE HAS CONFIRMED THE ACTIO N OF INVOCATION OF SECTION 145(3) OF THE IT ACT, 1961. 2. THE GROUND NO. 1 OF ASSESSEES APPEAL AND GROUND NOS. 1 & 2 OF REVENUES APPEAL ARE AGAINST THE PART RELIEF GRANTE D BY THE LD. CIT(A) WITH REGARD TO THE ESTIMATING THE INCOME AND SUSTAINING THE LUMP-S UM AMOUNT OF RS. 10,00,000/-. THE ASSESSEE IS A CIVIL CONTRACTOR. THE TOTAL RECEI PTS FOR THE YEAR UNDER CONSIDERATION WAS OF RS. 19,27,82,615/-. THE TOTAL EXPENDITURE DE BITED IN PROFIT AND LOSS ACCOUNT WAS RS. 17,20,95,111/-. THUS, THE CONTRACT EXPENSES DEBITED IN PROFIT AND LOSS WAS AT 89.25% OF THE TOTAL RECEIPT. THE ASSESSING OFFIC ER DISALLOWED 3% OF THE TOTAL CONTRACT EXPENSES AND MADE ADDITION OF RS. 51,62,85 3/-. THE LD. CIT(A) HAS DECIDED THIS ISSUE IN PARA 4.3 BY HOLDING AS UNDER:- 4.3 I HAVE CAREFULLY CONSIDERED THE SUBMISSION OF THE APPELLANT, FINDINGS OF THE A.O AS ALSO OTHER RELEVANT FACTS RELATING TO TH IS GROUND. IT MAY BE NOTED THAT THE APPELLANT HAS OBJECTED TO THE REJECTION OF BOOKS OF ACCOUNTS AND ADDITION OF RS. 5162853/- OUT OF CONTRACT EXPENSES. A SPECIFIC QUERY WAS 3 ITA NO. 275 & 339/JP/2016. M/S PARUL CONSTRUCTION COMPANY. RAISED REGARDING BIFURCATING THE CONSOLIDATED AMOUN T OF CONTRACT EXPENSES AND FURNISHING OF MONTH WISE STATEMENT OF DIFFERENT HEADS IN CONTRACT EXPENSES. AS PER A.O. THE APPELLANT NEVER PRODUCED BOOKS OF ACCOUNTS AS ALSO THAT THE COMPLETE DETAILS OF CONTRACT EXPENSES VIZ A VIZ EXPENSES INCURRED UNDER DIFFERENT HEADS WAS NOT FURNISHED. THEREFORE THE A.O. CAME TO THE CONCLUSION THAT THE CONTRACT EXPENSES AMOUNTING TO RS. 17.20 CRORES APPROXIMATELY AND WHICH WERE ABOUT 89.25% OF THE TO TAL RECEIPTS WERE NOT SUBJECT TO PROPER VERIFICATION. THE A.O. ACCORDINGL Y DISALLOWED 3% OF SUCH CONTRACT RECEIPT LEADING TO ADDITION OF RS. 5162863 /-. ON THE OTHER HAND THE APPELLANT CASE IS THAT PROCEEDINGS WERE ATTENDED ON SPECIFIC DATES WITH REGULAR BOOKS OF ACCOUNTS AND THAT ON THOSE SPECIFI C DATES THE A.O. WAS NOT AVAILABLE. IT IS ALSO CLAIMED THAT THE APPELLANT HA S MAINTAINED CONSTANT N.P. AND G.P. RATE AND THAT EVEN WHEN THE CASE WAS COMPL ETED UNDER SCRUTINY ASSESSMENT IN THE PAST THE INCOME WAS ASSESSED @ 6 TO 7% SUBJECT TO CLAIM OF DEPRECIATION INTEREST PAYMENT AND REMUNERATION T O THE PARTNERS. IT IS ALSO CONTENDED THAT BEFORE DISALLOWING 3% OF CONTRACT EX PENSES THE A.O. HAS NOT GIVEN PROPER OPPORTUNITY OF BEING HEARD OR ANY SHOW CAUSE NOTICE. ON CAREFUL CONSIDERATION OF RELEVANT FACTS IT MAY BE NOTED THA T THE A.O. HAS FIXED THE PROCEEDINGS ON DIFFERENT DATES AS MENTIONED IN THE ASSESSMENT ORDER AND THE APPELLANT NEITHER PRODUCED THE REGULAR BOOKS OF ACC OUNTS FOR EXAMINATION NOR FURNISHED SPECIFIC DETAIL IN RESPECT OF DIFFERENT H EADS OF CONTRACT EXPENSES AMOUNTING TO RS. 17.20 CRORES. IT MAY BE NOTED THAT SUCH SPECIFIC QUERY FOR FURNISHING OF BIFURCATED ACCOUNT OF CONTRACT EXPENS ES UNDER DIFFERENT HEADS WAS MADE BY THE A.O. VIDE NOTICE U/S 142(1) DATED 1 7.01.2014 AND WHICH WAS REPEATEDLY REQUESTED FOR ON THE SUBSEQUENT DATE S OF HEARING BUT THE APPELLANT NEVER COMPLIED WITH SUCH SPECIFIC REQUIRE MENT RAISED BY THE A.O. IT MAY BE NOTED THAT IN THE CONTRACT ACCOUNT OF M/S PA RUL CONSTRUCTION COMPANY THE APPELLANT HAS CLAIMED CONTRACT EXPENSES IN A CO NSOLIDATED MANNER FOR RS. 17.20 CRORES APPROXIMATELY AND FOR MAKING PROPER VE RIFICATION OF SUCH EXPENSES THE A.O. HAS RIGHTLY REQUIRED THE ASSESSEE TO FURNISH BIFURCATED 4 ITA NO. 275 & 339/JP/2016. M/S PARUL CONSTRUCTION COMPANY. DETAILS OF SUCH EXPENSES BY WAY OF EACH HEAD AS ALS O MONTH WISE EXPENSES OF EACH HEAD OF EXPENSES. HOWEVER THE AR OF THE ASSESS EE VIDE ORDER SHEET ENTRY DATED 18.02.2014 HAS EXPRESSED HIS INABILITY TO PRODUCE BOOKS OF ACCOUNTS BEFORE THE AO. IN THIS BACKGROUND IT CAN B E SAID WITH CERTAINTY THAT THE CLAIM OF THE APPELLANT IN RESPECT OF CONTRACT E XPENSES AMOUNTING TO RS. 17.20 CRORES WAS NOT SUBJECT TO PROPER VERIFICATION AND THEREFORE THE BOOKS OF ACCOUNTS OF THE APPELLANT CANNOT CONSIDERED TO BE C ORRECT OR COMPLETE AND THEREFORE THE A.O. HAS RIGHTLY REJECTED THE BOOKS O F ACCOUNTS AND MADE THE ASSESSMENT IN THE MANNER PROVIDED U/S 144 OF IT ACT . THEREFORE THE ACTION OF THE A.O. IN REJECTION OF BOOKS OF ACCOUNTS AND APPL YING PROVISION OF 145(3) OF IT ACT IS CONFIRMED. AS REGARDS ESTIMATION OF PROFIT, AFTER INVOKING THE PROVISIONS OF SEC. 145(3) OF IT ACT, IT MAY BE STATED THAT IT IS A SETTLED LAW T HAT EVEN AFTER INVOKING THE PROVISIONS OF SEC. 145(3), THE AO IS NOT EMPOWERED TO ASSESS THE INCOME AT WHATEVER FIGURES HE WANTS AND THE AO IS SUPPOSED TO MAKE AN HONEST ESTIMATION EITHER BASED ON THE PAST HISTORY OF THE APPELLANT'S OWN CASE OR ON THE BASIS OF ANY COMPARABLE CASE. THE PAST RESULTS MAY ALSO INDICATE THAT THE CLAIM OF THE EXPENSES SHOULD ALSO BE BROADLY SIMILA R TO THE PAST YEARS AND IF THERE IS WIDE VARIATIONS THEN THERE SHOULD BE SPECI FIC REASONS FOR THE SAME. FOR SUCH PROPOSITION RELIANCE IS PLACED ON THE FOLL OWING CASE LAWS: I) M/S BRIJBHUSHAN LAI PRADHUMAN KUAMR VS. CIT, 115 IT R 524 II) SHREE SHANKAR KHANDSARI SUGAR MILLS VS. CIT, 193 I TR 669 III) CIT VS DR. A.P. BAHEL 2 DTR 387 (RAJ) IV) CIT VS. SURESH MARBLES PVT. LTD. 18 DTR 118 (RAJ) V) SHRI RAM JHANWAR VS. ITO (2005) 98 TTJ 639 (ITAT, JODHPUR) VI) AJAY GOYAL VS. ITO 99 TTJ, ITAT, JODHPUR THE MERITS OR OTHERWISE OF THE ADDITION MADE BY THE A.O. ARE TO BE DECIDED ACCORDINGLY. IT MAY BE NOTED THAT AS PER TH E A.O. ON TOTAL TURNOVER OF RS. 192782615/- LACS. THE APPELLANT HAS SHOWN CONTR ACT EXPENSES AMOUNTING TO RS. 172095111/- LACS WHICH ARRIVED AT 89.25% OF TOTAL RECEIPTS. THE A.O. 5 ITA NO. 275 & 339/JP/2016. M/S PARUL CONSTRUCTION COMPANY. CONSIDERED SUCH CONTRACT EXPENSES EXCESSIVE AND DIS ALLOWED 3% OF SUCH EXPENSES LEADING TO ADDITION OF RS. 5162853/-. IT M AY BE NOTED THAT THE A.O. HAS NOT GIVEN ANY JUSTIFICATION FOR DISALLOWING 3% OF SUCH EXPENSES. IN FACT, THE A.O. HAS NOT EVEN COMPARED SUCH CONTRACT EXPENS ES INCURRED IN EARLIER YEARS AS COMPARED TO THE EXPENSES SHOWN IN THE YEAR UNDER CONSIDERATION. THE A.O. HAS ALSO NOT TRIED TO COMPARE THE G.P./N.P SHOWN BY THE APPELLANT IN EARLIER YEARS VIZ A VIZ IN THE YEAR UNDER CONSID ERATION. DURING THE APPELLATE PROCEEDINGS THE APPELLANT WAS REQUIRED TO FURNISH T HE DETAILS OF CONTRACT EXPENSES INCURRED IN EARLIER TWO YEARS AS COMPARED TO SUCH CLAIM IN THE YEAR UNDER CONSIDERATION AND THE COMPARATIVE FIGURE WAS FOUND TO BE AS UNDER: PARUL CONSTRUCTION COMPANY, JHUNJHUNU COMPARATIVE % OF CONTRACT EXPENSES FINANCIAL YEAR T URNOVER CONTRACT EXPENSES % OF CONTRACT EXPENSE AS TO TURNOVER 2008 - 09 RS. 26,58,45,224.00 RS. 238356752.00 89.65997 2009 - 10 RS. 30,62,54,769.00 RS. 275477252.00 89.95036 2010 - 11 RS. 19,27,82,615.00 RS. 17,20,95,111.00 89.26900 2011 - 12 RS. 30,13,17,657.00 RS. 27,18,92,012.00 90.02 THE PERUSAL OF SUCH COMPARATIVE EXPENSES MAY INDICA TE THAT IN COMPARISON TO A.Y. 2010-11 THE PERCENTAGE OF SUCH E XPENSES AS PROPORTION TO THE TOTAL RECEIPT HAS DECREASED FROM 89.95% TO 89.2 5%. HOWEVER, KEEPING IN VIEW THE FACT THAT THE BOOKS OF ACCOUNTS WERE NOT SUBJECT TO VERIFICATION AND SPECIFIC DETAILS IN RES PECT OF CONTRACT EXPENSES WERE NOT FILED MERELY BY RELYING ON PAST HISTORY, T HE ASSESSEE CANNOT BE ABSOLVED FROM THE STATUTORY DUTIES OF MAINTAINING P ROPER BOOKS OF ACCOUNTS. IT SEEMS THAT THE ASSESSEE IN THIS CASE HAS MADE A PRA CTICE OF NOT MAINTAINING / PRODUCING PROPER DETAILS TO SUPPORT THE EXPENSES CL AIMED IN CONTRACT ACCOUNT. THUS AFTER CONSIDERING THE TOTALITY OF FACTS AND CI RCUMSTANCES OF THIS CASE, 6 ITA NO. 275 & 339/JP/2016. M/S PARUL CONSTRUCTION COMPANY. LUMP SUM ADDITION OF RS. 10,00,000/- OUT OF SUCH CO NTRACT EXPENSES IS CONFIRMED. THE APPELLANT ACCORDINGLY GETS RELIEF OF RS. 4162853/- THE GROUNDS OF APPEAL ARE PARTLY ALLOWED. 2.1 AFTER HEARING BOTH THE SIDES, WE ARE OF THE VIE W THAT LD. CIT(A) HAS DEALT THE ISSUE ELABORATELY IN HER ORDER. AFTER CONSIDERING T HE PAST HISTORY AND ALSO THE VARIOUS OTHER REASONS OF NOT MAINTAINING AND PRODUCING PROP ER DETAILS TO SUPPORT THE EXPENSES CLAIMED IN CONTRACT ACCOUNT., THE LD. CIT (A) HAS RIGHTLY SUSTAINED THE ADDITION UP TO RS. 10 LACS. FURTHER, WE ALSO HOLD T HAT LD. CIT(A) RIGHTLY GRANTED THE RELIEF TO THE EXTENT OF RS. 41,62,853/- TO THE ASSE SSEE. THEREFORE, WE FIND NO MERITS IN THE GROUNDS OF THE REVENUES APPEAL AS WELL AS A SSESSEES APPEAL ON THIS ISSUE. IN THE RESULT, ASSESSEES GROUND NO. 1 AND REVENUE S GROUND NO. 1 & 2 ARE DISMISSED. 3. GROUND NO. 2 OF ASSESSEES APPEAL IS AGAINST SUSTAINING THE DIS ALLOWANCE ON INTEREST PAID ON VARIOUS FINANCIAL INSTITUTIONS AMO UNT OF RS. 6,02,135/-. 3.1 THE CIT(A) HAS DECIDED THIS ISSUE BY OBSERVING AS UNDER:- 6.3 I HAVE CAREFULLY CONSIDERED THE FINDINGS OF TH E AO AS ALSO ARGUMENTS OF THE LD. AR OF THE APPELLANT. THE TDS W AS DEPOSITED LATE BY THE ASSESSEE ON 04.02.2014. SECTION 40(A)(IA) ST ATES THAT:- SECTION 40. NOTWITHSTANDING ANYTHING TO THE CONTRARY IN SECTIO NS 30 TO [38], THE FALLOWING AMOUNTS SHALL NOT BE DEDUCTE D IN COMPUTING THE INCOME CHARGEABLE UNDER THE HEAD 'PROFITS AND GAINS OF BUSINESS OF PROFESSION', - (A) IN THE CASE OF ANY ASSESSEE (IA) [THIRTY PERCENT OF ANY SUM PAYABLE TO A RESIDE NT], ON WHICH TAX IS DEDUCTIBLE AT SOURCE UNDER CHAPTER XVII-B AND SUCH TAX HAS NOT BEEN DEDUCTED OR, AFTER DEDUCTION [HAS NOT BEEN PAID ON OR BEFORE THE DUE DATE SPECIFIED IN SUB-SECTION (1) OF SECTION 139:] 7 ITA NO. 275 & 339/JP/2016. M/S PARUL CONSTRUCTION COMPANY. [PROVIDED THAT WHERE IN RESPECT OF ANY SUCH SUM, TAX HAS BEE N DEDUCTED IN ANY SUBSEQUENT YEAR, OR HAS BEEN DEDUCT ED DURING THE PREVIOUS YEAR BUT PAID AFTER THE DUE DATE SPECIFIED IN SUB-SECTION (1) OF SECTION 139, [THIRTY PERCENT OF] SUCH SUM SHALL BE ALLOWED AS A DEDUCTION IN COMPUTING THE INCOME OF THE PREVIOUS Y EAR IN WHICH SUCH TAX HAS BEEN PAID:] [PROVIDED FURTHER THAT WHERE AN ASSESSEE FAILS TO DEDUCT THE WHOLE OR ANY PART OF THE TAX IN ACCORDANCE WITH THE PROVI SIONS OF CHAPTER XVII-B ON ANY SUCH SUM BUT IS NOT DEEMED TO BE AN A SSESSEE IN DEFAULT UNDER THE FIRST PROVISO TO SUB-SECTION (1) OF DEEMED THAT THE ASSESSEE HAS DEDUCTED AND PAID THE TAX ON SUCH SUM ON THE DATE OF FURNISHING OF RETURN OF INCOME BY THE RESIDENT PAYE E REFERRED TO IN THE SAID PROVISO.]' SINCE THE ASSESSEE HAS NOT DEPOSITED THE TDS IN THI S YEAR THEREFORE THE DEDUCTION CANNOT BE ALLOWED IN THIS YEAR. HOWEVER T HE AO IS DIRECTED TO GIVE DEDUCTION TO ASSESSEE IN AY 2014 -15 IN THE YEAR OF PAYMENT AS PER PROVISION OF LAW. THE ASSESSEE FURTHER CONTENDE D THAT WHEN INCOME IS ESTIMATED NO FURTHER DISALLOWANCE CAN BE MADE. FROM THE RECORD IT IS NOTED THAT INTEREST IS SEPARATELY CLAI MED IN P&L ACCOUNT AND INCOME OF THE ASSESSEE WAS ESTIMATED BY MAKING DISA LLOWANCE OUT OF CONTRACT EXPENSES WHICH DOES NOT INCLUDE INTEREST E XPENSES. THUS THE CASE LAWS RELIED UPON ARE DISTINGUISHABLE AND THERE FORE DISALLOWANCE U/S 40(A)(IA) COULD BE MADE FOR NON DEDUCTION AND P AYMENT OF TDS ON INTEREST TO NBFCS. IN VIEW OF ABOVE THIS GROUND IS DISMISSED. 3.2 AFTER HEARING BOTH THE SIDES, WE FIND THAT THE ASSESSEE HAS NOT DEPOSITED TDS IN THE YEAR. THEREFORE, THE LD. CIT(A) HAS NOT ALL OWED RELIEF TO THE ASSESSEE BUT HE HAS DIRECTED TO GIVE THE DIRECTION TO AO TO ALLOW I N THE ASSESSMENT YEAR 2014-15 8 ITA NO. 275 & 339/JP/2016. M/S PARUL CONSTRUCTION COMPANY. WHEN THE ASSESSEE HAS MADE PAYMENT. THEREFORE, WE F IND NO MERIT INTO THIS GROUND OF ASSESSEES APPEAL. 4. IN THE RESULT, BOTH ASSESSEE AND REVENUES APPEA LS ARE DISMISSED. ORDER IS PRONOUNCED IN THE OPEN COURT ON 28/12/20 17. SD/- SD/- ( DQY HKKJR ) ( HKKXPUN ( KUL BHARAT ) ( BHAGCHAND) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER JAIPUR DATED: 28/12/2017 POOJA VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. THE APPELLANT- M/S PARUL CONSTRCUTION COMPANY, JHUNJHUNU. 2. THE RESPONDENT ACIT, CIRCLE- JHUNJHUNU. 3. THE CIT. 4. THE CIT(A), 5. THE DR, ITAT, JAIPUR 6. GUARD FILE (ITA NO. 275 & 339/JP/2016) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR