DCIT (OSD) 8(1), MUMBAI V. CINEMAX INDIA LTD, MUMBAI

ITA 5692/MUM/2013

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 88195 (ITAT-MUMBAI)
• Duration Of Justice: 1 year(s) 4 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 28-01-2015
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: C
• Assessment Year: 2010-2011
• Appeal Filed On: 12-09-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: R N DSOUZA
• Keywords: Depreciation; Capital receipt

Judgement Text

, , , , , ,, , , IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES C, MUMBAI . . , ! '#, $ BEFORE SHRI JOGINDER SINGH, JUDICIAL MEMBER, AND SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER ITA NO.5692/MUM/2013 ASSESSMENT YEAR: 2010-11 ACIT - 8(1), 2 ND FLOOR, AAYAKAR BHAVAN, NEW MARINE LINES, MUMBAI-400020 / VS. CINELINE INDIA LTD. ATTRIUM-215, 10 TH FLOOR, NEAR MARRIOT COURT YARD, ANDHERI-KURALA ROAD, ANDHERI(E), MUMBAI-400059 ( '# / REVENUE) ( ()* /ASSESSEE) P.A. NO.AACCC1775F ITA NO.5718/MUM/2013 ASSESSMENT YEAR: 2010-11 CINELINE INDIA LTD. ATTRIUM-215, 10 TH FLOOR, NEAR MARRIOT COURT YARD, ANDHERI-KURALA ROAD, ANDHERI(E), MUMBAI-400059 / VS. ACIT - 8(1), 2 ND FLOOR, AAYAKAR BHAVAN, NEW MARINE LINES, MUMBAI-400020 ( ()* /ASSESSEE) ( '# / REVENUE) P.A. NO.AACCC1775F '# + , + , + , + , / REVENUE BY SMT. R.N. DSOUZA - DR ()* + , + , + , + , / // / ASSESSEE BY): SHRI VIJAY MEHTA + *-! / / / / DATE OF HEARING : 28/01/2015 ./0 + *-! / DATE OF PRONOUNCEMENT : 28/01/2015 CINELINE INDIA LTD. . 2 '1 '1 '1 '1 / / / / O R D E R PER JOGINDER SINGH (JUDICIAL MEMBER) : THE REVENUE AS WELL AS THE ASSESSEE ARE AGGRIEVED B Y THE IMPUGNED ORDER DATED 11/06/2013 OF THE LD. FIRST AP PELLATE AUTHORITY, MUMBAI. 2. IN THE APPEAL OF THE REVENUE ONLY GROUND RAISED PERTAINS TO HOLDING THAT THE ENTERTAINMENT TAX/DUTY OF RS.5,61, 54,109/-, COLLECTED BY THE ASSESSEE, IS A CAPITAL RECEIPT, CO NSEQUENTLY, EXEMPT FROM TAX PLACING RELIANCE UPON THE DECISION FROM HONBLE JURISDICTIONAL HIGH COURT IN THE CASE OF CIT VS CHA PALKAR BROTHERS, PUNE (ITA NO.1036 OF 2010) ORDER DATED 08 /06/2011 WITHOUT APPRECIATING THAT SLP HAS BEEN FILED BEFORE HONBLE APEX COURT, BY THE DEPARTMENT, AGAINST THE DECISION OF T HE HIGH COURT. 2.1. IN THE APPEAL OF THE ASSESSEE, THE GROUND RAI SED PERTAINS TO SUBSIDY RECEIVED IS CAPITAL RECEIPT AND HAS TO BE R EDUCED FROM WDV VALUE OF THE BLOCK OF ASSET AND TO ALLOW THE DEP RECIATION ON THE REDUCED VALUE OF WDV. 2.2. DURING HEARING OF THIS APPEAL, THE LD. DR, SHR I R.N. DSOUZA, ADVANCED HIS ARGUMENTS WHICH ARE IDENTICAL TO THE GROUND RAISED. ON THE OTHER HAND, THE LD. COUNSEL FOR THE ASSESSEE, SHRI VIJAY MEHTA, RELIED UPON THE AFORESA ID DECISION FROM HONBLE HIGH COURT AND ALSO THE DECISION OF TH E TRIBUNAL IN THE CASE OF ASSESSEE ITSELF FOR ASSESSMENT YEAR 200 8-09 AND 2009-10, ORDER DATED 24/01/2014. THIS FACTUAL MATR IX WAS NOT CONTROVERTED BY THE REVENUE. 2.3. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AND P ERUSED THE MATERIAL AVAILABLE ON RECORD. IN VIEW OF THE ABOVE , WE ARE CINELINE INDIA LTD. . 3 REPRODUCING HEREUNDER THE RELEVANT PORTION FROM THE AFORESAID ORDER OF THE TRIBUNAL DATED 24/01/2014 2. BRIEFLY STATED RELEVANT FACTS OF THE CASE ARE T HAT THE ASSESSEE IS ENGAGED IN THE BUSINESS OF EXHIBITION OF FILMS, BUI LDERS AND DEVELOPERS. DURING THE AY UNDER CONSIDERATION, ASSE SSEE COLLECTED RS. 6,98,17,074/- TOWARDS ENTERTAINMENT TAX AND ASS ESSEE GOT EXEMPTION FROM PAYMENT OF THE SAME. DURING THE ASSE SSMENT, ASSESSEE CLAIMED THAT THE SAID ENTERTAINMENT DUTY R EPRESENTS CAPITAL SUBSIDY AND NOT LIABLE TO BE TAXED AS REVE NUE RECEIPT . AO REJECTED THE CLAIM OF THE ASSESSEE BY HOLDING TH AT THE ASSESSEE HAD CONSISTENTLY BEEN SHOWING THE ENTERTAINMENT TAX COLLECTED AS REVENUE RECEIPTS WITHOUT BIFURCATING THE AMOUNT OF ENTERTAINMENT TAX SEPARATELY. THE AO FURTHER HELD THE ENTERTAINME NT TAX WAS COLLECTED BY THE ASSESSEE FOR EXHIBITING THE FILMS WHICH WAS THE BUSINESS OF THE ASSESSEE AND THEREBY TREATED THE SA ID RECEIPT AS REVENUE IN NATURE AND ACCORDINGLY BROUGHT THE SAME TO TAX. WITHOUT PREJUDICE TO THE SAID DECISION, THE AO FURT HER HELD THAT THE GRANT OR REIMBURSEMENT SHALL NOT BE INCLUDED IN THE COST OF THE ASSETS AND HENCE THE ALLEGED AMOUNT OF ENTERTAINMEN T TAX COLLECTED HAD TO BE REDUCED FROM THE COST OF ASSET FOR THE PU RPOSE OF DEPRECIATION IF IT IS TREATED AS CAPITAL RECEIPT. M ATTER TRAVELLED TO THE FIRST APPELLATE AUTHORITY. 3. DURING THE PROCEEDINGS BEFORE THE FIRST APPELLAT E AUTHORITY, AFTER CONSIDERING THE SUBMISSIONS MADE BY THE ASSES SEE, CIT (A) PARTLY ALLOWED THE APPEAL OF THE ASSESSEE AND TREAT ED THE SAID AMOUNT OF RS.6,98,17,074/- AS CAPITAL RECEIPT AND ACCORDINGLY DELETED THE ADDITION MADE BY THE AO BY RELYING ON T HE DECISION OF THE HONBLE BOMBAY HIGH COURT IN THE CASE OF M/S. C HAPHALKAR CINELINE INDIA LTD. . 4 BROTHERS VS ITO VIDE ITA NOS.1342& 1443 OF 2006 AND DIRECTED THE AO TO ALLOW THE DEPRECIATION ON THE REDUCED COS T OF ASSET. AGGRIEVED WITH THE DECISION OF THE CIT (A) BOTH THE ASSESSEE AS WELL AS THE REVENUE ARE IN APPEAL BEFORE THE TRIBUN AL. 4. DURING THE PROCEEDINGS BEFORE US, SHRI ANUJ KISN ADWALA, LD COUNSEL FOR THE ASSESSEE HEAVILY RELIED ON THE ORDE R OF THE CIT (A) AND REITERATED THE SUBMISSIONS MADE BEFORE THE LOWE R AUTHORITIES. 5. ON THE OTHER HAND, LD DR DUTIFULLY RELIED ON THE ORDER OF THE AO. 6. WE HAVE HEARD BOTH THE SIDES AND PERUSED THE MATERIAL ON RECORD. FIRSTLY, ON THE ISSUE RAISED BY THE REVENUE CLAIMING THAT THE ENTERTAINMENT TAX/DUTY COLLECTED BY THE ASSESSE E IS TO BE TREATED AS A REVENUE RECEIPT, IT IS PERTINENT TO MENTION TH AT THE CASE OF THE ASSESSEE SQUARELY COVERED BY THE DECISION OF THE HO N BLE BOMBAY HIGH COURT IN THE CASE OF CIT VS. CHAPHALKAR BROTHE RS (SUPRA), DATED 08.06.2011, WHEREIN IT HAS BEEN HELD THAT THE SUBSIDY OF THIS KIND CONSTITUTES CAPITAL RECEIPTS AS IT IS MEANT FO R PROMOTION OF THE NEW INDUSTRIES BY WAY OF MULTIPLEX THEATRES, IN OUR VIEW, HAS BEEN RIGHTLY FOLLOWED BY THE LD.CIT(A) FOR TREATING THE IMPUGNED AMOUNT AS CAPITAL RECEIPTS . IT IS ALSO RELEVANT TO MENTION THAT THE FACT OF THE ASSESSEE S CASE IS ALSO COVERED BY THE DECISION OF THE TRIBUNAL IN THE ASSESSEE S SISTER CONCERN CASE NAMELY VISTA ENTERTAINMENT PVT. LTD. IN ITA NO. 8402/MUM/2011 FO R THE ASSESSMENT YEAR 2008-09, THE ORDER TO WHICH THE PRE SENT AM IS ALSO A PARTY, WHEREIN IT HAS BEEN HELD THAT SIMILAR ADDITIONS ARE NOT SUSTAINABLE SINCE THE SAME AMOUNTS TO CAPITAL I N NATURE. FOLLOWING THE ABOVE DECISIONS IN THE SIMILAR CONTEX T OF FACTS INVOLVED, WE DO NOT FIND ANY JUSTIFIABLE REASON TO INTERFERE WITH THE DECISION OF THE LD. CIT(A) IN TREATING THE IMPUGNED AMOUNT AS CINELINE INDIA LTD. . 5 CAPITAL RECEIPT AND THE SAME NOT LIABLE TO TAX. ACC ORDINGLY, THE DECISION OF THE LD. CIT(A) ON THIS COUNT IS UPHELD. SIMILAR DECISION ON THIS ISSUE WAS TAKEN BY THE TRIBUNAL IN THE ASSE SSEE S OWN CASE VIDE ITA NO.1287/M/2012 AND 1483/M/2012 FOR THE AY 2009- 2010. 7. SECONDLY, AS REGARDS THE ISSUE RAISED IN T HE ASSESSEE S APPEAL REGARDING THE REDUCTION FROM THE WDV OF BLOC K OF ASSET AND TO ALLOW THE DEPRECIATION ON THE REDUCED VALUE OF WDV ACCORDINGLY, IT IS PERTINENT TO MENTION THAT SIMILA R ISSUE HAS BEEN ELABORATELY DISCUSSED BY THE TRIBUNAL IN THE CASE O F M/S. PVR LTD. IN ITA NO. 1897/DEL/2011, WHEREIN IT HAS BEEN HELD THAT THE AMOUNT OF SUCH SUBSIDY CANNOT BE HELD TO REDUCE THE ACTUAL COST OF ASSETS U/S 43(1) EXPLANATION 10 OF THE ACT. FOR THE SAID DECISION, THE TRIBUNAL IN TURN HAS RELIED ON THE JUDGMENT OF THE HONBLE APEX COURT IN THE CASE OF CIT VS. P.J. CHEMICALS LT D. 210 ITR 830(SC). SINCE SIMILAR FACTS ARE INVOLVED IN THE AS SESSEE S CASE ALSO, FOLLOWING THE DECISION OF THE TRIBUNAL, WE HO LD THAT THE AMOUNT OF SUBSIDY CANNOT BE HELD TO REDUCE THE ACTU AL COST OF ASSET U/S 43(1) EXPLANATION 10 OF THE ACT. ACCORDINGLY WE DECIDE THIS ISSUE IN FAVOUR OF THE ASSESSEE AND AGAINST THE REV ENUE. SIMILAR DECISION ON THIS ISSUE WAS TAKEN BY THE TRIBUNAL IN THE ASSESSEE S OWN CASE VIDE ITA NO.1287/M/2012 AND 1483/M/2012 FO R THE AY 2009-2010. 8. IN THE RESULT, THE APPEAL FILED BY THE REVENUE IS DISMISSED AND THAT OF THE ASSESSEE IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 24TH JANUARY, 2014 2.4. WE ARE ALSO REPRODUCING HEREUNDER THE ORDER OF THE TRIBUNAL DATED 24/01/2014 IN THE CASE OF ASSESSEE I TSELF FOR ASSESSMENT YEAR 2009-10 (ITA NO. 1287/MUM/2012 AND ITA NO.1483/MUM/2012) FOR READY REFERENCE:- CINELINE INDIA LTD. . 6 THESE CROSS APPEALS FILED BY THE REVENUE AND THE ASSESSEE ARE DIRECTED AGAINST THE ORDER OF THE LD.CIT(A)-16, MUM BAI DATED 26.12.2011 FOR THE ASSESSMENT YEAR 2009-10. THE GRO UNDS RAISED IN THE SAID APPEALS RELATE TO THE ISSUE ON THE TREA TMENT GIVEN TO THE SUBSIDY OF RS. 5,57,72,578/- COLLECTED IN THE FORM OF ENTERTAINMENT TAX. 2. THE RELEVANT FACTS ARE THAT THE ASSESSEE, A COMP ANY ENGAGED IN THE BUSINESS OF EXHIBITION OF FILMS, BUILDERS AND D EVELOPERS, DURING THE YEAR UNDER CONSIDERATION, COLLECTED A SUM OF RS . 5,57,72,578/- TOWARDS ENTERTAINMENT TAX FOR WHICH EXEMPTION WAS G RANTED TO THE ASSESSEE FROM PAYMENT OF THE SAME. THE ASSESSEE HAD CLAIMED THE ENTERTAINMENT DUTY COLLECTED WHICH REPRESENTS CAPIT AL SUBSIDY RECEIPT AND NOT LIABLE TO BE TAXED. HOWEVER, IN THE ASSESSMENT FRAMED, THE AO HAD REJECTED THE CLAIM BY STATING TH AT THE ASSESSEE HAD CONSISTENTLY BEEN SHOWING THE ENTERTAINMENT TAX COLLECTED AS REVENUE RECEIPTS WITHOUT BIFURCATING THE AMOUNT OF ENTERTAINMENT TAX SEPARATELY. THE AO FURTHER HELD THE ENTERTAINME NT TAX WAS COLLECTED BY THE ASSESSEE FOR EXHIBITING THE FILMS WHICH WAS THE BUSINESS OF THE ASSESSEE AND THEREBY TREATED THE SA ID RECEIPT AS REVENUE IN NATURE AND ACCORDINGLY BROUGHT THE SAME TO TAX. WITHOUT PREJUDICE TO THE SAID DECISION, THE AO FURT HER HELD THAT THE GRANT OR REIMBURSEMENT SHALL NOT BE INCLUDED IN THE COST OF THE ASSETS AND HENCE THE ALLEGED AMOUNT OF ENTERTAINMEN T TAX COLLECTED HAD TO BE REDUCED FROM THE COST OF ASSET FOR THE PU RPOSE OF DEPRECIATION IF IT IS TREATED AS CAPITAL RECEIPT. O N APPEAL, THE LD.CIT(A) WHILE PARTLY ALLOWING THE CLAIM OF THE AS SESSEE HELD THAT THE IMPUGNED AMOUNT TO BE TREATED AS CAPITAL RECEIP T AND ACCORDINGLY DELETED THE SAID ADDITION BY RELYING ON THE DECISION IN THE CASE OF CHAPHALKAR BROTHERS. HOWEVER, THE LD.CI T(A) DIRECTED CINELINE INDIA LTD. . 7 THE AO TO ALLOW DEPRECIATION ON THE REDUCED COST OF ASSET. AGGRIEVED BY THE IMPUGNED DECISION, THE REVENUE AND THE ASSESSEE ARE IN APPEAL BEFORE US. 3. WE HAVE HEARD BOTH THE SIDES AND PERUSED THE MAT ERIAL ON RECORD. FIRSTLY, ON THE ISSUE RAISED BY THE REVENUE CLAIMING THAT THE ENTERTAINMENT TAX/DUTY COLLECTED BY THE ASSESSE E IS TO BE TREATED AS A REVENUE RECEIPT, IT IS PERTINENT TO MENTION TH AT THE CASE OF THE ASSESSEE SQUARELY COVERED BY THE DECISION OF THE HO NBLE BOMBAY HIGH COURT IN THE CASE OF CIT VS. CHAPHALKAR BROTHE RS, DATED 08.06.2011, WHEREIN IT HAS BEEN HELD THAT THE SUBSI DY OF THIS KIND CONSTITUTES CAPITAL RECEIPTS AS IT IS MEANT FOR PRO MOTION OF THE NEW INDUSTRIES BY WAY OF MULTIPLEX THEATRES, IN OUR VIE W, HAS BEEN RIGHTLY FOLLOWED BY THE LD.CIT(A) FOR TREATING THE IMPUGNED AMOUNT AS CAPITAL RECEIPTS. IT IS ALSO RELEVANT TO MENTION THAT THE FACT OF THE ASSESSEES CASE IS ALSO COVERED BY THE DECISION OF THE TRIBUNAL IN THE ASSESSEES SISTER CONCERN CASE NAME LY VISTA ENTERTAINMENT PVT. LTD. IN ITA NO. 8402/MUM/2011 FO R THE ASSESSMENT YEAR 2008-09, THE ORDER TO WHICH THE PRE SENT AM IS ALSO A PARTY, WHEREIN IT HAS BEEN HELD THAT SIMILAR ADDITIONS ARE NOT SUSTAINABLE SINCE THE SAME AMOUNTS TO CAPITAL I N NATURE. FOLLOWING THE ABOVE DECISIONS IN THE SIMILAR CONTEX T OF FACTS INVOLVED, WE DO NOT FIND ANY JUSTIFIABLE REASON TO INTERFERE WITH THE DECISION OF THE LD.CIT(A) IN TREATING THE IMPUGNED AMOUNT AS CAPITAL RECEIPT AND THE SAME NOT LIABLE TO TAX. ACC ORDINGLY, THE DECISION OF THE LD.CIT(A) ON THIS COUNT IS UPHELD. 4. SECONDLY, AS REGARDS THE ISSUE RAISED IN THE ASS ESSEES APPEAL REGARDING THE REDUCTION FROM THE WDV OF BLOCK OF AS SET AND TO ALLOW THE DEPRECIATION ON THE REDUCED VALUE OF WDV ACCORDINGLY, CINELINE INDIA LTD. . 8 IT IS PERTINENT TO MENTION THAT SIMILAR ISSUE HAS B EEN ELABORATELY DISCUSSED BY THE TRIBUNAL IN THE CASE OF M/S. PVR L TD. IN ITA NO. 1897/DEL/2011, WHEREIN IT HAS BEEN HELD THAT THE AM OUNT OF SUCH SUBSIDY CANNOT BE HELD TO REDUCE THE ACTUAL COST OF ASSETS U/S 43(1) EXPLANATION 10 OF THE ACT. FOR THE SAID DECISION, T HE TRIBUNAL IN TURN HAS RELIED ON THE JUDGMENT OF THE HONBLE APEX COURT IN THE CASE OF CIT VS. P.J. CHEMICALS LTD. 210 ITR 830(SC) . SINCE SIMILAR FACTS ARE INVOLVED IN THE ASSESSEES CASE A LSO, FOLLOWING THE DECISION OF THE TRIBUNAL, WE HOLD THAT THE AMOUNT O F SUBSIDY CANNOT BE HELD TO REDUCE THE ACTUAL COST OF ASSET U /S 43(1) EXPLANATION 10 OF THE ACT. ACCORDINGLY WE DECIDE TH IS ISSUE IN FAVOUR OF THE ASSESSEE AND AGAINST THE REVENUE. 5. IN THE RESULT, THE APPEAL FILED BY THE REVENUE I S DISMISSED AND THAT OF THE ASSESSEE IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON THIS 24TH DAY OF JANUARY, 2014. 2.5. IN THE APPEAL OF THE REVENUE, THE ISSUE PERTAI NS TO ENTERTAINMENT TAX/DUTY COLLECTED BY THE ASSESSEE IS WHETHER CAPITAL RECEIPT AND WHETHER EXEMPTED FROM TAXATION, WHEREAS, IN THE APPEAL OF THE ASSESSEE, THE ISSUE PERTAINS TO T HE SUBSIDY RECEIVED FROM THE GOVERNMENT IS A CAPITAL RECEIPT A ND ALSO WHETHER IS TO BE REDUCED FROM THE VALUE OF WDV. WE NOTE THAT BOTH THESE ISSUES HAS BEEN DEALT WITH IN DETAIL BY THE TRIBUNAL, AS REPRODUCED HEREINABOVE, THEREFORE, WITHOUT GOIN G INTO MUCH DELIBERATION, WE FIND THAT THE TRIBUNAL VIDE ORDER DATED 24/01/2014, ON IDENTICAL FACT, IN THE CASE OF ASSES SEE ITSELF, VIDE AFORESAID ORDERS, DELIBERATED UPON THE ISSUE AND BY FOLLOWING THE DECISION FROM HONBLE JURISDICTIONAL HIGH COURT IN THE CASE OF CIT VS CHAPALAKAR BROTHERS (ORDER DATED 08/06/2011) , WHEREIN IT WAS HELD THAT SUBSIDY OF THIS KIND CONSTITUTES C APITAL RECEIPTS CINELINE INDIA LTD. . 9 AS THE SAME IS MEANT FOR PROMOTION OF NEW INDUSTRIE S BY WAY OF MULTIPLEX THEATERS, WHICH HAS BEEN FOLLOWED BY THE LD. FIRST AUTHORITY ALSO. THEREFORE, WE FIND NO MERIT IN THE APPEAL OF THE REVENUE AND ALSO FOLLOWING THE SAME ORDER WITH RESP ECT TO SUBSIDY RECEIVED HAS TO BE REDUCED FROM WDV OF THE B LOCK OF ASSET AND TO ALLOW THE DEPRECIATION ON THE REDUCED VALUE OF WDV ALSO VIDE PARA-4 OF THE ORDER OF THE TRIBUNAL DATED 24/01/2014, THE ISSUE HAS BEEN DECIDED IN FAVOUR OF THE ASSESSE E. RESPECTFULLY FOLLOWING THE ORDER OF THE TRIBUNAL, T HE APPEAL OF THE REVENUE IS DISMISSED AND THAT OF THE ASSESSEE IS AL LOWED. FINALLY, THE APPEAL OF THE REVENUE IS DISMISSED AND THAT OF THE ASSESSEE IS ALLOWED. THIS ORDER WAS PRONOUNCED IN THE OPEN COURT IN THE PRESENCE OF LD. REPRESENTATIVES FROM BOTH SIDES AT THE CONCLUSION OF THE HEARING ON 28/01/2015. '1 + ./0 2'3 28/01/2015 / + 9 SD/- (N.K.BILLAIYA) SD/- (JOGINDER SINGH) ! '# ! '# ! '# ! '# / ACCOUNTANT MEMBER '# '# '# '# / JUDICIAL MEMBER MUMBAI; 2' DATED : 28/01/201 5 F{X~{T? P.S/. .. '1 + :* ;0* '1 + :* ;0* '1 + :* ;0* '1 + :* ;0*/ COPY OF THE ORDER FORWARDED TO : 1. <= / THE APPELLANT 2. :><= / THE RESPONDENT. 3. ? ( ) / THE CIT, MUMBAI. 4. ? / CIT(A)- , MUMBAI 5. A9 :* , , / DR, ITAT, MUMBAI 6. 9B( C / GUARD FILE. '1 '1 '1 '1 / BY ORDER, >* :* //TRUE COPY// D DD D/ // /E ' E ' E ' E ' (DY./ASSTT. REGISTRAR) , , , , / ITAT, MUMBAI