HINDUSTAN ORGANIC CHEMICALS LTD, MUMBAI V. ASST CIT CIR 4(2), MUMBAI

ITA 4840/MUM/2011

• Counselvise Citation: [2012] 119 COUNSELVISE.COM (IT) 9047 (ITAT-MUMBAI)
• Duration Of Justice: 1 year(s) 6 month(s) 11 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 28-12-2012
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: E
• Next Hearing Date: 30-11-2012
• Assessment Year: 2003-2004
• Appeal Filed On: 16-06-2011
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: GIRIJA DAYAL
• Keywords: Depreciation
• Section: 43B

Judgement Text

, IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES E MUMBAI . , / BEFORE SHRI D. MANMOHAN, VICE PRESIDENT /AND !'# , ! . . SHRI RAJENDRA, ACCOUNTANT MEMBER . / ITA NO. 4839/MUM/2011 % % % % / ASSESSMENT YEAR 1999-2000 M/S. HINDUSTAN ORGANIC CHEMICALS LIMITED, HARICHANDRAI HOUSE, 81, M.K. ROAD, MARINE LINES MUMBAI-400 002. PAN: AAACH 2663 P VS. ASST. COMMISSIONER OF INCOME TAX, CIR.4(2) MUMBAI. . / ITA NO. 4840/MUM/2011 % % % % / ASSESSMENT YEAR 2003-04 M/S. HINDUSTAN ORGANIC CHEMICALS LIMITED, HARICHANDRAI HOUSE, 81, M.K. ROAD, MARINE LINES MUMBAI-400 002. PAN: AAACH 2663 P VS. ASST. COMMISSIONER OF INCOME TAX, CIR.4(2) MUMBAI. . / ITA NO. 4841/MUM/2011 % % % % / ASSESSMENT YEAR 2004-05 M/S. HINDUSTAN ORGANIC CHEMICALS LIMITED, HARICHANDRAI HOUSE, 81, M.K. ROAD, MARINE LINES MUMBAI-400 002. PAN: AAACH 2663 P VS. ASST. COMMISSIONER OF INCOME TAX, CIR.4(2) MUMBAI. ( &' / APPELLANT ) ( ()&' / RESPONDENT ) APPELLANT BY : SHRI K. GOPAL RESPONDENT BY : SHRI GIRIJA DAYAL (CIT DR) DATE OF HEARING : 30-11-2012 DATE OF PRONOUNCEMENT : 28-12-2012 ITA NO. 4839/MUM/2011 ITA NO. 4840/MUM/2011 ITA NO. 4841/MUM/2011 M/S. HINDUSTAN ORGANIC CHEMICALS LTD. 2 *!+ / O R D E R PER RAJENDRA, A.M. FOLLOWING GROUNDS OF APPEAL HAVE BEEN FILED BY THE ASSESSEE AGAINST THE ORDERS DT. 26-04-2011 OF THE CIT(A)-8, MUMBAI: ITA NO.4839/M/11 AY-1999-2000 1.THE LD. COMMISSIONER OF INCOME TAX (APPEALS) [HER EINAFTER REFERRED TO AS CIT(A)] ERRED IN CONFIRMING THE ACTION OF THE A.O. IN LEVYING PEN ALTY OF RS.57,55,260/- UNDER SECTION 271(1)(C) OF THE ACT WITHOUT APPRECIATING THE FACT AND CIRCUMSTANCES OF THE CASE. THE APPELLANT, THEREFORE, SUBMITS THAT THE LEVY OF CONC EALMENT PENALTY UNDER SECTION 271(1)(C) IS NOT AT ALL JUSTIFIED AND THE SAME MAY BE DELETED. 2.THE LD. CIT (A) ERRED IN CONFIRMING THE ORDER OF THE LD. A.O. TREATING THE FOLLOWING ADDITIONS AND DISALLOWANCE AS CONCEALMENT OF INCOME OF THE APPELLANT: SR.NO. PARTICULARS AMOUNT (RS.) A DISALLOWANCE OF DEPRECIATION ON DECAPITALISATION O F ASSET 44,34,346 B ADDITION ON ACCOUNT OF VALUATION OF EUTECTIC OIL 13,00,000 C DISALLOWANCES OF DEPRECIATION ON PLANT NOT IN ACTIV E USE 29,08,253 D ADDITIONS ON ACCOUNT OF PRIOR PERIOD EXPENSES 78,01,100 3. THE LD. CIT(A) FAILED TO APPRECIATE THAT THE APP ELLANT HAS NEITHER CONCEALED ANY PARTICULARS OF INCOME NOR FURNISHED ANY INACCURATE PARTICULARS OF INCOME. THEREFORE, THE LEVY OF CONCEALMENT PENALTY OF RS.57,55,260/- UNDER SECT ION 271(1)(C) IS UNJUSTIFIED AND THE SAME MAY BE DELETED. 4. THE LD. CIT(A) FAILED TO APPRECIATE, THAT ALL IN FORMATION / DETAILS WITH RESPECT TO THE ABOVE CLAIMS, WERE FURNISHED BY THE APPELLANT IN ITS ACCO UNTS, WHICH WERE FILED ALONG WITH THE RETURN OF INCOME. HENCE, LEVY OF CONCEALMENT PENALTY OF R S.57,55,260/- UNDER SECTION 271(1)(C) IS UNJUSTIFIED AND THE SAME MAY BE DELETED. 5. THE LD. CIT(A) FURTHER FAILED TO APPRECIATE, THA T THE APPELLANT HAS FURNISHED BONA-FIDE EXPLANATION WITH RESPECT TO EACH ITEMS OF ADDITIONS / DISALLOWANCES MADE, DURING THE COURSE OF THE ASSESSMENT AS WELL AS PENALTY PROCEEDINGS, W HICH HAS NOT BEEN FOUND TO BE FALSE. HENCE, LEVY OF CONCEALMENT PENALTY OF RS.57,55,260/ - UNDER SECTION 271(1) (C) OF THE ACT IS NOT JUSTIFIED AND THE SAME MAY BE DELETED. 6. THE APPELLANT CRAVES LEAVE TO ADD, ALTER OR AMEN D ANY OF THE ABOVE GROUNDS OF APPEAL. ITA NO.4840/M/11 AY-2003-04 1. THE LD. COMMISSIONER OF INCOME-TAX (APPEALS) [HE REINAFTER REFERRED TO AS CIT(A)] ERRED IN CONFIRMING THE ACTION OF THE A.O. IN LEVYI NG PENALTY OF RS.6,07,26,681/- UNDER SECTION 271(1)(C) OF THE ACT WITHOUT APPRECIATING THE FACT AND CIRCUMSTANCES OF THE CASE. THE APPELLANT, THEREFORE, SUBMITS THAT THE LEVY OF CONC EALMENT PENALTY UNDER SECTION 271(1)(C) IS NOT AT ALL JUSTIFIED AND THE SAME MAY BE DELETED. ITA NO. 4839/MUM/2011 ITA NO. 4840/MUM/2011 ITA NO. 4841/MUM/2011 M/S. HINDUSTAN ORGANIC CHEMICALS LTD. 3 2. THE LD. CIT (A) ERRED IN CONFIRMING THE ORDER OF THE LD. A.O. TREATING THE FOLLOWING ADDITIONS AND DISALLOWANCE AS CONCEALMENT OF INCOME OF THE APPELLANT: SN. PARTICULARS AMOUNT (RS.) A ADDITION ON ACCOUNT OF REVERSAL OF EXCESS LIABILITY 4,32,51,564 B ADDITIONS ON ACCOUNT OF PRIOR PERIOD EXPENSES 1,10,19,632 C ADDITION ON ACCOUNT OF VALUATION OF EUTECTIC OIL 12,70,000 D DISALLOWANCES OF PF/VPF/PENSION PAID BEYOND GRACE P ERIOD UNDER SECTION 43B 76,17,656 E ADDITION ON ACCOUNT OF LOANS AND ADVANCES WRITTEN O FF 6,35,000 F DISALLOWANCE OF DEPRECIATION ON RESEARCH AND DEVELO PMENT EQUIPMENT 8,18,57,646 G DISALLOWANCE OF DEPRECIATION ON RESEARCH AND DEVELO PMENT EQUIPMENT 47,46,477 H DISALLOWANCE OF DIRECT EXPENSES U/S. 145A 87,83,980 3. THE LD. CIT(A) FAILED TO APPRECIATE THAT THE APP ELLANT HAS NEITHER CONCEALED ANY PARTICULARS OF INCOME NOR FURNISHED ANY INACCURATE PARTICULARS OF INCOME. THEREFORE, THE LEVY OF CONCEALMENT PENALTY OF RS.6,07,26,681/-UNDER SEC TION 271(1)(C) IS UNJUSTIFIED AND THE SAME MAY BE DELETED. 4. THE LD. CIT(A) FAILED TO APPRECIATE, THAT ALL IN FORMATION / DETAILS WITH RESPECT TO THE ABOVE CLAIMS, WERE FURNISHED BY THE APPELLANT IN ITS ACCO UNTS, WHICH WERE FILED ALONG WITH THE RETURN OF INCOME. HENCE, LEVY OF CONCEALMENT PENALTY OF RS .6,07,26,681/-UNDER SECTION 271(1)(C) IS UNJUSTIFIED AND THE SAME MAY BE DELETED. 5. THE LD. CIT(A) FURTHER FAILED TO APPRECIATE, THA T THE APPELLANT HAS FURNISHED BONA-FIDE EXPLANATION WITH RESPECT TO EACH ITEMS OF ADDITIONS / DISALLOWANCES MADE, DURING THE COURSE OF THE ASSESSMENT AS WELL AS PENALTY PROCEEDINGS, W HICH HAS NOT BEEN FOUND TO BE FALSE. HENCE, LEVY OF CONCEALMENT PENALTY OF RS.6,07,26,68 1/- UNDER SECTION 271(1) (C) OF THE ACT IS NOT JUSTIFIED AND THE SAME MAY BE DELETED. 6. THE APPELLANT CRAVES LEAVE TO ADD, ALTER OR AMEND ANY OF THE ABOVE GROUNDS OF APPEAL. ITA NO.4841/M/11 AY-2004-05 1. THE LD. COMMISSIONER OF INCOME-TAX (APPEALS) [HE REINAFTER REFERRED TO AS CIT(A)] ERRED IN CONFIRMING THE ACTION OF THE A.O. IN LEVYI NG PENALTY OF RS.63,23,419/ UNDER SECTION 271 (1) (C) OF THE ACT WITHOUT APPRECIATING THE FAC T AND CIRCUMSTANCES OF THE CASE. THE APPELLANT, THEREFORE SUBMITS THAT THE LEVY OF CONCE ALMENT PENALTY UNDER SECTION 271(1)(C) IS NOT AT ALL JUSTIFIED AND THE SAME MAYBE DELETED. 2. THE LD. CIT (A) ERRED IN CONFIRMING THE ORDER OF THE LD. A.O. TREATING THE FOLLOWING ADDITIONS AND DISALLOWANCE AS CONCEALMENT OF INCOME OF THE APPELLANT: ITA NO. 4839/MUM/2011 ITA NO. 4840/MUM/2011 ITA NO. 4841/MUM/2011 M/S. HINDUSTAN ORGANIC CHEMICALS LTD. 4 SR.NO. PARTICULARS AMOUNT (RS.) A DISALLOWANCE OF DEPRECIATION ON DECAPITALISATION O F ASSET 10,52,291 B ADDITIONS ON ACCOUNT OF PRIOR PERIOD EXPENSES 1,10,49,240 C ADDITION ON ACCOUNT OF VALUATION OF EUTECTIC OIL 10,87,068 D DISALLOWANCES OF UN PAID INTEREST SECTION 43B 44,37,656 3. THE LD. CIT(A) FAILED TO APPRECIATE THAT THE APP ELLANT HAS NEITHER CONCEALED ANY PARTICULARS OF INCOME NOR FURNISHED ANY INACCURATE PARTICULARS OF INCOME. THEREFORE, THE LEVY OF CONCEALMENT PENALTY OF RS.63,23,419/-UNDER SECTI ON 271(L)(C) IS UNJUSTIFIED AND THE SAME MAY BE DELETED. 4. THE LD. CIT(A) FAILED TO APPRECIATE, THAT ALL IN FORMATION / DETAILS WITH RESPECT TO THE ABOVE CLAIMS, WERE FURNISHED BY THE APPELLANT IN ITS ACCO UNTS, WHICH WERE FILED ALONG WITH THE RETURN OF INCOME. 2. ASSESSEE-COMPANY, A PUBLIC SECTOR UNDERTAKING, IS E NGAGED IN THE BUSINESS OF MANUFACTURING OF BASIC CHEMICALS AND CHEMICAL INTER MEDIATES. DETAILS OF FILING OF RETURN, RETURNED INCOME, ASSESSED INCOME AND PENALT Y IMPOSED BY THE ASSESSING OFFICER (AO) CAN BE SUMMARISED AS UNDER: ITA NO. & A.Y. DATE OF FILING OF RETURN RETURN INCOME ASSESSED INCOME PENALTY IMPOSED BY THE AO 4839/M/11 1999-2000 31-12-1999 (-)57.14 CR. (-)50.97 CR. 57.55 LAKHS 4840/M/11 2003-04 25-11-2003 (-)22.60 CR. (-)4.58 CR. 6.07 CR. 4841/M/11 2004-05 01-11-2004 (-)55.79 CR. 51 CR. 63.23 LAKHS 3. DURING THE ASSESSMENT PROCEEDINGS, AO MADE VARIOUS ADDITIONS/DISALLOWANCES TO THE INCOMES RETURNED BY THE ASSESSEE FOR ALL THE THREE YEARS. ASSESSEE CHALLENGED A FEW ADDITIONS/DISALLOWANCES BEFORE THE FIRST APPELL ATE AUTHORITY (FAA) AND THE TRIBUNAL FOR THE RESPECTIVE AYS. MEANWHILE, AO ISS UED PENALTY NOTICES U/S.271(1) (C) R.W.S.274 OF THE ACT TO THE ASSESSEE FOR IMPOSI NG PENALTY FOR CONCEALMENT OF INCOME/AND FURNISHING INACCURATE PARTICULARS FOR TH E RESPECTIVE YEARS. AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESSEE-COMPANY , HE LEVIED PENALTY AS PER THE CHART GIVEN ABOVE. PENALTY ORDERS DT. 30-04-2010, P ASSED BY THE AO, WERE CHALLENGED BEFORE THE FAA, WHO VIDE HIS ORDER DT. 26-04-2011 D ECIDED ALL THE THREE APPEALS AGAINST THE ASSESSEE-COMPANY. 4. BEFORE US AUTHORISED REPRESENTATIVE SUBMITTED THAT PENALTY SHOULD NOT HAVE BEEN LEVIED JUST BECAUSE ADDITIONS/DISALLOWANCES WE RE MADE/CONFIRMED BY THE AO/APPELLATE AUTHORITIES, THAT SUBMISSIONS MADE BY THE APPELLANT DURING THE PENALTY PROCEEDINGS WERE NOT DEALT WITH BY THE AO/FAA. HE RELIED UPON THE CASE OF RELIANCE PETRO PRODUCTS (P)LTD.(322ITR158) DELIVERED BY THE HONBLE SUPREME COURT. HE ALSO RELIED UPON THE CASES OF ADITYA BIRLA NOVA LTD. (20 12-TIOL-692), VIP INDUSTRIES (122TTJ 289) JANKAR SHROFFIN (P) LTD. (48SOT113). DEPARTMENTAL REPRESENTATIVE ITA NO. 4839/MUM/2011 ITA NO. 4840/MUM/2011 ITA NO. 4841/MUM/2011 M/S. HINDUSTAN ORGANIC CHEMICALS LTD. 5 (DR) RELIED UPON THE ORDER OF THE FAA. 5. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. WHILE GOING THROUGH THE ORDERS OF THE AO I MPOSING PENALTY OF RS. 7.27 CRORES (RS. 57. 55 LAKHS + 6.07CRORES + 63.23LAKHS) WE HAVE NOTICED THAT AO HAS NOT DEALT WITH THE SUBMISSIONS THAT WERE MADE BY THE AS SESSEE IN RESPONSE TO THE NOTICES ISSUED FOR IMPOSING PENALTY. PENALTY ORDERS FOR AL L THE THREE AYS ARE IDENTICAL EXCEPT FOR THE FIGURES OF VARIOUS ADDITIONS/DISALLOWANCES MADE AND AMOUNT OF PENALTY IMPOSED. BUT, HE HAS NOT DEALT WITH THE BASIC ISSU E AS WHAT WERE THE PARTICULARS WHICH WERE CONCEALED OR WHICH WERE INACCURATE FOR THE AYS .1999-2000, 2003-04 AND 2005- 05. IN OTHER WORDS, HE HAS IMPOSED PENALTY WITHOUT DISCUSSING ANYTHING ABOUT THE ISSUES RAISED BY THE ASSESSEE-COMPANY DURING PENALT Y PROCEEDINGS. 5.1. SIMILAR IS THE POSITION OF THE ORDERS OF THE FAA PA SSED ON 26.04.2011.AFTER NARRATING THE FACTS OF THE CASES IN A SUMMARY MANNE R, HE HAS CONFIRMED PENALTY AMOUNTING TO RS. 7.27 CRORES VIDE PARAGRAPHS 1.1.AND 1.2 OF HIS ORDERS. WE FIND THAT ADDITIONS / DISALLOWANCES MADE BY THE AO ARE NOT ID ENTICAL FOR ALL THE THREE YEARS. ISSUES OF VALUATION OF EUTECTIC OIL AND PRIOR PERIO D EXPENSES ARE COMMON FOR ALL THE THREE AYS., WHEREAS ISSUE OF DEPRECIATION ON DECAP ITALISED ASSETS FINDS PLACE IN THE ORDERS OF THE AYS.1999-2000 AND AY.2004-05 ONLY. W E FIND THAT APPELLANT-COMPANY HAD MADE SUBMISSIONS ABOUT HALF A DOZEN OTHER ISSUE S DURING THE APPELLATE PROCEEDINGS. IN OUR OPINION ALL THESE ISSUES SHOUL D HAVE BEEN DEALT INDEPENDENTLY IN RESPECTIVE AYS-SPECIALLY IN THE AY 2003-04 WHERE PE NALTY OF RS.6.07 CRORES HAS BEEN CONFIRMED BY THE FAA. 5.2. AS PER THE PRACTICE FOLLOWED BY THE FAAS, FOR A COM MON ISSUE APPEARING IN MORE THAN ONE AY, A SPEAKING ORDER IS PASSED FOR ON E YEAR AND SAME IS FOLLOWED IN OTHER ASSESSMENT YEARS. BUT, FOR INDEPENDENT ISSUE /(S),WHICH IS/ARE NOT COMMON SEPARATE REASONED ORDERS ARE PASSED IN RESPECTIVE A YS. IN THE CASES UNDER CONSIDERATION WE FIND THAT ISSUES WERE DIFFERENT FO R DIFFERENT ASSESSMENT YEARS, SO TWO-PARAGRAPH-ORDERS CONFIRMING THE PENALTY OF RS.7 .27 CANNOT BE HELD SPEAKING AND REASONED ORDERS. IN OUR HUMBLE OPINION IT IS NOT T HE LENGTH OF AN ORDER, BUT THE REASONING MENTIONED IN THAT ORDER MAKES IT A SPEAKI NG/NON-SPEAKING ORDER. IN THE CASES UNDER CONSIDERATION ORDERS OF THE FAA ARE NEI THER SPEAKING NOR REASONED. AS PER THE ESTABLISHED PRINCIPLES OF TAXATION- JURISPR UDENCE DISALLOWANCE/ADDITIONS MADE BY THE AO IN THE ASSESSMENT ORDER AND CONFIRMED BY THE APPELLATE AUTHORITIES DO NOT RESULT IN AUTOMATIC LEVY OR PENALTY FOR CONCEALING THE PARTICULARS OF INCOME OR FOR FURNISHING INACCURATE PARTICULARS. SUBMISSIONS MADE BY THE ASSESSEE DURING PENALTY PROCEEDINGS HAVE TO BE INDEPENDENTLY ADJUDICATED UP ON. ISSUES LIKE UN PAID INTEREST U/S.43B, REVERSAL OF EXCESS LIABILITY, DISALLOWANCE S OF PF/VPF/PENSION PAID BEYOND GRACE PERIOD U/S.43B,LOANS AND ADVANCES WRITTEN OFF , DEPRECIATION ON RESEARCH AND DEVELOPMENT EQUIPMENT ETC. REQUIRED INDEPENDENT APP LICATION OF MIND AND ADJUDICATION. WE HAVE PERUSED THE SUBMISSION MADE BY THE ASSESSEE IN RESPONSE TO NOTICES ISSUED BY THE AO FOR IMPOSING PENALTY U/S.2 71(1)(C) OF THE ACT AND THE SUBMISSION MADE BEFORE THE FAA. (PAGES 476-486OF TH E PAPER BOOK).AFTER CONSIDERING THE SAME WE ARE OF THE OPINION THAT FA A, WHILE DECIDING THE APPEAL FILED BY THE APPELLANT-COMPANY, HAS NOT DEALT THE ISSUES BEFORE HIM IN A MANNER ENVISAGED BY THE PROVISIONS OF THE ACT. 5.3. SO, IN THE INTEREST OF JUSTICE, MATTERS ARE BEING R ESTORED BACK TO THE FILE OF THE ITA NO. 4839/MUM/2011 ITA NO. 4840/MUM/2011 ITA NO. 4841/MUM/2011 M/S. HINDUSTAN ORGANIC CHEMICALS LTD. 6 FAA FOR PASSING A SPEAKING ORDERS FOR ALL THE THREE AYS. AS HELD EARLIER, ADDITIONS/ DISALLOWANCES MADE DURING THE ASSESSMENT PROCEEDING S OR THEIR CONFIRMATION IN APPELLATE PROCEEDINGS DO NOT RESULT IN AUTOMATIC LE VY OF PENALTY FOR CONCEALMENT. THEREFORE, FAA SHOULD HAVE DECIDED THE ISSUE OF LEV YING PENALTY FOR FILING INACCURATE PARTICULARS/ CONCEALING THE PARTICULARS OF INCOME I NDEPENDENTLY-WITHOUT SOLELY RELYING UPON THE ADDITIONS CONFIRMED IN APPELLATE PROCEEDIN GS. WE ALSO FIND THAT THE FAA HAS STATED THAT THE DECISIONS RELIED UPON BY THE AS SESSEE-COMPANY WERE NO HELP TO IT, BUT HE HAS NOT ELABORATED AS HOW THE CASES RELIED U PON BY THE APPELLANT WERE DISTINGUISH-ABLE OR AS WHY SAME WERE NOT APPLICABLE TO THE FACTS AND CIRCUMSTANCES OF THE CASES ADJUDICATED BY HIM. IN THESE CIRCUMSTANC ES WE ARE RESTORING BACK ALL THE THREE MATTERS TO THE FILE OF THE FAA FOR PASSING SP EAKING ORDERS AFTER AFFORDING A REASONABLE OPPORTUNITY OF HEARING TO THE APPELLANT- COMPANY. AS A RESULT, APPEALS FILED BY THE APPELLANT FOR ALL THE THREE AYS. (ITA NO. 4839/ MUM/ 2011; ITA NO. 4840/ MUM/ 2011 & ITA NO. 4841/MUM/2011) STAND PARTLY ALLOWED. , -. ,/ 0 *12 3 4 /5 6 + . ! 7 3 / 8. ORDER PRONOUNCED IN THE OPEN COURT ON 28 TH DECEMBER, 2012 *!+ 3 :% 2 ! ' 6 ;* 28 TH DECEMBER, 2012 3 4 < SD/- SD/- ( . / D. MANMOHAN) ( !'# / RAJENDRA) / VICE PRESIDENT !2 *- / ACCOUNTANT MEMBER MUMBAI, ;* DATE: 28 TH DECEMBER, 2012 TNMM *!+ *!+ *!+ *!+ 3 33 3 (/= (/= (/= (/= >!=%/ >!=%/ >!=%/ >!=%/ / COPY OF THE ORDER FORWARDED TO : 1. APPELLANT 2. RESPONDENT 3. THE CONCERNED CIT (A) 4. THE CONCERNED CIT 5. DR E BENCH, ITAT, MUMBAI 6. GUARD FILE )=/ (/ //TRUE COPY// *! *! *! *!+ + + + / BY ORDER, / DY./ASST. REGISTRAR , / ITAT, MUMBAI