GULAB CHAND RAMCHANDANI, JODHPUR V. JCIT, Ajmer

ITA 41/JPR/2016

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 4969 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 10 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 07-11-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Not Allotted
• Assessment Year: 2010-2011
• Appeal Filed On: 07-01-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: POONAM RAI DCIT DR DHK
• Assessee Lawyers: GULAB RAI RAMCHANDANI
• Keywords: Unexplained cash credit; Question of law; Reasonable cause; Ignorance of law
• Section: 273B; 143(3)

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES (SMC), JAIPUR JH HKKXPUN] YS[KK LNL; DS LE{K BEFORE: SHRI BHAGCHAND, ACCOUNTANT MEMBER VK;DJ VIHY LA-@ ITA NO. 41/JP/2016 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2010-11 SHRI GULAB CHAND RAMCHANDANI 22, SHASTRI MARKET BEAWAR CUKE VS. THE ITO WARD- 2 BEAWAR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: AEQPR 9117 K VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY:SHRI GULAB RAI RAMCHANDANI (ASSESSEE) JKTLO DH VKSJ LS@ REVENUE BY :SMT. POONAM RAI, DCIT-. DR LQUOKBZ DH RKJH[K@ DATE OF HEARING : 28/10/2016 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 7 /11/2016 VKNS'K@ ORDER PER BHAGCHAND, AM THE ASSESSEE HAS FILED AN APPEAL AGAINST THE ORDE R OF THE LD. CIT(A), AJMER DATED 28-10-2015 FOR THE ASSESSMENT Y EAR 2010-11 RAISING THEREIN FOLLOWING GROUNDS:- (1) THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE, THE LD. CIT(A) GROSSLY ERRED IN UPHOLDING THE VALIDITY OF THE ORDER PASSED BY THE JCIT, RANGE-1, AJMER UND ER THE PROVISIONS OF SECTION 271D OF I.T. ACT, 1961. ITA NO. 41/JP/2016 SHRI GULAB CHAND RAMCHANDANI VS. ITO , WARD- 2, BEA WAR . 2 (2) THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE, THE LD. CIT(A) GROSSLY ERRED IN SUSTAINING TH E PENALTY OF RS. 2,83,500/- UNDER THE PROVISIONS OF SECTION 271D OF I.T. ACT, 1961. 2.1 APROPOS GROUND NO. 1 AND 2 OF THE ASSESSEE, IT IS OBSERVED THAT ASSESSMENT IN THE CASE OF SHRI GULAB RAI RAMCHANDAN I WAS COMPLETED U/S 143(3) OF THE I.T. ACT ON 18-03-2013 FOR THE ASSESS MENT YEAR 2011-12. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE IT O, WARD- 2, BEAWAR OBSERVED THAT THE ASSESSEE HAD ACCEPTED THE LOANS I N CASH OF RS. 2,83,500/-FROM THE FOLLOWING PERSONS WHICH ACC ORDING TO HIM IS CONTRAVENTION OF PROVISIONS OF SECTION 2699SS OF TH E I.T.ACT 1961 AND THUS IT ATTRACTS THE PENALTY U/S 271D OF THE ACT.. NAME OF PARTY DATE MODE OF PAYMENT AMOUNT (RS.) KAILASH SANGTANI 01-04-2009 CASH 19,000/- REKHA SANGTANNI 03-04-2009 CASH 19,000/- - DO - 17-04-2009 CASH 19,000/- SNEH RAMCHANDANI 01-04-2009 CASH 19,000/- SUSHIL KUMAR RAMNANI 01-04-2009 CASH 19,000/- - DO - 02-04-2009 CASH 19,500/- SANGEETA RAMCHANDANI 05-04-2009 CASH 18,000/- - DO - 06-04-2009 CASH 19,000/- - DO - 07-04-2009 CASH 19,000/- - DO - 10-04-2009 CASH 19,000/- - DO - 13-04-2009 CASH 19,000/- - DO - 15-04-2009 CASH 19,000/- - DO - 25-10-2009 CASH 19,000/- SURESH RAMNANI 01-04-2009 CASH 19,000/- - DO - 02-04-2009 CASH 19,000/- TOTAL 2,83,500 ITA NO. 41/JP/2016 SHRI GULAB CHAND RAMCHANDANI VS. ITO , WARD- 2, BEA WAR . 3 THUS THE ITO,WARD- 2, BEAWAR VIDE HIS LETTER DATED 04-04-2013 SENT THE PROPOSAL FOR INITIATION OF PENALTY PROCEEDING U/S 2 71D IN THE CASE OF THE ASSESSEE. SHOW CAUSE NOTICE FOR PENALTY U/S 271D WA S ISSUED ON 18-06- 2014 VIDE LETTER NO. 43 ASKING THE ASSESSEE AS TO W HY PENALTY U/S 271D BE NOT IMPOSED UPON FOR THE DEFAULT. IN RESPONSE TO TH E ABOVE SHOW CAUSE NOTICE, THE ASSESSEE SHRI GULAB RAM RAMCHANDANI APP EARED PERSONALLY ON 27-06-2013 AND SUBMITTED HIS REPLY BEFORE THE JC IT, RANGE-2, AJMER. THE CONCLUSIVE OBSERVATION OF THE JCIT, RANGE-2,AJM ER AS TO IMPOSITION OF PENALTY OF RS. 2,83,500/- U/S 271D OF THE ACT ON THE ASSESSEE IS AS UNDER:- ON GOING THROUGH THE ABOVE, IT IS OBSERVED THAT T HE ASSESSEE IN HIS SUBMISSION HAS HIMSELF ADMITTED THE FACT THAT HE HAS ACCEPTED THE LOANS FROM VARIOUS PERSONS IN CASH DUR ING THE YEAR UNDER CONSIDERATION. THE ASSESSEE FURTHER ARGUED TH AT HE WAS UNDER IMPRESSION THAT THERE IS NO NECESSITY TO ACCEPT A L OAN BELOW THE MONETARY LIMIT OF RS. 20,000/- THROUGH A CHEQUE OR DEMAND DRAFT. HE HAD NO IDEA THAT EVEN THE AGGREGATE IF EXCEEDED RS. 20,000/- RESULTED INTO CONTRAVENTION OF SECTION 269SS OF THE I.T. ACT , 1961. IN VIEW OF THE ENTIRE FACTS AND CIRCUMSTANCES OF TH E CASE, I HOLD THAT THE ASSESSEE HAS VIOLATED THE PRO VISIONS OF SECTION 269SS OF THE INCOME TAX ACT, 1961 BY ACCEPTING A SU M OF RS. 2,83,500/- IN CASH. IT IS NO WHERE RELEVANT THAT TH E ASSESSEE HAS MADE IT KNOWINGLY OR OTHERWISE AS THE IGNORANCE OF LAW HAS NO EXCUSE. THEREFORE, I IMPOSE A PENALTY U/S 271D OF T HE I.T. ACT OF RS. 2,83,500/- (RS. TWO LACS EIGHTY THREE THOUSAND & FIVE HUNDRED ONLY) I.E. AMOUNT OF LOAN TAKEN OR ACCEPTED IN CASH IN CONTRAVENTION OF THE PROVISION OF SECTION 269SS OF THE I.T. ACT. ITA NO. 41/JP/2016 SHRI GULAB CHAND RAMCHANDANI VS. ITO , WARD- 2, BEA WAR . 4 THE PENALTY LEVIABLE IS EQUAL TO THE AMOUNT OF LOAN OR DEPOSIT SO TAKEN IN THE CASE OF THE ASSESSEE. THE AMOUNT ACCEP TED IS RS. 2,83,500/-. I LEVY OF PENALTY OF RS. 2,83,500/- (RS . TWO LACS EIGHTY THREE THOUSAND & FIVE HUNDRED ONLY). 2.2 IN FIRST APPEAL, THE LD. CIT(A) CONFIRMED THE P ENALTY U/S 271D OF THE ACT IMPOSED BY THE AO BY OBSERVING AS UNDER:- 4.3 I HAVE GONE THROUGH THE PENALTY ORDER, STATEM ENT OF FACTS, GROUND OF APPEAL AND WRITTEN SUBMISSION C AREFULLY. IT IS SEEN THAT THE APPELLANT HAS ARGUED THAT HE HA D TO BORROW THE FUND IN CASH BECAUSE OF COMPELLING BUSINESS NEE DS BUT IN SUPPORT OF THE CLAIM, THE APPELLANT HAS NOT FURNISH ED ANY EVIDENCE. IN THE ABSENCE OF ANY EVIDENCE, THE CONTE NTION OF THE APPELLANT CANNOT BE ACCEPTED. AS FAR AS THE ARG UMENT OF THE APPELLANT THAT THE LOAN BY THE APPELLANT WERE G ENUINE, IT WOULD BE PERTINENT TO MENTION THAT PENALTY U/S 271D IS LEVIABLE FOR CONTRAVENTION OF THE PROVISIONS OF SEC TION 269SS AND NOT FOR UNEXPLAINED CREDIT U/S 68. SO THE ARGUM ENT OF THE APPELLANT THAT SINCE THE LOANS WERE ACCEPTED BY THE AO AS GENUINE, NO PENALTY U/S 271D SHOULD HAVE BEEN IMPOS ED BY THE AO, IS NOT ACCEPTED. FURTHER, THE APPELLANT HAS ARGUED THAT HE WAS UNDER BONA FIDE BELIEF THAT PENALTY U/S 271D CANNOT BE IMPOSED, IF THE AMOUNT BORROWED AT A TIME IS LESS THAN RS. 25,000/-, THEREFORE, NO PENALTY SHOULD HAV E BEEN LEVIED ON THE APPELLANT. IT HAS CONSISTENTLY BEEN H ELD BY VARIOUS COURTS THAT THE IGNORANCE OF LAW IS NO EXCU SE FOR INFRACTION OF ANY LAW OF THE LAND. THEREFORE, THE A RGUMENT OF THE APPELLANT THAT HE WAS NOT AWARE OF THE PROVISIO NS OF SECTION 269SS, HENCE, THE PENALTY COULD NOT BE LEVI ED U/S 271D, IS ALSO NOT ACCEPTABLE. AS FAR AS VARIOUS DECISIONS RELIED UPON BY THE APPELLANT ARE CONCERNED, THE APPELLANT HAS NOT FURN ISHED ANY DOCUMENTARY EVIDENCE TO SHOW THAT THE FACTS NARRATE D IN THESE DECISIONS ARE SIMILAR TO THE FACTS OF THE CAS E OF THE APPELLANT. THEREFORE, IT CANNOT BE HELD THAT RATIO OF THESE DECISION IS APPLICABLE IN THE CASE OF APPELLANT. TA KING INTO ITA NO. 41/JP/2016 SHRI GULAB CHAND RAMCHANDANI VS. ITO , WARD- 2, BEA WAR . 5 ACCOUNT ALL THE FACTS OF THE CASE, I AM OF THE CONS IDERED VIEW THAT AO WAS FULLY JUSTIFIED IN LEVYING THE PENALTY U/S 271D. HENCE, THE PENALTY LEVIED BY THE AO HEREBY CONFIRME D. 2.3 DURING THE COURSE OF HEARING, THE ASSESSEE PRAY ED THAT THESE DEPOSITS RECEIVED BY THE ASSESSEE ARE LESS THAN RS. 20,000/- AND THEY WERE TAKEN FROM THE CLOSE RELATIVES AND FAMILY MEMBERS. THE ASSESSEE WAS UNDER BONA FIDE BELIEF THAT SUCH TRANSACTION OF LES S THAN RS. 20,000/- CAN BE TAKEN. THE ASSESSEE FURTHER PRAYED THAT THE GENU INENESS OF THE LOANS WERE ESTABLISHED BEFORE THE AO WHO NEVER DOUBTED TH EIR AUTHENTICITY AND THE FUNDS WERE TAKEN TO MEET OUT THE URGENT NEED OF THE BUSINESS OF THE ASSESSEE. THERE WAS NO LOSS TO THE REVENUE. MOREOVE R, THERE WAS NO INTENTION OF THE ASSESSEE TO DEFRAY OR INFRINGE THE LAW. THE ASSESSEE RELIED ON THE DECISION OF HON'BLE JURISDICTIONAL HIGH COUR T IN THE CASE OF CIT VS. RAJ KUMAR SHARMA, 294 ITR 131 WHEREIN THE HON'B LE HIGH COURT REJECTED THE CONTENTION OF THE REVENUE AND DELETED PENALTY U/S 271D AFTER OBSERVING AS UNDER:- WE ARE NOT PERSUADED BY THE SUBMISSION OF COUNSEL FOR THE REVENUE . SECTION 271D OF THE INCOME TAX ACT PROVIDES FOR PEN ALTY FAILURE TO COMPLY WITH THE PROVISIONS OF SECTION 26 9SS OF THE INCOME- TAX ACT. ACCORDING TO THIS PROVISION, IF A PERSON, INTER ALIA, ACCEPTS ANY LOAN IN CONTRAVENTION OF THE PROVISIONS OF SECTION 269SS OF THE ITA NO. 41/JP/2016 SHRI GULAB CHAND RAMCHANDANI VS. ITO , WARD- 2, BEA WAR . 6 INCOME-TAX ACT, HE SHALL BE LIABLE TO PAY, BY WAY O F PENALTY, A SUM OF EQUAL TO THE AMOUNT OF LOAN OR DEPOSIT SO TAKEN OR ACCEPTED. SECTION 273B IS AN OVERRIDING PROVISION. ACCORDING TO THE S AID PROVISION, NO PENALTY SHALL BE IMPOSABLE ON A PERSON OR ASSESSEE FOR ANY FAILURE, INTER ALIA, REFERRED TO SECTION 271D IF HE PROVES THAT TH ERE WAS REASONABLE CAUSE FOR THE SAID FAILURE. THE TRIBUNAL IN ITS ORDER HAS FOUND THAT THE GENUIN ENESS OF THE DEPOSITS MADE BY THE ASSESSEE'S BROTHER PANKAJ SHAR MA WAS NOT IN DOUBT BY THE ASSESSING OFFICER. THE TRIBUNAL NOTICE D THAT EXPLANATION GIVEN BY THE ASSESSEE THAT THE DEPOSITS WERE OBTAIN ED BY HIM TO SATISFY THE IMMEDIATE BUSINESS REQUIREMENT BUT FOUND THAT T HIS HAS NOT BEEN ESTABLISHED. HOWEVER, THE TRIBUNAL WAS THUS OF THE VIEW THAT THERE WAS A REASONABLE CAUSE TO ACCEPT THE DEPOSIT OTHERWISE THROUGH BANK DRAFT OR THROUGH CHEQUE BECAUSE THE ASSESSEE BONA FIDE BE LIEVED THAT THE CASH TRANSACTIONS BELOW RS. 20,000/- WAS PERMISSIBLE. IT IS TRUE THAT THE IGNORANCE OF LAW IS NO EXCUSE, BUT THE QUESTION HERE IS WHETHER THE ASSESSEE WAS ABLE TO ESTABLISH REASONABLE CAUSE U/S 273B JUSTIFYING THAT NO PENALTY SHOULD BE IMPOSED I N CONTRAVENTION OF SECTION 271D OF THE INCOME-TAX ACT. NONE OF THE TRA NSACTIONS EXCEEDS, AS NOTICED ABOVE, RS. 20,000/-. THE TRIBUNAL ACCEPT ED THAT THE ASSESSEE BONA FIDE BELIEVED THAT THE CASH TRANSACTION BELOW RS. 20,000/- WAS PERMISSIBLE AND THE CAUSE SHOWN BY THE ASSESSEE CON STITUTED REASONABLE CAUSE. THE FINDING OF THE TRIBUNAL CANNOT BE SAID T O BE GROSSLY PERVERSE OR UNSUSTAINABLE IN LAW. IN OUR CONSIDERED VIEW, THE APPEAL DOES NOT GIVE RI SE TO ANY SUBSTANTIAL QUESTION OF LAW. IT IS DISMISSED IN LIM INE. 2.4 THE LD. DR RELIED ON THE ORDERS OF THE AUTHORITIES BELOW. 2.5 I HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. IT IS NOTED FROM THE RECORD TH AT THE ASSESSEE HAD RECEIVED THE FOLLOWING LOANS FROM HIS CLOSE RELATIV ES AND FAMILY MEMBERS ITA NO. 41/JP/2016 SHRI GULAB CHAND RAMCHANDANI VS. ITO , WARD- 2, BEA WAR . 7 NOT EXCEEDING RS. 20,000/- AT ONE TIME. HOWEVER, TH E TOTAL AMOUNTS OF THE LOANS TAKEN WAS AT RS. 2,83,500/-. NAME OF PARTY DATE MODE OF PAYMENT AMOUNT (RS.) KAILASH SANGTANI 01-04-2009 CASH 19,000/- REKHA SANGTANNI 03-04-2009 CASH 19,000/- - DO - 17-04-2009 CASH 19,000/- SNEH RAMCHANDANI 01-04-2009 CASH 19,000/- SUSHIL KUMAR RAMNANI 01-04-2009 CASH 19,000/- - DO - 02-04-2009 CASH 19,500/- SANGEETA RAMCHANDANI 05-04-2009 CASH 18,000/- - DO - 06-04-2009 CASH 19,000/- - DO - 07-04-2009 CASH 19,000/- - DO - 10-04-2009 CASH 19,000/- - DO - 13-04-2009 CASH 19,000/- - DO - 15-04-2009 CASH 19,000/- - DO - 25-10-2009 CASH 19,000/- SURESH RAMNANI 01-04-2009 CASH 19,000/- - DO - 02-04-2009 CASH 19,000/- TOTAL 2,83,500 THESE LOANS WERE TAKEN IN THE BUSINESS INTEREST AS THE ASSESSEE HAD STARTED A NEW VENTURE. THESE AMOUNTS WERE REPAID IN PARTS T O THE RESPECTIVE PERSONS WHICH CAN BE SEEN FROM THE BANK STATEMENT O F THE ASSESSEE. THE ASSESSEE WAS UNDER BONA FIDE BELIEF THAT THE LOAN A MOUNT OF LESS THAN RS. 20,000/- CAN BE TAKEN IN CASH AND IF IT IS EXCE EDED MORE THAN 20,000/- THEN IT WILL BE TAKEN EITHER THROUGH CHEQUE OR DEMA ND DRAFT. THUS THE ASSESSEE HAD TAKEN THE LOAN LESS THAN RS. 20,000/- FROM HIS CLOSE RELATIVES AND FAMILY MEMBERS FURTHER THE ASSESSEE IMMEDIATELY DEPOSITED THE AMOUNT IN BANK ACCOUNT FOR MAKING PAYMENT TO THE PA RTY. THE ITA NO. 41/JP/2016 SHRI GULAB CHAND RAMCHANDANI VS. ITO , WARD- 2, BEA WAR . 8 GENUINENESS OF THESE DEPOSITS WAS NEVER DOUBTED BY THE AO. IN SPITE OF ALL THESE FACTS AND CIRCUMSTANCES OF THE CASE, THE LOWER AUTHORITIES IMPOSED THE PENALTY OF RS. 2,83,500/- ON THE ASSESS EE U/S 271D OF THE ACT. IT IS FURTHER NOTED THAT ON SIMILAR TYPE OF IS SUE THE ITAT COORDINATE BENCH IN THE CASE OF SMT. KUSUM DHAMANI VS. ADDL. C IT VIDE ITS ORDER DATED 13-06-2014 IN ITA NO. 847/JP/2011 FOR THE ASS ESSMENT YEAR 2006- 07 DELETED THE PENALTY U/S 271D OF THE ACT BY OBSER VING AS UNDER:- 4.0 WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUS ED THE RELEVANT MATERIAL AVAILABLE ON RECORD. FROM THE REC ORD THERE IS NO SHRED OF DOUBT ABOUT THE GENUINENESS OF THE TRANSAC TIONS AND THEIR DISCLOSURE IN THE BOOKS OF ACCOUNT AND RETURNS OF B OTH THE ASSESSEE WHO HAPPEN TO BE HUSBAND AND WIFE, CARRYING ON THE BUSI NESS AS SISTER CONCERNS. SECTION 271D READ WITH SECTION 269SS WAS INTRODUCED BY THE LEGISLATURE TO DISCOURAGE THE MENACE OF BLACK MONEY . SINCE THESE TRANSACTIONS ARE GENUINE, THIS ELEMENT OF BLACK MON EY IS TOTALLY RULED OUT. THE ASSESSEE HAS GIVEN AN EXPLANATION IN OUR V IEW IS NOT UNREASONABLE AND IS BASED ON BUSINESS EXIGENCIES AL SO FOR PAYMENTS TO LABOURERS AND LENDERS. UNDER THESE CIRCUMSTANCES, W E ARE OF THE VIEW THAT THE TRANSACTIONS BEING GENUINE AND THE ASSESS EE HAVING OFFERED REASONABLE EXPLANATION JUSTIFYING THESE CASH TRANSA CTIONS, THE IMPUGNED PENALTY U/S 271D IS NOT LEVIABLE. OUR VIE W IS FORTIFIED BY THE JUDGEMENT OF HON'BLE JURISDICTIONAL HIGH COURT IN T HE CASE OF CIT VS. RAJ KUMAR SHARMA (SUPRA) AND THE JUDGEMENT OF HON'B LE PUNJAB & HARYANA HIGH COURT IN THE CASE OF CIT VS. SAINI MED ICAL STORE (SUPRA) WHICH IS FOLLOWED BY HON'BLE P & H HIGH COURT IN THE CASE OF CIT VS. SUNIL KUMAR GOEL (SUPRA). THUS IN VIEW OF THE FACTS AND CIRCUMSTANCES OF THE CASE AND THE DECISIONS RELIED ON ABOVE, THE PENALTY IS DELETED. RESPECTFULLY FOLLOWING THE DECISION OF ITAT COORDIN ATE BENCH IN THE CASE OF SMT. KUSUM DHAMANI VS. ADDL. CIT (SUPRA) AN D ALSO BEING THE SIMILAR FACTS AND CIRCUMSTANCES OF ASSESSEES CASE, I DIRECT TO DELETE THE ITA NO. 41/JP/2016 SHRI GULAB CHAND RAMCHANDANI VS. ITO , WARD- 2, BEA WAR . 9 PENALTY OF RS. 2,83,500/- U/S 271D OF THE ACT SUSTA INED BY THE LD. CIT(A) IN ASSESSEE'S CASE. THUS THE APPEAL OF THE ASSESSEE IS ALLOWED 3.0 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS A LLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 7 /11/2016 SD/- HKKXPUN ( BHAGCHAND) YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 7 /11/ 2016 *MISHRA VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SHRI GULAB CHAND RAMCHANDANI, BEAWAR 2. IZR;FKHZ@ THE RESPONDENT- THE ITO, WARD- 2, BEAWAR 3. VK;DJ VK;QDRVIHY@ CIT(A). 4. VK;DJ VK;QDR@ CIT, 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO. 41/JP/2016) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ @ ASSISTANT. REGISTRAR