M/s. Sharp Metal Overseas, Mumbai V. The ACIT., Vapi Circle, Vapi

ITA 629/AHD/2012

• Counselvise Citation: 62920514 RSA 2012
• Duration Of Justice: 3 year(s) 4 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-07-2015
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Next Hearing Date: 20-07-2015
• Assessment Year: 2000-2001
• Appeal Filed On: 13-03-2012
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: NARENDRA SINGHSR D R
• Assessee Lawyers: V H JARIWALA
• Keywords: Depreciation; Tangible material; Avoidance of tax; Reason to believe
• Section: 143(3); 80IB; 147; 148

Judgement Text

, IN THE INCOME TAX APPELLATE TRIBUNAL B BENCH, AHMEDABAD BEFORE SHRI G.D. AGRAWAL, VICE PRESIDENT AND SHRI KUL BHARAT, JUDICIAL MEMBER ./ ././ ./ ITA NOS. 628, 629 & 630/AHD/2012 / ASSESSMENT YEAR: 1999-2000, 2000-01 AND 2002-03 RESPECTIVELY SHARP METAL OVERSEAS, C/O. SURENDRAKUMAR AGARWAL, 191 KIKA STREET, GOGATE MANSION, 5 TH FLOOR, MUMBAI PAN : AAMFS 3472 G V/S. ACIT, VAPI CIRCLE, VAPI / // / (APPELLANT) / // / (RESPONDENT) ASSESSEE(S) BY : SHRI V.H. JARIWALA, AR REVENUE BY : SHRI NARENDRA SINGH, SR. DR !' # $%&/ // / DATE OF HEARING : 20/07/2015 '( # $%& / // / DATE OF PRONOUNCEMENT: 23/07/2015 )* )* )* )*/ // / O R D E R PER G.D. AGRAWAL, VICE PRESIDENT: THESE ARE THE THREE APPEALS FILED BY THE ASSESSEE A GAINST SEPARATE ORDERS OF THE COMMISSIONER OF INCOME TAX (APPEALS), VALSAD, DATED 29.11.2010 FOR ASSESSMENT YEARS 1999-2000 AND DATED 29.11.2011 FOR ASSESSMENT YEARS 2000-01 & 2002-03. 2. THE FIRST GROUND OF THE ASSESSEES APPEAL IN ALL THE YEARS IS AGAINST RE- OPENING OF ASSESSMENT U/S 147/148. SINCE THE REASO NS RECORDED FOR RE- OPENING OF ASSESSMENT AND THE FACTS OF THE CASE FOR ALL THE YEARS ARE IDENTICAL, WE SHALL CONSIDER THE DETAILS AS GIVEN IN ASSESSEE S APPEAL FOR ASSESSMENT YEAR 2000-01. 3. FOR THE YEAR UNDER CONSIDERATION, I.E, ASSESSMEN T YEAR 2000-01, THE ASSESSEE HAD FILED THE RETURN ON 19.10.2000, WHICH WAS ACCEPTED U/S 143(1) ITA NOS.628 TO 630/AHD/2012 SHARP METAL OVERSEAS VS. ACIT FOR AYS 1999-00, 2000-01& 2002-03 2 OF THE ACT. SUBSEQUENTLY, THE CASE WAS RE-OPENED BY INVOKING THE PROVISIONS OF SECTION 147. NOTICE U/S 148 WAS ISSUED ON 09.03 .2006. THE REASONS RECORDED FOR RE-OPENING OF ASSESSMENT READS AS UNDE R:- RETURN OF INCOME WAS FILED ON 19.10.2000 DECLARING TOTAL INCOME OF RS.22,500/- AFTER CLAIMING DEDUCTION U/S 80IA/80IB AMOUNTING TO RS.40,78,581/-. SAME WAS PROCESSED U/S 143(1) ON T HE SAME DAY. SUBSEQUENTLY ON GOING THROUGH THE CASE RECORDS, IT IS NOTICED THAT THE ASSESSEE HAS NOT CLAIMED THE DEPRECIATION AS THE EN TIRE INCOME OF THE INDUSTRIAL UNDERTAKING LOCATED IN THE BACKWARD AREA OF DAMAN / SILVASSA WAS FULLY EXEMPT U/S. 80IA/IB OF THE ACT AND THUS THE D EPRECIATION IS DEFERRED FOR FUTURE. IT IS SEEN THAT OUT OF ALL INDUSTRIAL UNDE RTAKINGS LOCATED IN THE BACKWARD AREA OF DAMAN AND SILVASSA AND ENJOYING BE NEFITS OF SECTION 80IB OF THE ACT, CERTAIN ASSESSEES ARE CLAIMING DEPRECIA TION RIGHT FROM THE INCEPTION OF THE UNIT, WHEREAS, CERTAIN ASSESSEES A RE SEEN TO BE NOT CLAIMING DEPRECIATION. LAW CANNOT BE DIFFERENT FOR A SAME C LASS OF ASSESSEES CLAIMING DEDUCTION U/S.80IB OF THE ACT. SUCH A TACTIC HAS LE D TO UNDUE BENEFIT OF THE ASSESSEES NOT CLAIMING DEPRECIATION. IT IS SEEN THA T THESE ASSESSEES HAVE NOT FORGONE THEIR CLAIM OF DEPRECIATION. THE MODUS OPER ANDI ADOPTED BY THEM IS THAT THEY START CLAIMING DEPRECIATION ON THE ORIGIN AL COST OF FIXED ASSETS FROM THE SIXTH YEAR ONWARDS. AS PER THE PROVISIONS OF SE CTION 80IB OF THE ACT, THE MANUFACTURING PROFITS OF THIS CLASS OF ASSESSEES AR E ELIGIBLE FOR DEDUCTION ONLY @ 25%; WHEREAS, THE REMAINING 75% OF THE PROFITS IS LIABLE TO BE TAXED, FROM THE SIXTH YEAR. AS SUCH, THE QUANTUM OF DEPRECIATIO N IN THE SIXTH YEAR, IN THOSE CASES WHERE DEPRECIATION WAS NOT CLAIMED IN T HE EARLIER YEARS, BECOMES A HUGE AMOUNT. AS A RESULT OF CLAIM OF DEPRECIATION I N. THE SIXTH YEAR, THE ASSESSEE SUCCEEDS IN REDUCING ITS PROFITS FROM MANU FACTURING ACTIVITY BY A HUGE SUM. THIS INDIRECTLY LEADS TO A HUGE LOSS TO T HE GOVERNMENT EX-CHEQUER, SINCE 75% OF THE PROFITS IS TAXABLE FROM THE 6TH YE AR ONWARDS. SUCH A MODUS OPERANDI IS NOT WITHIN THE MEANING OF TAX PLANNING. THIS CLEARLY AMOUNTS TO AVOIDANCE AND EVASION OF TAX. IT IS A FACT THAT GO VERNMENT HAS INTRODUCED BENEFIT OF SECTION 80IB TO DEVELOP A BACKWARD AREA, WHICH WAS PUT UPON THE SHOULDERS OF INDUSTRIALISTS BY GIVING THEM TAX INCE NTIVES. THE INTENTION OF THIS LEGISLATURE WAS NEVER TO GIVE THESE INDUSTRIAL ISTS SUCH A FREEDOM THAT THEY COULD BEND THE PROVISIONS OF LAW TO SUIT THEIR NEEDS. BY ADOPTING SUCH TACTICS, THE ASSESSEES NOT CLAIMING DEPRECIATION F OR THE INITIAL FIVE YEARS HAS NOT TAKEN THE LEGISLATION IN ITS CORRECT SPIRIT AND STRIDE. THE AFORESAID MODUS OPERANDI ADOPTED BY SUCH ASSESSEES CANNOT BE IN ANY MEANS BEING CONSIDERED AS TAX PLANNING. THE SAME VIEW IS UPHELD BY THE HO NBLE SUPREME COURT IN THE CASE OF MC. DOWELL & CO. LTD VS. COMMERCIAL TAX OFFICER, 154 ITR 48, WHEREIN IT WAS HELD THAT COLOURABLE DEVISES CANNOT BE A PART OF TAX PLANNING AND IT IS WRONG TO ENCOURAGE AVOIDANCE OF TAX BY DU BIOUS METHODS. ITA NOS.628 TO 630/AHD/2012 SHARP METAL OVERSEAS VS. ACIT FOR AYS 1999-00, 2000-01& 2002-03 3 ACCORDINGLY, IN THIS CONTEXT, THE MATTER REGARDING ALLOWANCE OF DEPRECIATION IS TO BE CONSIDERED AT LENGTH IN THE INSTANT CASE. DEDUCTION U/S. 80IA/80IB IS A SPECIAL DEDUCTION AND HENCE TOTAL INCOME IS TO BE COMPUTED IN ACCORDANCE WITH THE PROVISIONS OF THE ACT. COMPUTATION OF TOTA L INCOME IS NOT ONLY BASED ON THE PROVISIONS OF THE ACT BUT ALSO ON THE ACCOUN TING STANDARDS. BY NOT CLAIMING DEPRECIATION, THE ASSESSEE HAS INFLATED IT S TAX FREE PROFITS AND HAS FAILED TO DISCLOSE FULLY AND TRULY ALL MATERIAL FAC TS NECESSARY FOR ITS ASSESSMENT AND HAS CLAIMED EXCESSIVE RELIEF U/S. 80 IA/80IB OF THE ACT. THIS VIEW IS ALSO AFFIRMED BY THE DECISION OF THE HON'BL E SUPREME COURT IN THE CASE OF CAMBAY ELECTRIC SUPPLY CO. V/S. C.I.T. (197 8) 113 ITR 84 AND THE HON'BLE BOMBAY HIGH COURT IN THE CASE OF INDIAN RAY ON CORPORATION LTD. V/S C.I.T. (2003) 261 ITR 98. THE ABOVE VIEW OF THE DEPARTMENT HAS BEEN CONFIRMED BY THE THREE MEMBERS SPECIAL BENCH OF THE TRIBUNAL VIDE ITS CONSOLIDATED ORDER FOR ALMOST 52 ASSESSEES PASSED ON 09.11.2005 ON THE ISSUE OF ALLO WANCE OF DEPRECIATION. IN. VIEW OF THE ABOVE DISCUSSION, I HAVE REASON TO BELIEVE AND AM SATISFIED THAT THE ASSESSEE HAS CLAIMED EXCESS DEDUCTION OF DEPREC IATION AND FAILED TO DISCLOSE FULLY AND TRULY ALL MATERIAL FACTS NECESSA RY FOR ITS ASSESSMENT WITHIN THE MEANING OF SECTION 147 OF THE ACT AND HENCE INC OME CHARGEABLE TO TAX MORE THAN RS. 1 LACS HAS ESCAPED ASSESSMENT. ISSUE NOTICE U/S. 148 OF THE ACT. 4. IN RESPONSE TO NOTICE ISSUED U/S 148, THE ASSESS EE VIDE LETTER DATED 27.04.2006 REQUESTED THAT THE ORIGINAL RETURN FILED MAY BE TREATED AS FILED IN RESPONSE TO NOTICE U/S 148. THEREAFTER, THE ASSES SING OFFICER COMPLETED THE ASSESSMENT AT RS.23,260/-. ON APPEAL, THE CIT(A) U PHELD THE ORDER OF THE ASSESSING OFFICER; HENCE, THIS APPEAL BY THE ASSESS EE. 5. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE M ATERIAL PLACED BEFORE US. AFTER READING OF THE REASONS RECORDED, WE FIND THAT THE ASSESSING OFFICER IN DETAIL HAS DISCUSSED THAT THE ASSESSEE I S ENTITLED TO DEDUCTION U/S 80IA/80IB. IN THE RETURN OF INCOME, IT DID NOT CLA IM DEPRECIATION WHICH WILL ENTITLE THE ASSESSEE TO CLAIM MORE DEPRECIATION FRO M SIXTH YEAR ONWARDS WHEN THE ASSESSEE WOULD NOT BE ENTITLED TO DEDUCTIO N U/S 80IB. HOWEVER, ITA NOS.628 TO 630/AHD/2012 SHARP METAL OVERSEAS VS. ACIT FOR AYS 1999-00, 2000-01& 2002-03 4 AFTER RECORDING THESE FACTS, THE ASSESSING OFFICER RECORDED THE CONCLUSION IN VIEW OF THE ABOVE DISCUSSION, I HAVE REASON TO BELI EVE AND AM SATISFIED THAT THE ASSESSEE HAS CLAIMED EXCESS DEDUCTION OF DEPRECATIO N. THUS, AS PER CONCLUSION OF THE ASSESSING OFFICER, HE WAS OF THE OPINION THAT T HE EXCESS CLAIM OF DEPRECATION BY THE ASSESSEE IS THE REASON FOR RE-OP ENING OF ASSESSMENT. HOWEVER, THIS CONCLUSION OF THE ASSESSING OFFICER I S CONTRARY TO HIS OWN FINDING IN THE ENTIRE REASONS RECORDED BY HIM. IN T HE REASONS RECORDED, THE ASSESSING OFFICER HAS MENTIONED THAT THE ASSESSEE D ID NOT CLAIM ANY DEPRECIATION. ONCE THE ASSESSEE DID NOT CLAIM DEPRE CIATION IN THE YEAR UNDER CONSIDERATION, HOW IT CAN BE SAID THAT THE ASSESSEE CLAIMED EXCESS DEPRECIATION SO AS TO ARRIVE AT THE CONCLUSION THAT THERE WAS ESCAPEMENT OF INCOME IN THE YEAR UNDER CONSIDERATION. 6. AGAIN, IN THE CONCLUDING PARAGRAPH, THE ASSESSIN G OFFICER FURTHER RECORDED THAT THE ASSESSEE FAILED TO DISCLOSE FULLY AND TRULY ALL MATERIAL FACTS NECESSARY FOR ITS ASSESSMENT WITHIN THE MEANING OF SECTION 147 OF THE ACT . THIS CONCLUSION OF THE ASSESSING OFFICER IS ALSO CONTRAR Y TO THE DETAILED REASONS GIVEN BY HIM IN THE EARLIER PARAGRAPH WHICH READS SUBSEQUENTLY ON GOING THROUGH THE CASE RECORDS, IT IS NOTICED THAT THE AS SESSEE HAS NOT CLAIMED THE DEPRECIATION . THUS, THE FACTS OF NOT CLAIMING OF DEPRECIATION WERE ALREADY ON THE RECORD. IF THE ASSESSING OFFICER WHO ACCEPTED THE RETURN U/S 143(1) DID NOT GO THROUGH THE RECORDS, IT CANNOT BE SAID THAT THE ASSESSEE FAILED TO DISCLOSE FULLY AND TRULY ALL MATERIAL FACTS NECESSA RY FOR ITS ASSESSMENT. THUS, THE CONCLUSIONS RECORDED BY THE ASSESSING OFFICER A RE CONTRARY TO THE FACTS RECORDED BY HIM IN THE REASONS RECORDED ITSELF. 7. AT THE TIME OF HEARING BEFORE US, THE LD. COUNSE L HAS RELIED UPON THE DECISION OF HONBLE DELHI HIGH COURT IN THE CASE OF CIT VS. ORIENT CRAFT LTD ITA NOS.628 TO 630/AHD/2012 SHARP METAL OVERSEAS VS. ACIT FOR AYS 1999-00, 2000-01& 2002-03 5 VIDE ITA NO.555 OF 2012, WHEREIN THE HONBLE DELHI HIGH COURT HELD AS UNDER:- 14. CERTAIN OBSERVATIONS MADE IN THE DECISION OF RAJESH JHAVERI (SUPRA) ARE SOUGHT TO BE RELIED UPON BY THE REVENUE TO POINT OU T THE DIFFERENCE BETWEEN AN ASSESSMENT AND AN INTIMATION. THE CONTEXT IN WH ICH THOSE OBSERVATIONS WERE MADE HAS TO BE KEPT IN MIND. THEY WERE MADE TO POINT OUT THAT WHERE AN INTIMATION IS ISSUED UNDER SECTION 143(1) THER E IS NO OPPORTUNITY TO THE ASSESSING AUTHORITY TO FORM AN OPINION AND THEREFOR E WHEN ITS FINALITY IS SOUGHT TO BE DISTURBED BY ISSUING A NOTICE UNDER SE CTION 148, THE PROCEEDINGS CANNOT BE CHALLENGED ON THE GROUND OF CHANGE OF OP INION. IT WAS NOT OPINED BY THE SUPREME COURT THAT THE STRICT REQUIREMENTS O F SECTION 147 CAN BE COMPROMISED. ON THE CONTRARY, FROM THE OBSERVATIONS (QUOTED BY US EARLIER) IT WOULD APPEAR CLEAR THAT THE COURT REITERATED THA T SO LONG AS THE INGREDIENTS OF SECTION 147 ARE FULFILLED AN INTIMA TION ISSUED UNDER SECTION 143(1) CAN BE SUBJECTED TO PROCEEDINGS FOR REOPENIN G. THE COURT ALSO EMPHASISED THAT THE ONLY REQUIREMENT FOR DISTURBING THE FINALITY OF AN INTIMATION IS THAT THE ASSESSING OFFICER SHOULD HAV E REASON TO BELIEVE THAT INCOME CHARGEABLE TO TAX HAS ESCAPED ASSESSMENT. IN OUR OPINION, THE SAID EXPRESSION SHOULD APPLY TO AN INTIMATION IN THE SAM E MANNER AND SUBJECT TO THE SAME INTERPRETATION AS IT WOULD HAVE APPLIED TO AN ASSESSMENT MADE UNDER SECTION 143(3). THE ARGUMENT OF THE REVENUE T HAT AN INTIMATION CANNOT BE EQUATED TO AN ASSESSMENT, RELYING UPON CE RTAIN OBSERVATIONS OF THE SUPREME COURT IN RAJESH JHAVERI (SUPRA) WOULD ALSO APPEAR TO BE SELF- DEFEATING, BECAUSE IF AN INTIMATION IS NOT AN AS SESSMENT THEN IT CAN NEVER BE SUBJECTED TO SECTION 147 PROCEEDINGS, FOR, THAT SECTION COVERS ONLY AN ASSESSMENT AND WE WONDER IF THE REVENUE WOULD BE PREPARED TO CONCEDE THAT POSITION. IT IS NOBODYS CASE THAT AN INTIMAT ION CANNOT BE SUBJECTED TO SECTION 147 PROCEEDINGS; ALL THAT IS CONTENDED B Y THE ASSESSEE, AND QUITE RIGHTLY, IS THAT IF THE REVENUE WANTS TO INVOKE SEC TION 147 IT SHOULD PLAY BY THE RULES OF THAT SECTION AND CANNOT BOG DOWN. IN O THER WORDS, THE EXPRESSION REASON TO BELIEVE CANNOT HAVE TWO DIFFERENT STAND ARDS OR SETS OF MEANING, ONE APPLICABLE WHERE THE ASSESSMENT WAS EARLIER MAD E UNDER SECTION 143(3) AND ANOTHER APPLICABLE WHERE AN INTIMATION WAS EARL IER ISSUED UNDER SECTION 143(1). IT FOLLOWS THAT IT IS OPEN TO THE ASSESSEE TO CONTEND THAT NOTWITHSTANDING THAT THE ARGUMENT OF CHANGE OF OPI NION IS NOT AVAILABLE TO HIM, IT WOULD STILL BE OPEN TO HIM TO CONTEST THE R EOPENING ON THE GROUND THAT THERE WAS EITHER NO REASON TO BELIEVE OR THAT THE A LLEGED REASON TO BELIEVE IS NOT RELEVANT FOR THE FORMATION OF THE BELIEF THAT I NCOME CHARGEABLE TO TAX HAS ESCAPED ASSESSMENT. IN DOING SO, IT IS FURTHER OPEN TO THE ASSESSEE TO CHALLENGE THE REASONS RECORDED UNDER SECTION 148(2) ON THE GR OUND THAT THEY DO NOT MEET THE STANDARDS SET IN THE VARIOUS JUDICIAL PRON OUNCEMENTS. ITA NOS.628 TO 630/AHD/2012 SHARP METAL OVERSEAS VS. ACIT FOR AYS 1999-00, 2000-01& 2002-03 6 14. IN THE PRESENT CASE THE REASONS DISCLOSE THAT THE ASSESSING OFFICER REACHED THE BELIEF THAT THERE WAS ESCAPEMENT OF INC OME ON GOING THROUGH THE RETURN OF INCOME FILED BY THE ASSESSEE AFTER HE AC CEPTED THE RETURN UNDER SECTION 143(1) WITHOUT SCRUTINY, AND NOTHING MORE. THIS IS NOTHING BUT A REVIEW OF THE EARLIER PROCEEDINGS AND AN ABUSE OF P OWER BY THE ASSESSING OFFICER, BOTH STRONGLY DEPRECATED BY THE SUPREME CO URT IN CIT VS. KELVINATOR (SUPRA). THE REASONS RECORDED BY THE ASS ESSING OFFICER IN THE PRESENT CASE DO CONFIRM OUR APPREHENSION ABOUT THE HARM THAT A LESS STRICT INTERPRETATION OF THE WORDS REASON TO BELIEVE VIS --VIS AN INTIMATION ISSUED UNDER SECTION 143(1) CAN CAUSE TO THE TAX REGIME. T HERE IS NO WHISPER IN THE REASONS RECORDED, OF ANY TANGIBLE MATERIAL WHICH CA ME TO THE POSSESSION OF THE ASSESSING OFFICER SUBSEQUENT TO THE ISSUE OF THE IN TIMATION. IT REFLECTS AN ARBITRARY EXERCISE OF THE POWER CONFERRED UNDER SEC TION 147. 8. THE ABOVE DECISION WOULD BE SQUARELY APPLICABLE TO THE FACTS OF THE ASSESSEES CASE; BECAUSE, THE FACTS OF THE ASSESSEE S CASE ARE IDENTICAL TO THE FACTS BEFORE THE HONBLE DELHI HIGH COURT IN THE CA SE OF ORIENT CRAFT LTD (SUPRA). NO CONTRARY DECISION IS BROUGHT TO OUR KN OWLEDGE. IT WAS ALSO POINTED OUT BY THE LD. COUNSEL THAT THE HONBLE APE X COURT HAS REJECTED THE SLP FILED BY THE REVENUE AGAINST THE DECISION OF HO NBLE DELHI HIGH COURT. COPY OF THE SLP REJECTION IS FILED BEFORE US, WHERE IN THE HONBLE APEX COURT REJECTED THE SLP OBSERVING WE FIND NO REASON TO ENTERTAIN THIS SPECIAL LEAVE PETITION, WHICH IS ACCORDINGLY DISMISSED. IN VIEW OF ABOVE, WE, RELYING UPON THE DECISION OF HONBLE DELHI HIGH COURT IN THE CAS E OF ORIENT CRAFT LTD (SUPRA), HOLD THAT THE CONDITIONS FOR RE-OPENING OF ASSESSMENT U/S 147 WERE NOT SATISFIED. WE, THEREFORE, QUASH THE RE-OPENING OF ASSESSMENT. SINCE THE FACTS IN ALL THE THREE YEARS ARE IDENTICAL, WE QUAS H THE RE-OPENING OF ASSESSMENT FOR ALL THE THREE YEARS UNDER APPEAL BEF ORE US, I.E., ASSESSMENT YEARS 1999-2000, 2000-2001 AND 2002-03. ITA NOS.628 TO 630/AHD/2012 SHARP METAL OVERSEAS VS. ACIT FOR AYS 1999-00, 2000-01& 2002-03 7 9. SINCE WE HAVE ALREADY QUASHED THE RE-OPENING OF ASSESSMENT, THE OTHER GROUNDS RAISED BY THE ASSESSEE WITH REGARD TO MERITS OF THE ADDITION NEED NO ADJUDICATION. 10. IN THE RESULT, ASSESSEES APPEALS ARE ALLOWED. ORDER PRONOUNCED IN THE COURT ON 23 RD JULY, 2015 AT AHMEDABAD. SD/- SD/- (KUL BHARAT) JUDICIAL MEMBER (G.D. AGRAWAL) VICE-PRESIDENT AHMEDABAD; DATED 23/07/2015 BIJU T., PS )* # $+ ,)+$ )* # $+ ,)+$ )* # $+ ,)+$ )* # $+ ,)+$/ COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT. 3. $ !- / CONCERNED CIT 4. !- ( ) / THE CIT(A) 5. +01 $ , , / DR, ITAT, AHMEDABAD 6. 13 4' / GUARD FILE . )*! )*! )*! )*! / BY ORDER, TRUE COPY 5 55 5/ // / 6 6 6 6 ( DY./ASSTT.REGISTRAR) , , , , / ITAT, AHMEDABAD