Appeal details
Counselvise Citation
[2016] 132 COUNSELVISE.COM (IT) 2357 (ITAT-MUMBAI)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
2 year(s) 6 month(s) 8 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
29-07-2016
Appeal Filed By
Assessee
Order Result
Dismissed
Bench Allotted
E
Assessment Year
2008-2009
Appeal Filed On
20-01-2014
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH EMUMB AI BEFORE SHRI SANJAY ARORA, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER ITA NO.439/MUM/2014 ASSESSMENT YEAR: 2011-12 SHRI SHAILESH R. KOTHARI, C-33, MAHESHWARI MANSION, NEPEAN SEA ROAD, MUMBAI-400036. PAN: AGAPK7174K VS. ITO 16(2)(4), MATRU MANDIR, MUMBAI-400007. (APPELLANT) (RESPONDENT) ASSESSEE BY : SHRI HARI S. RAHE JA (AR) REVENUE BY : SHRI DEBABRATA BAID YA (DR) DATE OF HEARING : 09.05.2015 DATE OF ORDER : 29.07.2016 O R D E R PER PAWAN SINGH, JM: 1. THE PRESENT APPAL IS FILED BY THE ASSESSEE AGAINST THE ORDER OF CIT(A)- 27, MUMBAI DATED 19.11.2013 IN RESPECT OF ASSESSMEN T YEAR (AY) 2008-09. THOUGH THE ASSESSEE HAS RAISED AS MANY AS FOUR GROUNDS OF APPEAL BUT AS PER OUR OPINION GROUND NO.1 IS THE ON LY SUBSTANTIVE GROUND FOR OUR CONSIDERATION AND REST OF THE GROUND S ARE ARGUMENTATIVE OR FORMAL IN NATURE. 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E AND IN LAW THE CIT(A) ERRED IN CONFIRMING THE ADDITION 11,19,500/- FROM OUT OF THE ADDITION OF RS. 12,19,500/- MADE BY THE ASSESSING O FFICER. 2. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E AND IN LAW THE LEARNED CIT(A) HAS FAILED TO APPRECIATE THE CONTRIB UTION MADE BY THE 2 ITA NO.439/M/14- SHRI SHAILESH R. KOTHARI APPELLANT AND THE FAMILY MEMBERS FROM OUT OF THEIR PERSONAL WITHDRAWALS AS ALSO THE RE-DEPOSITS MADE BY THE APP ELLANT IN THE BANK ACCOUNT THUS HOLDING THAT THE APPELLANT WAS NOT ABL E TO JUSTIFY THE CASH CREDITS IN THE BANK ACCOUNT. 3. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E AND IN LAW THE LEARNED CIT(A) HAS FAILED TO APPRECIATE THAT THE CA SH ACCOUNT SUMMARY OF THE FAMILY MEMBERS FILED DURING THE APPELLATE ST AGE FULLY SUPPORT THE CLAIM OF THE APPELLANT. 4. THE APPELLANT CRAVES LEAVE TO, ADD TO, ALTER, MO DIFY, DELETE AND/OR CHANGE ALL OR ANY ABOVE GROUNDS OR BEFORE THE HEARI NG OF THE APPEAL. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE F ILED RETURN OF INCOME FOR RELEVANT AY ON 24.02.2008 DECLARING TOTAL INCOM E OF RS. 1,14,980/-. THE RETURN WAS SELECTED FOR SCRUTINY. DURING THE AS SESSMENT, THE ASSESSING OFFICER (AO) OBSERVED FROM THE AIR INFORM ATION THAT THERE IS A CASH DEPOSIT OF RS. 12,19,500/- IN ASSESSEES BANK ACCOUNT IN HSBC. THE ASSESSEE WAS ASKED TO DISCLOSE THE SOURCE OF THESE DEPOSITS. THE ASSESSEE SUBMITTED HIS REPLY THAT HIS FAMILY ME MBER CONTRIBUTED THE MONEY TO MEET THE GENERAL EXPENSES OF THE FAMIL Y. ALONG WITH HIS REPLY, THE ASSESSEE ENCLOSED THE BANK STATEMENT, CA PITAL ACCOUNT, BALANCE SHEET AND RELEVANT PAPER OF FAMILY MEMBER T O PROVE THE CONTRIBUTION TO THE ASSESSEE. IT WAS FURTHER CONTEN DED THAT CASH WAS GIVEN BY THE FAMILY MEMBER TO SPEND THROUGH CREDIT CARDS TO GET REWARD POINTS WHICH IS BENEFIT FOR FAMILY. THE CONTENTION OF ASSESSEE WAS NOT ACCEPTED BY THE AO AND THE WHOLE OF THE AMOUNT OF R S. 12,19,500/- WAS ADDED U/S. 68 OF THE ACT IN THE INCOME OF ASSES SEE IN ASSESSMENT ORDER DATED 31.12.2010. AGGRIEVED BY THE ORDER OF A O, THE ASSESSEE FILED APPEAL BEFORE THE CIT(A). THE CIT(A) AFTER CO NSIDERING THE CONTENTION OF ASSESSEE GRANTED PARTIAL RELIEF OF RS . 1,00,000/- OUT OF THE TOTAL ADDITION MADE OF RS. 12,19,500/- IN ITS ORDER DATED 19.11.2013, AGAINST WHICH THE PRESENT APPEAL IS FILED BY ASSESS EE BEFORE US. 3. WE HAVE HEARD AUTHORISED REPRESENTATIVE (AR) OF THE ASSESSEE SHRI HARI S. RAHEJA AND SHRI DEBABARATA (DR) FOR REVENUE . LD AR OF THE 3 ITA NO.439/M/14- SHRI SHAILESH R. KOTHARI ASSESSEE ARGUED THAT ALL THE DEPOSITS WERE MADE BY THE ASSESSEE IN HIS BANK ACCOUNT BY THE CONTRIBUTION OF FAMILY MEMBERS. THE CONTRIBUTION WAS MADE BY THE FAMILY MEMBERS TO MEET OUT THE REQU IREMENT OF HOUSE- HOLD EXPENSES. NO STATEMENT OF ACCOUNT OF INCOME IS MAINTAINED BY ANY OF THE FAMILY MEMBER. OTHERWISE THEY WERE NOT REQUI RED TO MAINTAIN THE BOOKS OF ACCOUNT UNDER THE LAW TO MAINTAIN THE BOOK S OF ACCOUNT. LD AR OF ASSESSEE FURTHER ARGUED THAT SIMILAR CONTRIBU TION WAS MADE IN PREVIOUS YEAR BUT NO ADDITION WAS MADE IN ASSESSMEN T IN RESPECT OF AY 2007-08. LD DR FOR THE REVENUE ARGUED THAT THE ASS ESSEE FAILED TO PROVE THE CREDITWORTHINESS OF THE FAMILY MEMBERS WH O ALLEGEDLY MADE CONTRIBUTION FOR DEPOSIT OF THE AMOUNT IN ASSESSEE S BANK. THE CONFIRMATIONS FILED BY THE ASSESSEE ARE FABRICATED ONE AND DOES NOT BEAR EVEN THE DATE OF CONFIRMATION. THE DOCUMENT FILED B Y ASSESSEE DOES NOT CORROBORATE THE CONTENTION OF THE ASSESSEE AND ARGU ED THAT THE ORDERS OF AUTHORITIES BELOW ARE BASED ON THE FACTUAL POSITION AND NEEDS NO INTERFERENCE. 4. WE HAVE CONSIDERED THE RIVAL CONTENTION OF THE LD A RS FOR PARTIES AND GONE THROUGH THE MATERIAL AVAILABLE ON RECORD. DUR ING THE ASSESSMENT PROCEEDINGS, WHILE CONSIDERING THE CONTENTION OF TH E ASSESSEE THE AO CONCLUDED THAT THE STATEMENT OF CREDIT CARD AND THE EXPENSES ARE NOT OF THE NATURE OF GENERAL HOUSE-HOLD EXPENSES BUT RELAT ED TO RESTAURANT BILLS, ENTERTAINMENT AND OTHER PERSONAL EXPENSES. THE AO C ONCLUDED THAT, NO DOUBT THAT ASSESSEE HAS INCOME FROM UNEXPLAINED SOU RCE WHICH HAS BEEN DEPOSITED IN HIS ACCOUNT. THE ASSESSEES CLAIM IS NOT SUBSTANTIATED FROM THE STATEMENT OF BANK ACCOUNT ITSELF, AS TOTAL CREDIT CARD EXPENSES OF RS. 2,07,382/- ONLY. AS SUCH, THE ASSESSEES CON TENTION THAT DEPOSITS WERE MADE OUT OF THE CONTRIBUTION FROM THE WITHDRAW AL OF FAMILY MEMBERS TO MEET OUT GENERAL EXPENSES IS NOT PROVED. AND THE WHOLE OF 4 ITA NO.439/M/14- SHRI SHAILESH R. KOTHARI THE AMOUNT WAS ADDED U/S. 68 OF THE ACT IN THE INCO ME OF ASSESSEE. THE CIT(A) AFTER CONSIDERING THE CONTENTIONS OF THE ASS ESSEE, ELABORATELY DEALT WITH EACH AND EVERY CONTENTION OF THE ASSESSE E. ON THE ASSESSEES REQUEST FOR BEING ALLOWED OPPORTUNITY TO SUBSTANTIA TE HIS CASE, THE LD. CIT(A) SOUGHT REMAND REPORT FROM THE AO TWICE. THIS , DESPITE THE ASSESSEE TAKING DIFFERENT AND INCONSISTENT STANDS A T DIFFERENT TIMES. DURING THE APPELLATE PROCEEDING, THE ASSESSEE FURNI SHED CONFIRMATION LETTER FROM THE FAMILY MEMBERS ALONG WITH THE COMPU TATION OF INCOME, ACKNOWLEDGEMENT OF INCOME TAX RETURN IN RESPECT OF SMT. SUSHILA KOTHARI, ANITA KOTHARI, RAKESH KOTHARI, PRAKASH KOT HARI AND TRIPTI KOTHARI. MISS. NEHA AND TANYA WERE NOT ASSESSED TO TAX AND WERE NOT FILED RETURN OF INCOME AS EXPLAINED BY ASSESSEE ON FURNISHING OF SUCH DETAIL, CIT(A) SEEK TO REMAND REPORT WHEREIN THE AO FURNISHED HIS REPORT AS UNDER: A) SMT. ANITA R. KOTHARI (PAN-AJLPK0583G) THE AS SESSEE HAS CONTENDED THAT SMT. ANITA R. KOTHARI HAS GIVEN OF R S. 1,07,000/- TO THE ASSESSEE WITHDRAWING CASH FROM DEN A BANK. IN THIS REGARDS, THE ASSESSEE HAS FILED CONFIRMATION OF RS. 1,07,000/-, THE BANK PASS BOOK OF THE SAID BANK AND RETURN OF INCOME FOR A. Y. 2007-0 8 & 2008-09. ON PERUSAL OF THE RETURN OF INCOME FOR A.Y. 2008-09, I T IS SEEN THAT UNDER THE HEAD INCOME FROM HOUSE PROPERTY, SMT. ANITA R. KOTHARI HAS RECEIVED RENT OF RS.2,10,000/- DURING THE YEAR, THE COPY OF RENT AGREEMENT FOR THE PERIOD 05.11.2007 TO 4.10.2008 HA S BEEN SUBMITTED BY THE ASSESSEE. FURTHER, SMT. ANITA R. KOTHARI HAS RECEIVED OF RS. 20, 000/- FROM TAILORING WORK, AND RS. 10,000/- FROM TU ITION FEES. THE ASSESSEE HAS ALSO RECEIVED BANK INTEREST OF RS.38, INTEREST ON PPF OF RS.2668/- & DIVIDEND OF RS.9,301/-. (B) SMT. NEHA KOTHARI (PAN-AFRPJ2437C) THE ASSESS EE HAS CONTENDED THAT SMT. NEHA KOTHARI HAS GIVEN OF RS. 5 0,000/- TO THE ASSESSEE. IN THIS REGARDS, THE ASSESSEE HAS FILED C ONFIRMATION. HOWEVER, THE ASSESSEE HAS NOT FILED ANY RETURN OF INCOME FOR THE RELEVANT A. Y. AND ANY BANK PASS BOOK. HENCE, IT IS NOT ASCERTAINE D THE SOURCE OF INCOME OF THE SAID FAMILY MEMBER. C) PRAKASH KOTHARI- (PAN-AHUPK6108N)- THE ASSESEE H AS CONTENDED THAT SHRI. PRAKASH KOTHARI HAS GIVEN OF RS.1,99,300 /- TO THE ASSESSEE WITHDRAWING CASH FROM DENA BANK. IN THIS REGARDS, T HE ASSESSEE HAS FILED CONFIRMATION OF RS. 1,99,300/-. THE ASSESSEE HAS FILED ONLY ACKNOWLEDGE OF RETURN OF INCOME FOR A.Y.2008-09 DEC LARING TOTAL INCOME OF RS.2,16,390/- AND BANK PASS BOOK. HENCE, IT IS NOT ASCERTAINED THE SOURCE OF INCOME OF THE SAID FAMILY MEMBER. 5 ITA NO.439/M/14- SHRI SHAILESH R. KOTHARI D) SUSHILA R. KOTHARI (PAN-AEPPK8136A) - THE ASSESE E HAS CONTENDED THAT SMT. SUSHILA R. KOTHARI HAS GIVEN OF RS. 28,000/- TO THE ASSESSEE WITHDRAWING CASH FROM ORIENTAL BANK OF COM MERCE. IN THIS REGARDS, THE ASSESSEE HAS FILED CONFIRMATION OF RS. 3,28, 000/-, THE BANK PASS BOOK OF THE SAID BANK AND RETURN OF INCOME FOR A.Y. 2007-08 & 2008- 09. ON PERUSAL OF THE RETURN OF INCOME FOR A. Y. 2008-09, IT IS SEEN THAT UNDER THE HEAD INCOME FROM HOUSE PROPERTY , SMT. SUSHILA R. KOTHARI HAS SHOWN GROSS RENT OF RS.2,28,000/- OUT O F WHICH RECEIVED OF RS.2,10,000/- AND ADVANCE RENT OF RS. 18,000/- DURI NG THE YEAR, THE COPY OF RENT AGREEMENT FOR 11 MONTH COMMENCING FROM 01.0 5.2007 HAS BEEN SUBMITTED BY THE ASSESSEE. FURTHER, SMT. SUSHILA R. KOTHARI HAS RECEIVED BANK INTEREST OF RS.34/- AND INTEREST ON P PF OF RS. 1,054/-. E) RAKESH R. KOTHARI- (PAN- AADPK6323K)- THE ASSESE E HAS CONTENDED THAT SHRI. RAKESH R. KOTHARI HAS GIVEN OF RS. 48,000/- TO THE ASSESSEE WITHDRAWING CASH FROM DENA BANK. IN THIS R EGARDS, THE ASSESSEE HAS SUBMITTED RETURN OF INCOME FOR A. Y. 2 007-08 & 2008-09. ON PERUSAL OF THE RETURN OF INCOME FOR A. Y. 2008-0 9, IT IS SEEN THAT UNDER THE HEAD INCOME FROM OTHER SOURCES, SHRI RAKE SH R. KOTHARI HAS RECEIVED COMMISSION & BROKERAGE OF RS. 1,53,460/-, BANK INTEREST OF RS.46/- AND INTEREST ON PPF OF RS.1020/-. HOWEVER, THE ASSESSEE HAS NOT FILED ANY CONFIRMATION OF THE CASH OF RS. 48,000/- GIVEN TO THE ASSESSEE. F) TANYA KOTHARI - THE ASSESEE HAS CONTENDED THAT S MT. TANYA KOTHARI HAS GIVEN OF RS. 1,53,000/- TO THE ASSESSEE. HOWEVE R, THE ASSESSEE HAS NOT FILED ANY CONFIRMATION OF THE CASH OF RS. 1,53, 000/- GIVEN TO THE ASSESSEE, RETURN OF INCOME FOR THE RELEVANT A.Y. AN D ANY BANK PASS BOOK. HENCE, IT IS NOT ASCERTAINED THE SOURCE OF IN COME OF THE SAID FAMILY MEMBER. G) TRIPTI KOTHARI- THE ASSESEE HAS CONTENDED THAT S MT. TRIPTI KOTHARI HAS GIVEN OF RS.41,000/- TO THE ASSESSEE. IN THIS R EGARDS, THE ASSESSEE HAS SUBMITTED RETURN OF INCOME FOR A.Y. 2008-09. ON PERUSAL OF THE RETURN OF INCOME FOR A.Y.2008-09, IT IS SEEN THAT U NDER THE HEAD INCOME FROM OTHER SOURCES, SMT. TRIPTI KOTHARI HAS RECEIVE D RENT FROM COMPUTER OF RS.94,000/-, RS.67,820/- FROM TAILORING WORK, RS.22, 630/- FROM TUITION FEES AND BANK INTEREST OF RS. 76/- RES PECTIVELY. HOWEVER, THE ASSESSEE HAS NOT FILED ANY CONFIRMATION OF THE CASH OF RS.41,000/- GIVEN TO THE ASSESSEE. H) WITH RESPECT TO THE ASSESSEE'S INCOME FROM BROKE RAGE AND COMMISSION, IT IS SUBMITTED BY THE ASSESSEE THAT NO ONE IS WILLING TO GIVE THE CONFIRMATION. HOWEVER SOME CONFIRMATIONS H AS BEEN OBTAINED AND SUBMITTED HEREWITH. ON VERIFICATIONS OF THE SAI D CONFIRMATIONS, IT IS OBSERVED THAT THE COMMISSION OF RS. 14,800/- AND RS . 19,500/- HAS BEEN RECEIVED BY THE ASSESSEE FROM M/S A NARANDAS JEWELL ERS. HOWEVER, NO OTHER SUPPORTING CONFIRMATIONS HAVE BEEN PRODUCED B Y THE ASSESSEE AS DECLARED COMMISSION/BROKERAGE INCOME IN THE RETURN OF INCOME. 5. IN REMAND PROCEEDINGS, THE ASSESSEE WAS GIVEN OPPOR TUNITY TO FILE HIS REPLY/REJOINDER. ACCORDINGLY, THE SAME WAS FILED BY THE ASSESSEE AND AFTER CONSIDERING THE REMAND REPORT AND THE REPLY O F ASSESSEE, THE LD. 6 ITA NO.439/M/14- SHRI SHAILESH R. KOTHARI CIT(A) SUMMARIZED/TABULATED THE ALLEGED PAYMENTS WH ICH WERE STATED AS ADVANCED BY THE FAMILY MEMBERS ON THE BASIS OF T HE WITHDRAWAL AS PER CAPITAL ACCOUNT AND THE CASH WITHDRAWAL, AS UND ER:- SR. NO. NAME OF THE FAMILY MEMBER AMOUNT ALLEGED TO HAVE BEEN ADVANCED (RS.) WITHDRAWAL AS PER CAPITAL ACCOUNT (RS.) CASH WITHDRAWAL AS PER BANK ACCOUNT (RS.) 1 ANITA KOTHARI 1,07,000 95,000 3,64,000 2 PRAKASH KOTHARI 1,99,300 DETAILS NOT FILED 2,22, 320 3 SUSHILA KOTHARI 3,28,000 28,000 4,53,000 4 RAKESH KOTHARI 48,000 85,000 DETAILS NOT FILED 5 TRIPTI KOTHARI 41,000 80,000 DETAILS NOT FILED 6 NEHA KOTHARI 50,000 NO RETURN FILED DETAILS NOT FILED 7 TANYA KOTHARI 1,53,000 NO RETURN FILED DETAILS N OT FILED 6. AFTER PERUSAL OF THE CAPITAL ACCOUNT OF THE FAMILY MEMBERS OF ASSESSEE, THE LD. CIT(A) CONCLUDED THAT NOWHERE ADVANCES TO T HE ASSESSEE HAD BEEN REFLECTED IN THE SAID STATEMENT AS WELL AS IN THE BALANCE-SHEETS. HOWEVER, THE LOANS AND ADVANCES GIVEN TO OTHER MEMB ERS OF THE FAMILY WERE DULY REFLECTED. THE CIT(A) FURTHER NOTICED THA T IN CASE OF ANITA KOTHARI, THE BALANCE-SHEET AS ON 31.03.2008 REFLECT ED LOANS AND ADVANCES OF RS. 2,13,000/- TO SHRI PRAKASH KOTHARI ,WHEREAS NOTHING HAS BEEN SHOWN IN RESPECT OF THE ASSESSEE IN THE BA LANCE-SHEET OF SUSHILA KOTHARI AS ON 31.03.2008. LOAN (OR ADVANCE) OF RS. 10,000/- HAS BEEN NOTED IN RESPECT OF ONE PERSON, NAMELY, SU BHASH, AND NO MENTION IS MADE OF THE ASSESSEE. THE BALANCE-SHEET OF RAKESH KOTHARI ON 31.03.2008 REFLECTS A LOAN AND ADVANCE OF RS. 1, 80,000/- TO SHRI PRAKASH KOTHARI, BUT AGAIN THERE WAS NO MENTION THE REIN IN RESPECT OF THE ASSESSEE. THE LD CIT(A) FURTHER NOTICED THAT FR OM THE CONDUCT OF FAMILY MEMBERS WHILE PREPARING BALANCE-SHEET AND CA PITAL GIVEN, NO ADVANCES HAVE BEEN SHOWN TO HAVE BEEN MADE TO THE A SSESSEE. AND IT WAS ONLY WHEN THE ASSESSEE FAILED TO PROVE THE SOUR CE OF THE CASH DEPOSITS IN HIS BANK ACCOUNT, THAT SUCH AN EXPLANAT ION STANDS ADVANCED. 7 ITA NO.439/M/14- SHRI SHAILESH R. KOTHARI IN OTHER WORDS, THE ASSESSEES EXPLANATION IS AN AF TERTHOUGHT AND, FURTHER, COMPLETELY UN-EVIDENCED; RATHER, DISPROVED . IN ARRIVING AT SUCH A CONCLUSION, THE LD CIT(A) ALSO EXAMINED THE CASH WITHDRAWAL MADE BY DIFFERENT FAMILY MEMBERS (OF THE ASSESSEE) AS WE LL AS ITS UTILIZATION, INCLUDING BY WAY OF CASH DEPOSITS (IN THEIR BANK AC COUNTS). TO FIND NO SUBSTANCE IN THE ASSESSEES EXPLANATIONS, WHICH WER E THUS CONSIDERED BY HIM AS MERE BALD STATEMENTS. NO MATERIAL TOWARD ESTABLISHING THE CREDITWORTHINESS OF THE ALLEGED DEPOSITORS, OR EVEN A NEXUS BETWEEN THE IMPUGNED DEPOSITS AND THE STATED SOURCE THEREOF, HA S BEEN BROUGHT ON RECORD AT ANY STAGE, I.E. INCLUDING BEFORE US. IN F ACT, CONSIDERING THE CASH WITHDRAWALS BY THE FAMILY MEMBERS, WE OBSERVE THAT THE LD. CIT(A) HAS ALREADY ALLOWED RELIEF OF RS. 1,00,000/- TO THE ASSESSEE. 7. IN VIEW OF THE FOREGOING, WE FIND NO INFIRMITY IN T HE ORDER BY THE LD. CIT(A) NOR HAS ANY BEEN BROUGHT TO OUR NOTICE. WE, ACCORDINGLY UPHOLD HIS ORDER, AND THE APPEAL OF THE ASSESSEE IS DISMIS SED. 8. IN THE RESULT, THE ASSESSEES APPEAL IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON THIS 29 TH JULY, 2016. SD/- SD/- (SANJAY ARORA) (PAWAN SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER MUMBAI; DATED 29/07/2016 S.K.PS / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT. 3. ( ) / THE CIT(A), MUMBAI. 4. / CIT 5. , , / DR, ITAT, MUMBAI 6. !'# / GUARD FILE. 8 ITA NO.439/M/14- SHRI SHAILESH R. KOTHARI / BY ORDER, / (ASSTT.REGISTRAR) , / ITAT, MUMBAI $ //TRUE COPY/
