Vinod Gopalkrishnan Nair, Aurangabad V. Income-tax Officer,

ITA 354/PUN/2014

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 93730 (ITAT-PUNE)
• Duration Of Justice: 1 year(s) 2 month(s) 24 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 20-05-2015
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: A
• Next Hearing Date: 06-05-2015
• Assessment Year: 2010-2011
• Appeal Filed On: 26-02-2014
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Unexplained expenditure; Gift; Earning of tax free income
• Section: 69C; 143(3); 69; 144

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH A, PUNE BEFORE MS SUSHMA CHOWLA, JUDICIAL MEMBER AND SHRI R.K. PANDA, ACCOUNTANT MEMBER ITA NO.354/PN/2014 ASSESSMENT YEAR: 2010-11 VINOD GOPALKRISHNAN NAIR, PLOT NO.503, F SECTOR, N-1, CIDCO, AURANGABAD. PAN: AHIPG0405M . APPELLANT VS. THE INCOME TAX OFFICER, WARD 2(3), AURANGABAD. . RESPONDENT APPELLANT BY : NONE RESPONDENT BY : SHRI RAJESH DAMOR DATE OF HEARING : 06-05-2015 DATE OF PRONOUNCEMENT : 20-05-2015 ORDER PER SUSHMA CHOWLA, JM: THIS APPEAL FILED BY THE ASSESSEE IS AGAINST THE OR DER OF CIT(A), AURANGABAD DATED 25.11.2013 RELATING TO ASSESSMENT YEAR 2010-11 PASSED UNDER SECTION 143(3) OF THE INCOME-TAX ACT, 1961. 2. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS OF APPEAL:- 1. THAT ON FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW THE LEARNED CIT(APPEALS) HAS ERRED IN SUSTAINING ADDITI ON TOWARDS ALLEGED UNEXPLAINED CASH DEPOSITS IN ICLCI BANK AS MADE BY THE LEARNED AO - TOTALLY DISREGARDING THE FACTS AND CONTENTION OF ASSESSEE FOR GIFTS RECEIVED FROM HER MOTHER AND - IGNORING EVEN THE WRITTEN SUBMISSIONS FILED BY TH E APPELLANT DURING THE COURSE OF ASSESSMENT PROCEEDINGS. AND THEREFORE, THE IMPUGNED ADDITION SHOULD BE DELE TED. 2. THAT ON FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW THE LEARNED CIT(APPEALS) HAS ERRED IN SUSTAINING THE AD DITION OF RS.5,03,314/- MADE BY THE LEARNED AO TOWARDS EXPEND ITURE INCURRED THROUGH CREDIT CARDS, WHERE AS ALL THE PAYMENTS WER E MADE THROUGH ACCOUNT PAYEE CHEQUES. 3. THAT ON FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW THE LEARNED CIT(APPEALS) HAS ERRED IN SUSTAINING THE AD DITIONS CREDIT ENTRIES IN SAVING BANK ACCOUNT ADDED U/S 69 WITHOUT APPRECI ATING THE FACT THAT THE LEARNED AO HAD NOT CONSIDERED ANY SUBMISSION OF THE ASSESSEE. ITA NO.354/PN/2014 2 4. THE APPELLANT CRAVES LEAVE TO ADD, AMEND, ALTER, SUBSTITUTE, MODIFY THE ABOVE GROUNDS OF APPEAL, IF NECESSARY ON THE BASIS OF WRITTEN SUBMISSIONS AND PERSONAL PRESENTATION TO BE MADE AT THE TIME OF HEARING. 3. DESPITE OF NOTICE, NONE APPEARED ON BEHALF OF TH E ASSESSEE AND NOR ANY APPLICATION WAS MOVED FOR ADJOURNMENT. WE PROCEED TO DECIDE THE PRESENT APPEAL AFTER HEARING THE LD. DEPARTMENTAL REPRESENT ATIVE FOR THE REVENUE. 4. BRIEFLY, THE FACTS OF THE CASE ARE THAT THE ASSE SSEE HAD FILED RETURN OF INCOME DECLARING TOTAL INCOME OF RS.6,52,160/-. TH E CASE OF THE ASSESSEE WAS SELECTED FOR SCRUTINY UNDER CASS. THERE WAS NON-CO MPLIANCE OF THE ASSESSEE BEFORE THE ASSESSING OFFICER AND EVEN ON THE DATES WHEN THE ASSESSEE APPEARED, COMPLETE INFORMATION/DOCUMENTS WERE NOT F ILED BY THE ASSESSEE. THE ASSESSING OFFICER THUS FINALIZED THE ASSESSMENT ON THE BASIS OF THE DETAILS AVAILABLE ON RECORD. THE ASSESSING OFFICER NOTED T HAT AS PER THE AIR INFORMATION, ASSESSEE HAD DEPOSITED A SUM OF RS.16,04,900/- IN T HE SAVINGS BANK ACCOUNT WITH ICICI BANK. THERE WERE CERTAIN OTHER CREDIT E NTRIES IN THE SAID BANK ACCOUNT. ON THE PERUSAL OF THE RETURN OF INCOME, THE ASSESSI NG OFFICER NOTED THAT THE ASSESSEE HAD SHOWN INCOME FROM REMUNERATION FROM FI RM, INTEREST ON CAPITAL WITH THE FIRM AND HAD EXEMPT INCOME FROM PROFIT FROM THE SAID FIRM, M/S VEEKAY CONSTRUCTIONS. THE REMUNERATION AND THE INTEREST D UE FROM THE FIRM WAS CREDITED IN THE CAPITAL ACCOUNT ITSELF. SINCE THE ASSESSEE HAD NOT FURNISHED ANY CLARIFICATION OF THE CREDITS MADE THROUGH CHEQUES/T RANSFER AND SOURCE OF CASH DEPOSITS IN THE BANK ACCOUNT, STATEMENT OF THE ASSE SSEE WAS RECORDED UNDER SECTION 131(1)(B) OF THE ACT ON 10.10.2012. IN REP LY TO THE SAID STATEMENT, THE ASSESSEE CLAIMED THAT HE HAD NO SOURCE OF INCOME OT HER THAN THE RECEIPTS FROM THE PARTNERSHIP FIRM. HE ALSO CONFIRMED THAT HE HA D NOT RECEIVED ANY UNSECURED LOAN DURING THE CURRENT FINANCIAL YEAR AND AN UNSEC URED LOAN WAS TAKEN DURING THE FINANCIAL YEAR 2008-09. FURTHER, HE HAD NOT TR ANSACTED IN SALE AND PURCHASE OF ANY PROPERTY. THE ASSESSEE WAS ASKED TO EXPLAIN THE SOURCE OF CASH DEPOSITS IN THE BANK ACCOUNT WITH ICICI BANK AT RS.16,04,900 /- AND ALSO TO EXPLAIN NATURE ITA NO.354/PN/2014 3 OF CREDIT ENTRIES OF RS.2,00,000/- DATED 12.05.2009 AND RS.66,000/- DATED 19.05.2009. THE EXPLANATION OF THE ASSESSEE VIS-- VIS THE CASH DEPOSITS IN THE BANK ACCOUNT WAS EITHER WITHDRAWAL FROM FIRM AND LO AN FROM RELATIVE. SINCE THE ASSESSEE HAD DEPOSED IN HIS STATEMENT THAT HE HAD N OT RECEIVED ANY UNSECURED LOAN OR GIFT DURING THE YEAR UNDER CONSIDERATION, T HE SOURCE OF CASH DEPOSITS BEING UNEXPLAINED WAS PROPOSED TO BE ADDED BY THE A SSESSING OFFICER, AGAINST WHICH AN EX-PARTE NOTICE UNDER SECTION 144 OF THE A CT DATED 25.10.2012 WAS ISSUED TO THE ASSESSEE. IN REPLY, THE LD. AUTHORIZ ED REPRESENTATIVE FOR THE ASSESSEE APPEARED AND STATED THAT THERE WERE DEPOSI TS AS WELL AS WITHDRAWALS AND THE ENTIRE DEPOSITS COULD NOT BE TREATED AS INC OME OF THE ASSESSEE AND ONLY PEAK OF THE CREDIT FACILITY BE ADDED. THE ASSESSEE WAS ASKED TO FURNISH THE REPLY WHICH IS REPRODUCED UNDER PARA 3.4 OF THE ASSESSMEN T ORDER AT PAGES 5 AND 6. THE ASSESSING OFFICER NOTED THAT AS AGAINST THE CLA IM OF THE ASSESSEE, THERE WAS CASH WITHDRAWALS IN THE BANK IN THE NAME OF (I) MRS . LINCY SABASTEIN; (II) ANTHONY MATHEW; AND, (III) M. NANDKUMAR. SINCE THE ASSESSE E HAD EARLIER EXPLAINED THAT THE LOANS OF THE SAID PERSONS WERE PAID, THE EXPLAN ATION OF THE ASSESSEE WAS REJECTED AND THE ASSESSING OFFICER TABULATED THE DE TAILS OF CASH DEPOSITS IN THE BANK AT PAGE 7 OF THE ASSESSMENT ORDER AND ADDED A SUM OF RS.13,84,900/-, AGAINST WHICH NO EXPLANATION WAS GIVEN BY THE ASSES SEE. FURTHER, IN RESPECT OF THE CREDIT TO THE SAID SAVINGS BANK ACCOUNT, THE AS SESSING OFFICER NOTED THAT EXCEPT FOR WITHDRAWALS OF RS.1,20,000/-, NO OTHER W ITHDRAWALS WERE REFLECTED IN THE CAPITAL ACCOUNT OF THE ASSESSEE IN THE BOOKS OF ACCOUNT OF THE FIRM. IN VIEW THEREOF, CREDITS OF RS.2,70,000/- CLAIMED TO BE WIT HDRAWALS FROM THE FIRM WAS REJECTED AND THE SAME WAS ADDED AS INCOME OF THE AS SESSEE UNDER SECTION 69 OF THE ACT. OTHER CREDITS THROUGH CHEQUES/TRANSFER WE RE TABULATED AND ARE REPRODUCED UNDER PARA 4.4 AT PAGE 9 OF THE ASSESSME NT ORDER AND SINCE THE ASSESSEE FAILED TO EXPLAIN THE SOURCE AND NATURE OF THE SAID CREDIT TOTALING TO RS.7,01,000/-, THE SAID AMOUNT WAS ADDED AS INCOME OF THE ASSESSEE UNDER SECTION 69 OF THE ACT. ITA NO.354/PN/2014 4 5. BEFORE THE CIT(A), THE ASSESSEE FILED SUBMISSION S IN WHICH AS AGAINST THE ADDITION MADE BY THE ASSESSING OFFICER TOTALING RS. 28,60,257/-, THE ASSESSEE CONTESTED ONLY TWO ADDITIONS I.E. OF RS.2,70,000/- AND RS.7,01,000/- ON ACCOUNT OF CREDIT ENTRIES IN SAVINGS BANK ACCOUNT UNDER SEC TION 69 OF THE ACT. THE GROUNDS OF APPEAL RAISED BY THE ASSESSEE AND THE WR ITTEN SUBMISSIONS FILED BY THE ASSESSEE BEFORE THE CIT(A) ARE REPRODUCED UNDER PARAS 4 AND 5 AT PAGES 2 TO 4 OF THE APPELLATE ORDER. THE SUBMISSIONS OF TH E ASSESSEE WERE FORWARDED TO THE ASSESSING OFFICER WHO, IN TURN, SUBMITTED THE R EMAND REPORT OBJECTING TO THE ADMISSION OF THE EVIDENCE FILED BY THE ASSESSEE AND ALSO REJECTING THE EXPLANATION OF THE ASSESSEE VIS--VIS THE SOURCES O F THE SAID CREDIT ENTRIES. THE REPORT OF THE ASSESSING OFFICER WAS FORWARDED TO TH E ASSESSEE FOR HIS COUNTER COMMENTS AND THE ASSESSEE CLAIMED THAT OUT OF TOTAL ADDITION OF RS.28,60,257/-, THE ADDITION OF RS.5,36,000/- WAS TO BE DELETED. T HE SAID SUBMISSIONS OF THE ASSESSEE ARE REPRODUCED UNDER PARA 5.2 AT PAGES 6 A ND 7 OF THE APPELLATE ORDER. VIS--VIS THE FIRST CLAIM OF THE ASSESSEE IN RESPEC T OF RS.2,70,000/-, THE CIT(A) NOTED THAT THE SAID AMOUNT WAS TRANSFERRED FROM THE FIRMS BANK ACCOUNT IN WHICH THE ASSESSEE WAS A PARTNER. THE CIT(A) WAS OF THE VIEW THAT IF THE AMOUNT HAS BEEN TRANSFERRED FROM THE PARTNERSHIP FIRMS BANK A CCOUNT, NO ADDITION WAS TO BE MADE IN THE HANDS OF THE ASSESSEE. THE CIT(A) DIRE CTED THE ASSESSING OFFICER TO VERIFY THE CLAIM OF THE ASSESSEE AFTER OBTAINING BA NK OF BARODA ACCOUNT OF THE PARTNERSHIP FIRM, M/S VEEKAY CONSTRUCTIONS AND TO D ELETE THE ADDITION. 6. AS REGARDS, THE OTHER ADDITION OF RS.7,01,000/-, THE CIT(A) PERUSED THE COPIES OF CREDIT CARD STATEMENTS OF ICICI BANK SHOW ING ORIGINAL AMOUNT OF LOAN OBTAINED ON 10.05.2009 OF RS.2,00,000/- AND ON 15.0 5.2009 OF RS.66,000/-. IN VIEW OF THE SAID CREDIT CARD LOAN STATEMENTS, THE C ONTENTION OF THE ASSESSEE WAS THAT THE ENTRIES WERE OUT OF LOANS FROM ICICI BANK THROUGH CREDIT CARD WERE FOUND TO BE CORRECT AND ACCEPTED. THE ASSESSING OFFICER WAS DIRECTED TO DELETE THE ADDITION TO THE EXTENT OF RS.2,66,000/- FROM THE AD DITION MADE BY THE ASSESSING OFFICER OF RS.7,01,000/-. ITA NO.354/PN/2014 5 7. HOWEVER, THE ASSESSEE BEFORE US HAS FILED THE GR OUNDS OF APPEAL AGAINST THE ADDITION MADE IN HIS HANDS ON ACCOUNT OF UNEXPL AINED CASH DEPOSITS IN ICICI BANK AS MADE BY THE ASSESSING OFFICER AND ADDITION SUSTAINED BY THE CIT(A) TOTALING RS.5,03,314/- MADE ON ACCOUNT OF UNEXPLAIN ED EXPENDITURE INCURRED THROUGH CREDIT CARDS AND ALSO AGAINST CREDIT ADDITI ON ON ACCOUNT OF CREDIT ENTRIES IN THE SAVINGS BANK ACCOUNT ADDED UNDER SECTION 69 OF THE ACT. 8. THE ASSESSEE UNDER THE PROVISIONS OF SECTION 254 OF THE ACT IS EMPOWERED TO FILE AN APPEAL BEFORE THE TRIBUNAL AGA INST THE ORDER OF THE CIT(A). HOWEVER, THE RIGHT TO FILE OF AN APPEAL AND RAISE G ROUND OF APPEAL AGAINST SUCH ORDER OF THE CIT(A) ARE RESTRICTED TO THE ISSUES RA ISED BEFORE THE CIT(A). THOUGH, THERE ARE PROVISIONS FOR ADMISSION AND ADJUDICATION OF ADDITIONAL GROUND OF APPEAL BY THE TRIBUNAL BUT NO SUCH ISSUE HAS BEEN R AISED IN THE PRESENT APPEAL BEFORE US. THE ASSESSING OFFICER IN THE FACTS OF T HE CASE HAD MADE AN ADDITION ON ACCOUNT OF THE FOLLOWING REASONS :- PARTICULARS OF ADDITION PARA OF ASSTT. ORDER AMOUNT RS. UNEXPLAINED CASH DEPOSITS IN ICICI BANK 3.10 13,84, 900 CREDIT ENTRIES IN SAVINGS BANK ACCOUNT ADDED UNDER SECTION 69 OF THE ACT 4.3 2,70,000 CREDIT ENTRIES IN SAVINGS BANK ACCOUNT ADDED UNDER SECTION 69 OF THE ACT 4.5 7,01,000 UNEXPLAINED EXPENDITURE THOUGH CREDIT CARD ADDED UNDER SECTION 69C OF THE ACT 5 5,03,314 BANK SAVING INTEREST 6 1,043 TOTAL 28,60,257 9. HOWEVER, BEFORE THE CIT(A) THE GROUNDS OF APPEAL RAISED BY THE ASSESSEE WERE AS UNDER :- 1. MR. VINOD NAIR WAS UNABLE TO PROVIDE THE REQUIR ED DETAILS AND DOCUMENTS IN THE COURSE OF ASSESSMENT PROCEEDINGS U/S 143(3) FOR A.Y.2010-11, AS HE WAS FREQUENTLY OUT OF TOWN DURING THE MONTHS SEPTEMBER 2012 TO JANUARY 2013, DUE TO SOME UNAVOIDABLE PERSONAL REASONS AND DUE TO ILL HEALTH OF HIS MOTHER RESIDING IN KERALA. AS HE CAME IN TOWN AND WHEN IT COMES TO HIS KNOWLEDGE ABO UT ADDITIONS MADE IN HIS TOTAL INCOME FOR A.Y. 2010-11, HE WANTS TO GIVE FOLLOWING INFORMATION/CLARIFICATIONS AND SUBMIT REQUIRED DETA ILS/DOCUMENTS. ITA NO.354/PN/2014 6 2. AS MENTIONED IN PARA 4.4 OF ASSESSMENT ORDER, AN ADDITION OF RS.7,01,000/- HAS BEEN MADE ON ACCOUNT OF SOURCES O F SUCH CREDIT AMOUNTS THAT CANNOT BE SUBSTANTIATED BY THE ASSESSE E. OUT OF WHICH RS.2,00,000/- AND RS. 66,000/- CREDITED IN BANK STATEMENT DTD.12.05.2009 AND 19.05.2009 RESPECTIVELY, WAS ON ACCOUNT OF PERSONAL LOANS AVAI LED AND TRANSFERRED/CREDITED TO CONCERN SAVINGS ACCOUNTS. 3. AS MENTIONED IN PARA 4.3 OF ASSESSMENT ORDER RS.2,70,000/- WAS BEING ADDED TO ASSESSEE'S TOTAL INCOME ON ACCOUNT O F WITHDRAWALS MADE BY HIM FROM HIS PARTNERSHIP FIRM'S ACCOUNT WHICH HAS NOT B EEN REFLECTED IN CAPITAL ACCOUNT LEDGER EXTRACT OF PARTNER'S CAPITAL ACCOUNT IN THE BOOKS OF VEE KAY CONSTRUCTION. WITH REGARD TO THIS WE WISH TO INFORM YOU THAT WHILE SUBMISSION OF CAPITAL ACCOUNT EXTRACT OF PARTNER'S CAPITAL INADVE RTENTLY WRONG CAPITAL ACCOUNT EXTRACT HAD BEEN SUBMITTED. CORRECT CAPITAL ACCOUNT EXTRACT HAS BEEN PROVIDED BY THE ASSESSEE AS PER THAT ALL WITHDRAWALS ARE DEBITE D TO CAPITAL ACCOUNT OF THE ASSESSEE. 4. ASSESSEE IS ALSO MAKING EFFORTS TO GATHER OTHER REQUIRED DETAILS AND INFORMATION SUCH AS LOAN CONFIRMATIONS, BANK ST ATEMENTS AND INCOME DETAILS OF THE UNSECURED LOANERS. 5. THE LEARNED AO HAS NOT CONSIDERED ASSESSES ACTUA L DIFFICULTY/ INABILITY WHILE NON FURNISHING OF REQUIRED DOCUMENT S AND DETAILS. IT WILL BE POSSIBLE FOR THE ASSESSEE TO PRODUCE/SUBMIT REQUIRE D INFORMATION AND DETAILS IF ASSESSEE IS GIVEN SUFFICIENT OPPORTUNITY AND TIME F OR SUBMISSION. 6. ASSESSEE CRAVE TO ALTER, ADD, DELETE OR MODIFY A NY OTHER GROUNDS AT THE TIME OF APPEAL. 7. WE REQUEST HERE WITH, PLEASE CONSIDER ABOVE FACT S AND KINDLY GIVE AN OPPORTUNITY TO THE ASSESSEE TO SUBMIT REQUIRED D ETAILS/DOCUMENTS UNDER RULE 46A(1)(D) IN SUPPORT OF ADDITIONS MADE BY LEAR NED AO TO ASSESSEE'S TOTAL INCOME OR KINDLY REMIND BACK CASE TO THE AO F OR REASSESSMENT WHICH WILL RESULT REDUCTION IN AMOUNT OF ADDITIONS MADE TO TOTAL INCOME VIS NET TAX PAYABLE AS MENTIONED IN ASSESSMENT ORDE R OF LEARNED AO. 10. THE CIT(A) NOTED VIDE PARA 5 THAT THE ASSESSEE HAS CONTESTED ONLY TWO ADDITIONS I.E. ADDITION OF RS.7,01,000/- AND RS.2,7 0,000/- MADE ON ACCOUNT OF CREDIT ENTRIES IN SAVINGS BANK ACCOUNT ADDED UNDER SECTION 69 OF THE ACT. IN THE SUBMISSIONS FILED BY THE ASSESSEE DATED 02.07.2013, REFERENCE HAS ALSO BEEN MADE ONLY TO THE ABOVE SAID TWO ADDITIONS I.E. RS.7 ,01,000/- AND RS.2,70,000/-, ASSESSEE FURNISHED EXPLANATION FOR RS.2,66,000/- AN D FURTHER FURNISHED EXPLANATION FOR RS.2,70,000/-. THE CIT(A) AFTER TA KING INTO CONSIDERATION THE REMAND REPORT OF THE ASSESSING OFFICER AND THE SUBM ISSIONS MADE BY THE ASSESSEE IN REPLY THERETO WHEREIN THE ASSESSEE HAD PRAYED TO DROP THE ADDITION MADE BY THE ASSESSING OFFICER TO THE ASSESSEES TOT AL INCOME OF RS.5,36,000/- I.E. RS.2,70,000/- PLUS RS.2,66,000/-, DIRECTED THE ASSESSING OFFICER TO VERIFY THE CLAIM OF THE ASSESSEE VIS--VIS RS.2,70,000/- AND D ELETE THE ADDITION OF ITA NO.354/PN/2014 7 RS.2,66,000/-. IN THE TOTALITY OF THE ABOVE SAID F ACTS AND CIRCUMSTANCES WHERE THE ASSESSEE HAD ACCEPTED THE ADDITIONS MADE BY THE ASSESSING OFFICER IN THE FIRST APPEAL FILED BY HIM BEFORE THE CIT(A) AND IN THE ABSENCE OF ANY OTHER SUBMISSIONS HAVING BEEN FILED BY THE ASSESSEE BEFOR E US, WE FIND NO MERIT IN THE GROUNDS OF APPEAL RAISED BY THE ASSESSEE AND THE SA ME ARE DISMISSED. IT MAY ALSO BROUGHT ON RECORD THAT THE PRESENT APPEAL FILE D BY THE ASSESSEE IS AFTER DELAY OF 22 DAYS AND THE ASSESSEE HAS FAILED TO FUR NISH ANY EVIDENCE FOR THE ABOVE SAID DELAY AND IN THE ABSENCE OF THE SAME, TH E APPEAL OF THE ASSESSEE MERITS TO BE DISMISSED IN LIMINE. 11. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DI SMISSED. ORDER PRONOUNCED ON THIS 20 TH DAY OF MAY, 2015. SD/- SD/- (R.K. PANDA) (SUSHMA CHOWLA) ACCOUNTANT MEMBER JUDICIAL MEMBER PUNE, DATED: 20 TH MAY, 2015 SUJEET COPY OF THE ORDER IS FORWARDED TO: - 1) THE ASSESSEE; 2) THE DEPARTMENT; 3) THE CIT(A), AURANGABAD; 4) THE CIT, AURANGABAD; 5) THE DR A BENCH, I.T.A.T., PUNE; 6) GUARD FILE. BY ORDER //TRUE COPY// ASSISTANT REGISTRAR I.T.A.T., PUNE