M/s. Karp Mfg. Co., Surat V. The ACIT.,Circle-7, Surat

ITA 374/AHD/2011

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 85871 (ITAT-AHMEDABAD)
• Duration Of Justice: 4 year(s) 1 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-03-2015
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: D
• Next Hearing Date: 18-03-2015
• Assessment Year: 2006-2007
• Appeal Filed On: 11-02-2011
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ROOP CHAND
• Assessee Lawyers: MEHUL R SHAH
• Keywords: Question of law; Benefit of exemption
• Section: 143(3); 10B

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL D BENCH, AHMEDABAD (BEFORE SHRI MUKUL KR. SHRAWAT, J.M. & SHRI ANIL C HATURVEDI, A.M.) I.T. A. NOS. 374 & 766 /AHD/2011 (ASSESSMENT YEAR: 2006-07) M/S. KARP MFG. CO., F/P NO. 23A OPP NATRAJ CINEMA, LALDARWAJA, SURAT V/S ADDL. COMMISSIONER OF INCOME TAX, RANGE-7, SURAT. (APPELLANT) (RESPONDENT) ADDL. COMMISSIONER OF INCOME TAX, RANGE-7, SURAT. V/S M/S. KARP MFG. CO., F/P NO. 23A OPP NATRAJ CINEMA, LALDARWAJA, SURAT (APPELLANT) (RESPONDENT) PAN: AAFFK 5003Q APPELLANT BY : SHRI MEHUL. R. SHAH, A.R. RESPONDENT BY : SHRI ROOP CHAND, SR. D.R. ( )/ ORDER DATE OF HEARING : 18-03-2015 DATE OF PRONOUNCEMENT : 26 -03-2015 PER SHRI ANIL CHATURVEDI,A.M. 1. THESE TWO APPEALS, ONE FILED BY THE ASSESSEE AND TH E OTHER FILED BY THE REVENUE, ARE AGAINST THE ORDER OF CIT(A)-V, SURAT D ATED 16.11.2010 FOR A.Y. 2006-07. 2. THE RELEVANT FACTS AS CULLED OUT FROM THE MATERIAL ON RECORD ARE AS UNDER. ITA NOS 374 & 766/AHD/20111 . A.Y.2006-07 2 3. ASSESSEE IS A PARTNERSHIP FIRM STATED TO BE ENGAGED IN THE BUSINESS OF IMPORT OF ROUGH DIAMONDS AND MANUFACTURING AND EXPORT OF P OLISHED DIAMONDS. ASSESSEE FILED ITS RETURN OF INCOME FOR A.Y. 2006-0 7 ON 28.12.2006 DECLARING ITS TOTAL INCOME OF RS. 2,80,950/-. THE C ASE WAS SELECTED FOR SCRUTINY AND THEREAFTER THE ASSESSMENT WAS FRAMED U NDER SECTION 143(3) VIDE ORDER DATED 24.12.2009 AND THE TOTAL INCOME WAS DET ERMINED AT RS. 19,41,540/-. AGGRIEVED BY THE ORDER OF A.O., ASSES SEE CARRIED THE MATTER BEFORE LD. CIT(A) WHO VIDE ORDER DATED 16.11.2010 G RANTED PARTIAL RELIEF TO THE ASSESSEE. AGGRIEVED BY THE AFORESAID ORDER OF LD. CIT(A), ASSESSEE & REVENUE ARE NOW IN APPEAL BEFORE US. THE GROUNDS RA ISED BY THE ASSESSEE READS AS UNDER:- 1. ON THE FACTS AND CIRCUMSTANCES OF THE CASE AS WELL AS LAW ON THE SUBJECT, THE LD. CIT(A) HAS ERRED IN PARTLY CONFIRMING THE ACTION OF ASSESSING OFFICER IN NOT GRANTING DEDUCTION OF RS. 1,02,000/- OUT OF RS. 18,62,586/- U/S. 10B OF THE ACT ON ACCOUNT OF INTEREST INCOME. 4. ON THE OTHER HAND THE GROUNDS RAISED BY THE REVENUE READS AS UNDER:- 1. ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN L AW, THE LD. CIT(A) HAS ERRED IN ALLOWING THE ASSESSEES CLAIM OF DEDUCTION U/S. 10B OF INTEREST INCOME OF RS. 17,60,586/- WITHOUT APPRECIATING THE FACT THAT SUCH INTEREST EARNED HAS NO BEARING ON THE EXPORT INCOME AND HENCE IS INELIGIBLE FOR CLAIM OF SUCH DEDUCTION. 5. SINCE THE GROUNDS RAISED BY THE ASSESSEE AND REVENU E ARE INTERCONNECTED AND THEREFORE THE GROUNDS RAISED IN BOTH THE APPEAL S ARE CONSIDERED TOGETHER. 6. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, A.O NO TICED THAT ASSESSEE HAS CLAIMED DEDUCTION U/S. 10B ALSO ON THE INTEREST IN COME OF RS. 20,67,936/- WHICH COMPRISED OF INTEREST FROM BANK ON FDRS OF RS . 17,60,586/- AND ITA NOS 374 & 766/AHD/20111 . A.Y.2006-07 3 INTEREST OF RS. 3,07,350/- ON THE DEPOSITS PLACED W ITH ELECTRICITY BOARD. A.O WAS OF THE VIEW THAT THE INTEREST INCOME RECEIVED F ROM BANK WAS DERIVED FROM THE FDRS AND WAS NOT DIRECTLY RELATED TO THE B USINESS OF EXPORT OF ARTICLE OR THINGS AND NOT DERIVED THROUGH FOREIGN E XCHANGE WHICH IS THE MAIN CRITERIA FOR CLAIMING DEDUCTION U/S. 10B. HE ALSO N OTED THAT SIMILAR ADDITION WAS MADE IN EARLIER YEARS AND LD. CIT(A) HAD PARTLY CONFIRMED THE ADDITION AND THE DEPARTMENT HAD NOT ACCEPTED THE DECISION OF LD. CIT(A) AND HAD PREFERRED APPEAL BEFORE HONBLE ITAT. WITH RESPECT TO INTEREST RECEIVED FROM ELECTRICITY DEPARTMENT ON THE DEPOSITS PLACED WITH IT, HE WAS OF THE VIEW THAT IT HAD NO DIRECT RELATION WITH THE BUSINE SS OF THE ASSESSEE AND THEREFORE NOT ELIGIBLE FOR DEDUCTION. HE ACCORDINGL Y IGNORED THE INTEREST RECEIVED FROM BOTH THE SOURCES FOR THE PURPOSE OF D EDUCTION U/S. 10B. AGGRIEVED BY THE ORDER OF A.O., ASSESSEE CARRIED TH E MATTER BEFORE LD. CIT(A). LD. CIT(A) NOTED THAT IDENTICAL ISSUE AROSE IN A.Y. 2005-06 IN ASSESSEES OWN CASE AND FOLLOWING THE ORDER OF HIS PREDECESSOR, GRANTED PARTIAL RELIEF BY DELETING THE ADDITION OF RS. 17, 60,586/- ON ACCOUNT OF INTEREST INCOME EARNED FROM BANKS BUT HOWEVER CONFI RMED THE ADDITION OF RS. 1,02,000/- ON THE INTEREST EARNED ON DEPOSIT WI TH ELECTRICITY BOARD. THE RELEVANT FINDING OF LD. CIT(A) IS AS UNDER:- DECISION: I HAVE CONSIDERED RIVAL CONTENTIONS. IN THE APPELLA NT OWN CASE FOR THE A.Y. 2005-06, SIMILAR ADDITION WERE MADE BY THE ASSESSING OFFICER . IT IS SEEN FROM THE RECORD THAT IN THE APPEAL MY PREDECESSOR HAS DELETED THE ADDITION MADE ON ACCOUNT OF INTEREST INCOME FROM F.D.R. AND CONFIRMED THE ADDITION OF INTEREST INCOM E FROM ELECTRICITY BOARD. FOLLOWING MY PREDECESSOR'S ORDER THE ADDITION OF RS. 17,60,58 6/- ON ACCOUNT OF INTEREST INCOME EARNED ON F.D.R. WITH STATE BANK OF INDORE IS HEREB Y DELETED AND ADDITION OF RS.1,02,000/- ON ACCOUNT OF INTEREST EARNED ON DEPO SIT WITH ELECTRICITY BOARD IS CONFIRMED. ITA NOS 374 & 766/AHD/20111 . A.Y.2006-07 4 7. AGGRIEVED BY THE ORDER OF LD. CIT(A), ASSESSEE AND REVENUE ARE NOW IN APPEAL BEFORE US. 8. BEFORE US, AT THE OUTSET, LD. A.R. SUBMITTED THAT A GAINST THE ORDER OF LD. CIT(A) FOR A.Y. 05-06, ASSESSEE AND REVENUE HAD PRE FERRED APPEAL BEFORE HONBLE TRIBUNAL. HONBLE TRIBUNAL WHICH DECIDING T HE APPEAL (ITA NO. 314 & 315/AHD/2009) DATED 27.05.2011 CONFIRMED THE ORDER OF CIT(A) AND DECIDED THE ISSUE PARTLY IN FAVOUR OF ASSESSEE BY HOLDING AS UNDER:- 4.THE ONLY GROUND READS AS UNDER: ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN L AW, THE LEARNED CIT(A) HAS ERRED IN RESTRICTING THE DISALLOWANCE ON ACCOUNT OF INTEREST INCOME U/S.10B OF THE I.T. ACT OF RS.9,45,200/- MADE BY THE AO WITHOUT CONSIDERING TH E FACTS BROUGHT IN, IN ITS ENTIRETY. 4.1. WHILE DECIDING THE ISSUE INVOLVED LD.CIT(A) HAS GRANTED PART RELIEF AS PER THE FOLLOWING OBSERVATION: 'I HAVE CAREFULLY CONSIDERED THE REASONS GIVEN BY A SSESSING OFFICER & ALSO THE SUBMISSIONS OF THE APPELLANT. AFTER CAREFULLY ANALY ZING THE FACTS OF THE CASE IT IS SEEN THAT SO FAR AS INTEREST INCOME ON FDR IS CONCERNED, I FI ND MERIT IN THE CONTENTION OF APPELLANT THAT AS FDR IS PLACED OUT OF LOAN BORROWED FROM THE BANK, THE EXPENDITURE INCURRED ON LOAN IS REQUIRED TO BE REDUCED FROM THE INTEREST ON FDR AS SAID AMOUNT IS EXPENDED FOR EARNING THE INTEREST INCOME. AS INTEREST PAID IS MO RE THAN INTEREST ON FDR, DEDUCTION U/S.10B CANNOT BE CURTAILED ON THIS GROUND IN VIEW OF THE PRINCIPLE OF NETTING. I ALSO FIND THAT RATIO OF HONOURABLE GUJARAT HIGH COURT DECISIO N IN THE CASE OF JASHVIDHYABEN C.MEHTA V. CIT -172 ITR 680 & WHICH IS DISCUSSED BY HONOURABLE SUPREME COURT IN CASE OF CIT V. DR. V.P. GOPINATHAN - 248 ITR 449 IS APPLICABLE TO THE FACTS OF INSTANT CASE AND THUS, ACTION OF ASSESSING OFFICER IN DISAL LOWING DEDUCTION U/S.10B ON THE INTEREST INCOME ON FDR OF RS.9,45,200/- IS NOT SUSTAINABLE. HOWEVER, AS REGARDS INTEREST INCOME ON DEPOSIT WITH ELECTRICITY COMPANY, I FIND THAT AP PELLANT HAS FAILED TO PROVE ANY SUCH NEXUS & THUS, ACTION OF ASSESSING OFFICER IN DISALL OWING DEDUCTION U/S.10B ON SAID INTEREST INCOME OF RS.2,02,386/- IS CONFIRMED. ACCORDINGLY, OUT OF TOTAL DISALLOWANCE OF RS. ITA NOS 374 & 766/AHD/20111 . A.Y.2006-07 5 L1,47,586/- MADE BY ASSESSING OFFICER, DISALLOWANCE TO THE EXTENT OFRS.9,45,200/- IS HEREBY DELETED & THE BALANCE AMOUNT OF RS.2,02,386/ - IS CONFIRMED ' 4.2. ON THE BASIS OF OBSERVATION OF ID.CIT(A) SINCE THE ASSESSEE HAS NOT PROVED THE NEXUS IN RESPECT OF PART OF INTEREST, THEREFORE, THE VIEW TAKEN BY THE ID.CIT(A) APPEARS TO BE A JUSTIFIED VIEW, HENCE, HEREBY CONFIRMED. 9. BEFORE US, THE LD. A.R. THEREFORE SUBMITTED THAT TH E AS FAR AS ISSUE WITH RESPECT TO INTEREST EARNED ON FIXED DEPOSITS IS CON CERNED, SINCE IT HAS BEEN DECIDED IN FAVOUR OF ASSESSEE IN EARLIER YEAR, IN T HE YEAR UNDER CONSIDERATION THE ISSUE HAS TO BE DECIDED IN FAVOUR OF ASSESSEE I N VIEW OF THE DECISION OF TRIBUNAL IN ASSESSEES OWN CASE. WITH RESPECT TO TH E INTEREST EARNED ON DEPOSITS PLACED WITH ELECTRICITY DEPARTMENT LD. A.R . SUBMITTED THAT BEFORE A.O AND LD. CIT(A), ASSESSEE HAD RELIED ON THE DECI SION OF BANGALORE TRIBUNAL IN THE CASE OF ACIT VS. MOTOROLA INDIA ELE CTRONICS PVT. LTD. 114 ITD 387 BUT WAS FOUND NOT APPLICABLE TO ASSESSEES CASE AND THE SAME WAS NOT CONSIDERED BY THEM. HE FURTHER SUBMITTED THAT THE AFORESAID DECISION OF TRIBUNAL WHICH WAS RELIED BY ASSESSEE, BEFORE A.O A ND LD. CIT(A) HAS BEEN UPHELD BY HONBLE KARNATAKA HIGH COURT IN ITA NO. 4 28/A/2007 AND 447/A/2007 ORDER DATED 11.12.2013. HE THEREFORE SUB MITTED THAT SINCE THE ISSUE HAS BEEN DECIDED BY THE HIGH COURT AND SINCE THE HONBLE TRIBUNAL WHILE DECIDING THE APPEAL OF THE ASSESSEE FOR A.Y. 2007-08 WAS NOT HAVING THE BENEFIT OF THE AFORESAID DECISION, AND IN THE A BSENCE OF ANY CONTRARY BINDING DECISION OF JURISDICTIONAL HIGH COURT OR AP EX COURT, THE ISSUE ON INTEREST ON DEPOSITS WITH ELECTRICITY DEPARTMENT TH OUGH DECIDED AGAINST THE ASSESSEE BY THE TRIBUNAL IN EARLIER YEARS AND IN VI EW OF THE DECISION OF HONBLE KARNATAKA HIGH COURT NEEDS TO BE DECIDED IN FAVOUR OF THE ASSESSEE. HE ALSO PLACED ON RECORD AT PAGE 11 TO 31 OF THE PAPER BOOK THE ITA NOS 374 & 766/AHD/20111 . A.Y.2006-07 6 COPY OF THE AFORESAID DECISION OF HONBLE KARNATAKA HIGH COURT. LD. D.R. ON THE OTHER HAND SUPPORTED THE ORDER OF A.O. 10. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL ON RECORD. THE ISSUE IN THE PRESENT CASE IS WITH RESPECT TO IGNORI NG INTEREST INCOME FOR THE PURPOSE OF DEDUCTION U/S. 10B OF THE ACT. AS FAR AS THE INTEREST FROM FDRS PLACED WITH BANKS IS CONCERNED, WE FIND THAT THE IS SUE HAS BEEN DECIDED IN FAVOUR OF THE ASSESSEE BY THE CO-ORDINATE BENCH OF TRIBUNAL FOR A.Y. 2005- 06 IN ITA NO. 3148 & 3353/A/2009 ORDER DATED 27.05. 2011. BEFORE US, SINCE REVENUE HAS NOT BROUGHT ANY CONTRARY BINDING DECISION IN ITS SUPPORT, WE THEREFORE RELYING ON THE DECISION OF THE CO-ORDI NATE BENCH FOR A.Y. 2005- 06, FIND NO REASON TO INTERFERE WITH THE ORDER OF L D. CIT(A). WITH RESPECT TO THE INTEREST EARNED ON DEPOSITS PLACED WITH ELECTRI CITY DEPARTMENT IS CONCERNED, WE FIND THAT THE ISSUE WAS DECIDED AGAIN ST THE ASSESSEE BY THE CO-ORDINATE BENCH OF TRIBUNAL IN A.Y. 2005-06. WE H OWEVER FIND THAT THE HONBLE KARNATAKA HIGH COURT, AFTER CONSIDERING THE DECISIONS OF APEX COURT IN THE CASE OF PANDIAN CHEMICALS LTD. VS. CIT (2003) 262 ITR 278, LIBERTY INDIA VS. CIT (2009) 317 ITR 218, CIT VS. S TERLING FOODS (1999) 237 ITR 579 (SC) AND OTHER DECISIONS AND AFTER CONS IDERING THE AMENDMENT MADE BY FINANCE ACT, 2001 TO SUB-SECTION (4) TO SEC TION 10B HAS HELD HAS UNDER:- BY FINANCE ACT, 2001, WITH EFFECT FROM 01.04.2001, THE PRESENT SUBSECTION (4) IS SUBSTITUTED IN THE PLACE OF OLD SUBSECTION (4). NO DOUBT SUBSECTION 10B) SPEAKS ABOUT DEDUCTION OF SUCH PROFITS AND GAINS AS DERIVED F ROM 100% EOU FROM THE EXPORT OF ARTICLES OR THINGS OR COMPUTER SOFTWARE. THEREFORE, IT EXCLUDES PROFIT AND GAINS FROM EXPORT OF ARTICLES. BUT SUBSECTION (4) EXPLAIN S WHAT IS THE PROFIT DERIVED FROM EXPORT OF ARTICLES AS MENTIONED IN SUBSECTION (1) THE SUB STITUTED SUBSECTION (4) SAYS THAT PROFITS DERIVED FROM EXPORT OF ARTICLES OR THINGS OR COMPUT ER SOFTWARE SHALL BE THE ACCOUNT WHICH ITA NOS 374 & 766/AHD/20111 . A.Y.2006-07 7 BARES TO THE PROFITS OF THE BUSINESS OF THE UNDERTA KING AND NOT THE PROFITS AND GAINS FROM EXPORT OF ARTICLES. THEREFORE, PROFITS AND GAINS DE RIVED FROM EXPORT OF ARTICLES IS DIFFERENT FROM THE INCOME DERIVED FROM THE PROFITS OF THE BUS INESS OF THE UNDERTAKING. THE PROFITS OF THE BUSINESS OF THE UNDERTAKING INCLUDES THE PROFIT S AND GAINS FROM EXPORT OF THE ARTICLES AS WELL AS ALL OTHER INCIDENTAL INCOMES DERIVED FROM THE BUSINESS OF THE UNDERTAKING. IT IS INTERESTING TO NOTE THAT SIMILAR PROVISIONS A RE NOT THERE WHILE DEALING WITH COMPUTATION OF INCOME UNDER SECTION 80HHC. ON THE C ONTRARY, THERE IS SPECIFIC PROVISIONS LIKE SECTION 80HHB WHICH EXPRESSLY EXCLU DES THIS TYPE OF INCOMES. THEREFORE, IN VIEW OF THE AFORESAID PROVISIONS, IT IS CLEAR TH AT, WHAT IS EXEMPTED IS NOT MERELY THE PROFITS AND GAINS FROM THE EXPORT OF ARTICLES BUT A LSO THE INCOME FROM THE BUSINESS OF THE UNDERTAKING. 8. IN THE INSTANT, CASE, THE ASSESSEE IS A 100% EOU , WHICH HAS EXPORTED SOFTWARE AND EARNED THE INCOME. A PORTION OF THAT INCOME IS INCL UDED IN EEFC ACCOUNT. YET ANOTHER PORTION OF THE AMOUNT IS INVESTED WITHIN THE COUNTR Y BY WAY OF FIXED DEPOSITS, ANOTHER PORTION OF THE AMOUNT IS INVESTED BY WAY OF LOAN TO THE SISTER CONCERN WHICH IS DERIVING INTEREST OR THE CONSIDERATION RECEIVED FROM SALE OF THE IMPORT ENTITLEMENT, WHICH IS PERMISSIBLE IN LAW. NOW THE QUESTION IS WHETHER THE INTEREST RECEIVED AND THE CONSIDERATION RECEIVED BY SALE OF IMPORT ENTITLEMEN T IS TO BE CONSTRUED AS INCOME OF THE BUSINESS OF THE UNDERTAKING. THERE IS A DIRECT NEXU S BETWEEN THIS INCOME AND THE INCOME OF THE BUSINESS OI THE UNDERTAKING. THOUGH IT DOES NOT PAR TAKE THE CHARACTER OF A PROFIT AND GAINS FROM THE SALE OF AN ARTICLE, IT IS THE IN COME WHICH IS DERIVED FROM THE CONSIDERATION REALIZED BY EXPORT OF ARTICLES. IN VI EW OF THE DEFINITION OF 'INCOME FROM PROFITS AND GAINS' INCORPORATED IN SUBSECTION (4), THE ASSESSEE IS ENTITLED TO THE BENEFIT OF EXEMPTION OF THE SAID AMOUNT AS CONTEMPLATED UNDER SECTION 10B OF THE ACT. THEREFORE, THE TRIBUNAL WAS JUSTIFIED IN EXTENDING THE BENEFIT TO THE AFORESAID AMOUNTS ALSO. WE DO NOT FIND ANY MERIT IN THESE APPEALS. THEREFORE, THE FIRST SU BSTANTIAL QUESTION OF LAW RAISED IN ITA NO.428/2007 IS ANSWERED IN FAVOUR OF THE REV ENUE AND AGAINST THE ASSESSEE AND THE FIRST SUBSTANTIAL QUESTION OF LAW IN ITA NO. 44 7/2007 IS ANSWERED IN FAVOUR OF THE ASSESSEE AND AGAINST THE REVENUE. ITA NOS 374 & 766/AHD/20111 . A.Y.2006-07 8 11. WE THUS FIND THAT HONBLE KARNATAKA HIGH COURT HAS HELD THAT IN VIEW OF THE AMENDMENT TO SUB-SECTION(4) TO SECTION 10B, WITH EF FECT FROM 01.04.2001, WHAT IS EXEMPT IS NOT MERELY THE PROFITS AND GAINS FROM EXPORT OF ARTICLES BUT ALSO THE INCOME FROM THE BUSINESS OF THE UNDERTAKIN G. IN THE ABSENCE OF ANY CONTRARY BINDING DECISION BROUGHT TO OUR NOTICE BY LD. D.R., WE RESPECTFULLY FOLLOWING THE AFORESAID DECISION OF HONBLE KARNATA KA HIGH COURT IN THE CASE OF MOTOROLA INDIA ELECTRONICS PVT. LTD (SUPRA) , HOLD THAT ASSESSEE IS ELIGIBLE FOR DEDUCTION U/S. 10B OF THE ACT ON THE I NTEREST RECEIVED ON DEPOSITS PLACED WITH ELECTRICITY DEPARTMENT. WE THUS DIRECT ACCORDINGLY. IN THE RESULT, THE GROUNDS OF ASSESSEE ARE ALLOWED AND THAT OF REV ENUE ARE DISMISSED. 12. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOWE D AND THAT OF REVENUE IS DISMISSED. ORDER PRONOUNCED IN OPEN COURT ON 26 - 03 - 2015. SD/- SD/- (MUKUL KR. SHRAWAT) (ANIL CHATURVEDI) JUDICIAL MEMBER ACCOUNTANT MEMBER AHMEDABAD. TRUE COP Y RAJESH COPY OF THE ORDER FORWARDED TO: - 1. THE APPELLANT. 2. THE RESPONDENT. 3. THE CIT (APPEALS) 4. THE CIT CONCERNED. 5. THE DR., ITAT, AHMEDABAD. 6. GUARD FILE. BY ORDER DEPUTY/ASSTT.REGISTRA R ITAT,AHME DABAD