The Income-tax Officer, Amritsar. V. M/s. Rajiv Exports, Amritsar.

ITA 72/ASR/2012

• Counselvise Citation: 7220914 RSA 2012
• Duration Of Justice: 44 year(s) 3 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 29-04-2014
• Appeal Filed By: Department
• Assessment Year: misc
• Appeal Filed On: 01-01-1970
• Court: TRIBUNAL
• Keywords: Unexplained investment; Business income; Depreciation; Bad and doubtful debts
• Section: 143(3); 133A; 133(6)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH; AMRITSAR. BEFORE SH. H.S. SIDHU, JUDICIAL MEMBER AND SH. B.P. JAIN, ACCOUNTANT MEMBER I.T.A. NO.72 (ASR)/2012 ASSESSMENT YEAR: 2007-08 PAN:AABFR2412C INCOME TAX OFFICER, VS. M/S RAJIV EXPORTS, 49-KO T WARD 3(3), AMRITSAR MAHNA SINGH, TARN TARAN ROAD, AMRITSAR (APPELLANT) (RESPONDENT) AND C.O. NO. 13(ASR)/2012 [IN I.T.A. NO.72 (ASR)/2012] ASSESSMENT YEAR: 2007-08 PAN:AABFR2412C INCOME TAX OFFICER, VS. M/S RAJIV EXPORTS, 49-KO T WARD 3(3), AMRITSAR MAHNA SINGH, TARN TARAN ROAD, AMRITSAR (APPELLANT) (RESPONDENT) APPELLANT BY: SH. TARSEM LAL, DR RESPONDENT BY: SH. SALIL KAPOOR, ADVOCATE DATE OF HEARING: 21.04.2014 DATE OF PRONOUNCEMENT: 29.04.2014 ORDER PER BENCH 1. THE REVENUE HAS FILED THE PRESENT APPEAL AGAINST THE IMPUGNED ORDER DATED 29.12.2011 PASSED BY LEARNED CIT(A), AM RITSAR, FOR THE 2 ASSESSMENT YEAR 2007-08. THE ASSESSEE HAS ALSO FILE D CROSS OBJECTION AGAINST ORDER OF LEARNED CIT(A), AMRITSAR. 2. LEARNED FIRST APPELLATE AUTHORITY HAS NARRATED T HE BRIEF FACTS OF THE PRESENT CASE ON THE ISSUE IN DISPUTE IN PARA NO S. 4 TO 4.4 (PAGE NOS. 2 TO 4), THE SAME IS REPRODUCED AS UNDER, FOR THE SAK E OF CONVENIENCE: 4. BRIEFLY, IN THIS CASE OF A PARTNERSHIP FIRM DE RIVING BUSINESS INCOME FROM MANUFACTURING OF JUTE PRINTED BAGS AND TRADING OF JUTE PRODUCTS, RETURN DECLARING AN INCOME OF RS. 16,370/ - FILED ON 25.10.2007 WAS PROCESSED U/S 143(1) ON 23.03.2009. SINCE THIS CASE WAS COVERED UNDER SURVEY CONDUCTED U/S 133A ON 24.08.2006, THE CASE WAS TAKEN UP FOR COMPULSORY SCRUTINY. DURING THE COURSE OF SURVE Y, CLOSING STOCK OF RS. 3,19,801/- WAS FOUND AT THE BUSINESS PREMISES O F THE APPELLANT. DURING ASSESSMENT PROCEEDINGS, THE APPELLANT FURNIS HED SEPARATE TRADING FOR THE PERIOD 1.4.6 TO 24.8.06 AND FROM 24.8.06 TO 31.3.07 DISCLOSING G.P. RATE OF 4.93% FOR BOTH THE PERIOD. THE CLOSING STOCK AS ON 24.08.2006 HAS BEEN SHOWN AT RS. 4,24,300/- AS AGAI NST THE STOCK FOUND ON PHYSICAL VERIFICATION AS ON THE DATE OF SURVEY A T RS. 3,19,801/-. FURTHER, AS PER TRIAL BALANCE TAKEN AT THE TIME OF SURVEY, THE INPUT TAX CREDIT WAS SHOWN AT RS. 3,03,646/- AND OUTPUT TAX C REDIT AT RS. 2,15,585/-. VIDE SHOW CAUSE NOTICE, THE APPELLANT WAS REQUIRED TO RECONCILE THE APPARENT VARIATION AND DISCREPANCY IN VIEW OF THE F ACT THAT VAT @ 4% IS APPLICABLE IN THIS LINE OF APPELLANTS BUSINESS. ON SALES OF RS. 53,89,265/- BY APPLYING G.P. RATE OF 4.93%, THE GROSS PROFIT C OMES AT RS. 2,65,708/- AS AGAINST RS. 2,258/- SHOWN IN THE TRADING ACCOUNT PREPARED AT THE TIME OF SURVEY. AFTER TAKING INTO ACCOUNT THE ABOVE GROS S PROFIT OF RS. 2,65,708/- THE INVESTMENT IN PURCHASE AMOUNTED TO R S. 24,67,208/- WHICH HAVE BEEN MADE BY THE APPELLANT FROM UNDISCLOSED SO URCES AND ADDITION TO THIS EXTENT WAS PROPOSED BY THE A.O. IN THIS SHO W CAUSE NOTICE. CONSIDERING THE APPELLANTS REPLY (DULY REPRODUCED IN THE ASSESSMENT ORDER ITSELF) TO THIS SHOW CAUSE NOTICE WHEREIN THE ONLY EXCUSE TAKEN IS THAT SINCE AT THE TIME OF SURVEY, ITS ACCOUNT BOOKS FOR THE ACCOUNTING PERIOD ENDED 31.3.06 WERE LYING UN-AUDITED AND AS S UCH OPENING BALANCE FOR F.Y. 2006-07 WERE WITHOUT ADJUSTMENT. HOWEVER, THIS REPLY OF THE APPELLANT DID NOT MERIT CONSIDERATION WITH THE A.O. IT IS OPINED BY THE 3 A.O. THAT NO ADJUSTMENT OF ACCOUNTS ARE REQUIRED TO BE MADE AT THE TIME OF AUDIT OF BOOKS OF ACCOUNTS. FURTHER, THE CLOSING STOCK FOUND ON PHYSICAL VERIFICATION DURING SURVEY WAS LESS THAN T HE STOCK SHOWN IN THE TRADING ACCOUNT PREPARED AND FILED DURING THE COURS E OF ASSESSMENT PROCEEDINGS WHICH ALSO GOES TO SHOW THAT THE APPELL ANT HAS BEEN INDULGING IN MAKING PURCHASES AND SALES OUTSIDE THE BOOKS OF ACCOUNTS. CONSIDERING THE APPELLANTS EXPLANATION NOTHING BUT AN AFTER-THOUGHT AND SINCE THE TRUE PROFITS FROM THE APPELLANTS BOOKS O F ACCOUNT CANNOT BE WORKED OUT/ADDUCED AS SUCH THE SAME WERE REJECTED. BY REFERRING THE PROVISIONS OF SECTION 292C, THE CONTENTS OF THE BOO KS OF ACCOUNT & OTHER DOCUMENTS FOUND DURING SURVEY U/S 133A TO BE TRUE A ND ALSO BY ADOPTING THE FIGURES OF INPUT TAX CREDIT AND OUTPUT TAX CRED IT AS PER TRIAL BALANCE DRAWN ON THE DATE OF SURVEY ON 24.08.06, THE ASSESS ING OFFICER OBSERVED THAT INVESTMENT IN PURCHASES OF RS. 24,67,208/- REM AINED UNDISCLOSED, BESIDES EARNING PROFIT OF RS. 2,65,708/- ON SALES O F TRS. 53,89,265/- MADE OUTSIDE THE BOOKS OF ACCOUNT (SUPRA), THE A.O. PRO POSED TO MADE AN ADDITION OF RS. 27,32,918/- [RS. 24,67,208/- TOWARD S UNEXPLAINED INVESTMENT IN PURCHASES + GROSS PROFIT OF RS. 2,65, 708/- EARNED ON SALES OF RS. 53,89,265/- ALLEGED TO BE MADE OUTSIDE THE B OOKS]. TRADING ADDITION OF RS. 27,32,916/- HAS BEEN MADE BY THE A. O. ON THIS ACCOUNT. 4.1 FURTHER, THE A.O. HAS MADE ADDITION OF RS. 1,4 4,750/- CLAIMED AS BAD DEBT RECEIVABLE AS SALE CONSIDERATION OF TWO SALE INVOICES NO. 356 DT. 4.5.04 FOR RS. 56,250/- AND OF RS. 88,500/- VID E INVOICE NO. 361 DT. 29.5.04 FROM RAGGA INTERNATIONAL DRAWING INFERENCE FROM THE PARTYS RESPONSE TO INQUIRY NOTICE U/S 133(6) THAT IT OWED ONLY RS. 56,250 AS ON 31.3.07 AND THAT PARTY IS STILL DOING BUSINESS AND HAS NOT BECOME ABSOLUTE BANKRUPT AND DEFUNCT AND GONE IN LIQUIDATION IN THE MARKET. 4.2 FURTHER, IT WAS OBSERVED BY THE A.O. THAT THE APPELLANT HAS MADE INTEREST FREE ADVANCES OF RS. 2,50,000/- EACH TO SH. A.S. YUSUF AND MS. SHEEBA. HOWEVER, THE APPELLANTS REPLY TO THE E FFECT THAT THESE INTEREST FREE ADVANCES ARE OLD & GIVEN FOR PROMOTIN G OVER EXPORTS IN JEDDAH DID NOT FIND FAVOUR WITH THE A.O. ON THE GRO UND THAT AS PER A LETTER DATED 6.2.06 ADDRESSED TO MR. A.S. YUSUF, C/O METRO CARS, D.B. ROAD, KALOOR, KOCHI BY ONE OF THE PARTNERS OF THE FIRM NA MELY, SH. SURINDER S. BHATIA WAS FOUND DURING SURVEY AS PER WHICH IT HAS FORTHCOMING THAT THE LOAN OF RS. 2,50,000/- WAS GIVEN ON INTEREST @ 12% P.A. FOR FOUR MONTHS OF 6.2.06 TO 6.6.06. IN VIEW OF THIS CORROBORATIVE AND RELEVANT EVIDENCE 4 AVAILABLE ON RECORD, THE A.O. CONCLUDED THAT INTERE ST CHARGEABLE OF RS. 60,000/- (@ 12% ON RS. 5,00,000/-) HAS NOT BEEN DIS CLOSED AND ADDITION TO THIS EXTENT HAS BEEN MADE BY THE A.O. 4.3 THE A.O. FURTHER MADE AD-HOC DISALLOWANCE FOR UNDENYING PERSONAL USAGE OF CAR AND TELEPHONE BY THE PARTNERS AS UNDER: (A) RS. 18,902/- @ 1/5 TH OF CAR REPAIR & MAINTENANCE OF RS. 20596/-, PETROL OF RS. 13,250/-, CAR DEPRECIATION OF RS. 60, 666/- (AGGREGATING RS. 94,512/-). (B) RS. 1500/- OUT OF TELEPHONE EXPENSES OF RS. 12, 062/- ON AD-HOC BASIS AS PERSONAL CALLS OF PARTNERS & THEIR FAMILY MEMBER S CANNOT BE RULES OUT. 4.4 AGGRIEVED BY THE FIRST THREE ADDITIONS OF RS. 27,32,916/-(TRADING ADDITION), RS. 1,44,750/- TOWARDS BAD DEBTS, RS. 60 ,000/- TOWARDS NON- DISCLOSURE OF INTEREST ACCRUED @ 12% P.A. ON TWO AD VANCE OF RS. 2,50,000/- EACH, THE APPELLANT HAS FILED THIS APPEA L. 3. AGGRIEVED WITH THE ORDER DATED 09.10.2009 PASSE D BY THE ASSESSING OFFICER UNDER SECTION 143(3) OF THE A CT IN WHICH THE ASSESSING OFFICER MADE THE ADDITION IN DI SPUTE, THE ASSESSEE FILED AN APPEAL BEFORE THE LEARNED FIRST A PPELLATE AUTHORITY, WHO VIDE IMPUGNED ORDER DATED 29.12.2011 , PARTLY ALLOWED THE APPEAL OF THE ASSESSEE. NOW, BEING AGGR IEVED WITH THE ORDER OF LEARNED FIRST APPELLATE AUTHORITY, THE REVENUE FILED THE PRESENT APPEAL CHALLENGING THE ADDITIONS DELETED BY THE LEARNED FIRST APPELLATE AUTHORITY. THE ASSESSEE HAS ALSO FILED HIS CROSS OBJECTION. 5 4. AT THE TIME OF HEARING LEARNED DR RELIED UPON TH E ORDER PASSED BY THE ASSESSING OFFICER AND STATED TH AT THE LEARNED FIRST APPELLATE AUTHORITY HAS WRONGLY DELET ED THE ADDITION OF RS. 27,32,916/- MADE BY THE ASSESSING O FFICER ON ACCOUNT OF INVESTMENT IN PURCHASES FROM UNDISCLOSED SOURCES AND PROFIT ON SALES MADE OUTSIDE THE BOOKS OF ACCOU NTS. HE FURTHER STATED THAT THE SECOND ADDITION AMOUNTING T O RS. 1,44,750/- HAS ALSO WRONGLY BEEN DELETED BY THE LEA RNED FIRST APPELLATE AUTHORITY IN RESPECT OF VAT DEBT. HE RELI ED UPON THE CONTENTION RAISED BY THE REVENUE IN THE GROUNDS OF APPEAL. 5. ON THE CONTRARY LEARNED COUNSEL FOR THE ASSESSEE RELIED UPON THE ORDER PASSED BY LEARNED CIT(A), AMRITSAR. MR. SALIL KAPOOR, ADVOCATE, LEARNED COUNSEL FOR THE ASSESSEE HAS ALSO MADE THE STATEMENT THAT HE DOES NOT WANT TO PRESS T HE CROSS OBJECTION I.E. C.O. NO. 13(ASR)/2012 FILED IN THE PRESENT APPEAL AND REQUESTED THAT THE SAME MAY BE DISMISSED AS WITHDRA WN. HE HAS ALSO ENDORSED THE SAME ON THE ORIGINAL GROUNDS OF APPEAL . 6. KEEPING IN VIEW THE STATEMENT MADE BY MR. SALIL KAPOOR, ADVOCATE, LEARNED COUNSEL FOR THE ASSESSEE, THE C.O . NO. 13(ASR)/2012 FILED IN I.T.A. NO.72 (ASR)/2012 IS DISMISSED AS WITHDRAW . 6 7. AS REGARDS TO THE ADDITION DELETED BY LEARNED FIRST APPELLATE AUTHORITY, WE ARE OF THE CONSIDERED VIEW THAT THE L EARNED FIRST APPELLATE AUTHORITY HAS CAREFULLY CONSIDERED THE ASSESSEES W RITTEN SUBMISSION AS WELL THE DOCUMENTARY EVIDENCE PRODUCED BY THE ASSES SEE AS WELL AS THE ORDER PASSED BY THE ASSESSING OFFICER. LEARNED FIRS T APPELLATE AUTHORITY HAS RIGHTLY HELD THAT THE ADDITION OF RS. 27,32,916 /- WAS MADE ON THE BASIS OF TRIAL BALANCE TAKEN AT THE TIME OF SURVEY ON 24.08.2006 AND IS ALSO BASED ON THE FIGURES OF PURCHASES AND SALES FO R THE PERIOD 01.04.2006 TO 24.08.2006 WHICH ESTIMATED ON THE BASIS OF INPUT TAX CREDIT RS., 3,03,645.59 AND OUTPUT TAX CREDIT RS. 2,15,585.16/- AS PER TRIAL BALANCE TAKEN AT THE TIME OF SURVEY. THE RATE OF VAT APPLIE D TO CALCULATE THE ABOVE PURCHASE/SALE WAS 4%, WHICH IS APPLICABLE TO THE ASSESSEES BUSINESS. LEARNED FIRST APPELLATE AUTHORITY HAS ALS O RIGHTLY HELD THAT THE ASSESSING OFFICER FAILED TO APPRECIATE THE FACTS OF WRITTEN REPLIES FILED DURING THE TIME OF ASSESSMENT PROCEEDINGS THAT THE FIGURES OF INPUT TAX CREDIT AND OUTPUT TAX CREDIT AS PER THE TRIAL BALAN CE MADE AT THE TIME OF SURVEY INCLUDED THE OPENING BALANCES BROUGHT FORWAR DS FROM THE PREVIOUS FINANCIAL YEAR 2005-06 DUE TO NON-COMPLETI ON OF FINALIZATION OF BOOKS OF ACCOUNT. THE COMPLETE RECONCILIATION OF TH E TRIAL BALANCE FOUND AT THE TIME OF SURVEY WITH BOOKS OF ACCOUNTS WERE F ILED AND NO 7 DISCREPANCY WAS POINTED BY THE ASSESSING OFFICER. L EARNED FIRST APPELLATE AUTHORITY IN THE IMPUGNED ORDER HELD THAT THE ASSES SING OFFICER HAS ACCEPTED THE B/FD FIGURE OF INPUT TAX CREDIT (VAT P REPARED) RS. 91,516.43/- AS PER THE AUDITED BALANCE SHEET AS ON 31.03.2006 FILED AT THE TIME OF ASSESSMENT PROCEEDINGS. THE ABOVE AMOUN T WAS OUTSTANDING IN THE INPUT TAX CREDIT A/C AFTER THE ADJUSTMENT OF INPUT TAX CREDIT & OUTPUT TAX CREDIT AT THE TIME OF FINALIZATION & AUD IT OF BOOKS OF ACCOUNT OF THE FINANCIAL YEAR 2005-06. THE ASSESSING OFFICE R HAS IGNORED THE OUTSTANDING BALANCE OF RS. 2,88,171.59/- AS ON 01.0 4.2006 IN THE INPUT TAX CREDIT A/C WHILE ESTIMATING THE PURCHASES OF RS . 75,91,125/- FOR THE PERIOD OF 01.04.2006 TO 24.08.2006 BY APPLYING VAT @ 4% ON THE BALANCE OF I.T.C. OF RS. 3,03,645/- AS PER TRIAL BA LANCE MADE AT THE TIME OF SURVEY. IN FACT, THE I.T.C. DURING THE ABOVE PER IOD WAS ONLY RS. 15,474/- FROM THE PURCHASES OF RS. 3,86,838/- DURIN G THE ABOVE PERIOD WHICH WAS DULY ACCOUNTED FOR IN THE BOOKS. SIMILAR LY, THE ASSESSING OFFICER HAS ALSO IGNORED THE OUTSTANDING BALANCE O F RS. 2,17,070.16/- AS ON 01.04.2006 IN THE OUTPUT TAX CREDIT A/C WHILE ES TIMATING THE SALES OF RS. 53,89,625/- FOR THE PERIOD OF 01.04.2006 TO 24. 08.2006 BY APPLYING VAT @ 4% ON THE BALANCE OF O.T.C. OF RS. 2,15,585.1 6/- AS PER TRIAL BALANCE MADE AT THE TIME OF SURVEY. IN FACT, THE O. T.C. DURING THE ABOVE 8 PERIOD WAS ONLY RS. 3,688/- FROM THE SALES OF RS. 9 2,183/- DURING THE ABOVE PERIOD WHICH WAS DULY ACCOUNTED FOR IN THE B OOKS. DURING THE ABOVE PERIOD, THE ASSESSEE HAD ALSO MADE THE PAYMEN T OF V.A.T. RS. 5,173/-. 8. LEARNED FIRST APPELLATE AUTHORITY HAS ELABORATEL Y APPRECIATED THE EVIDENCE PRODUCED BY THE ASSESSEE BY PASSING A WELL REASONED ORDER IN PARA NOS. 7 TO 7.8 (PAGE NO. 8 TO 10) AND MAINLY H ELD THAT THE ASSESSING OFFICER HAS COMPLETED THE ASSESSMENT ON HYPOTHETICA L AND ARITHMETICAL BASIS WHICH IS NOT PERMISSIBLE UNDER THE LAW. HE HA S MADE THE ASSESSMENT FOR FULL FINANCIAL YEAR AND, THEREFORE, ANY ANALYSI S DURING MID YEAR IS MISLEADING AND UNCALLED FOR. HOWEVER, THE COMPARISO N OF TRADING ACCOUNT WITH THE INPUT TAX ACCOUNT AND OUTPUT TAX ACCOUNT, WHETHER MADE UP TO 24.08.2006 OR FOR THE WHOLE YEAR I.E. 01.04.2005 TO 31.03.2006 FULLY TALLY WITH THE TRADING ACCOUNT AS PER BOOKS OF ACCO UNT. FINALLY, THE LEARNED FIRST APPELLATE AUTHORITY HAS RIGHTLY DELET ED THE ADDITION OF RS. 27,32,912/- AFTER APPRECIATING THE EVIDENCE PRODUCE D BY THE ASSESSEE FOR THE WHOLE YEAR IN DISPUTE. THUS, WE FIND NO INFIRM ITY IN THE IMPUGNED ORDER ON THE DELETION OF ADDITION IN DISPUTE AND WE UPHOLD THE IMPUGNED ORDER ON THIS VERY ISSUE. 9 9. AS REGARDS TO THE ADDITION OF RS. 1,44,750/- MAD E ON ACCOUNT OF DISALLOWANCE OF BAD DEBTS AS CLAIMED BY THE ASSESSE E, LEARNED FIRST APPELLATE AUTHORITY HAS RIGHTLY OBSERVED THAT THE A SSESSEE-FIRM HAS SOLD GOODS TO M/S RAAGA INTERNATIONAL, TARN TARAN ROAD, AMRITSAR IN MAY, 2004 BY THREE BILLS FOR TOTAL AMOUNT OF RS. 1,82,25 0/-. ONLY ONE PAYMENT OF RS. 37,500/- WAS RECEIVED DURING THE FINANCIAL Y EAR 2004-05 AND THE BALANCE OF RS. 1,44,750/- WAS IRRECOVERABLE AND CLA IMED AS BAD DEBTS. ON THE BASIS OF VARIOUS DOCUMENTARY EVIDENCE FILED BY THE ASSESSEE AS WELL AS ON THE BASIS OF JUDGMENT OF HON'BLE SUPREME COURT O F INDIA IN THE CASE OF T.R.F. LTD. VS. COMMISSIONER OF INCOME TAX (2010) 2 30 CTR (SC) 14, THE LEARNED FIRST APPELLATE AUTHORITY DELETED THE A DDITION IN DISPUTE. SECONDLY, IT IS ALSO NOT DISPUTED BY THE ASSESSING OFFICER THAT THE RECOVERY OF AMOUNT IN DISPUTE IS STILL UNRECOVERED. THEREFORE, THE ADDITION IN DISPUTE AMOUNTING TO RS. 1,44,750/- HAS RIGHTLY BEEN DELETED BY LEARNED FIRST APPELLATE AUTHORITY AND WE UPHOLD THE IMPUGNED ORDER ON THE DELETION OF ADDITION OF RS. RS. 1,44,750/-. 10. KEEPING IN VIEW THE FOREGOING DISCUSSIONS, WE AR E OF THE CONSIDERED VIEW THAT THE LEARNED FIRST APPELLATE AU THORITY HAS PASSED A WELL REASONED ORDER ON THE BASIS OF DOCUMENTARY EVI DENCE FILED BY THE ASSESSEE AS WELL AS UNDER THE PROVISIONS OF LAW. TH US, NO INTERFERENCE IS 10 CALLED FOR IN THE IMPUGNED ORDER AND WE UPHOLD THE IMPUGNED ORDER DATED 29.12.2011 PASSED BY LEARNED CIT(A), AMRITSAR, BY D ISMISSING THE APPEAL FILED BY THE REVENUE. 11. IN THE RESULT, THE APPEAL FILED BY THE REVENUE A S WELL AS THE CROSS OBJECTION FILED BY THE ASSESSEE ARE DI SMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 29 TH APRIL, 2014 SD/./- SD/./- (B.P. JAIN) (H.S. SIDHU) ACCOUNTANT MEMBER JUDICIAL MEMBER DATED: 29 TH APRIL, 2014 /RK/ COPY OF THE ORDER FORWARDED TO: 1. THE ASSESSEE: M/S RAJIV EXPORTS, 49-KOT MAHNA SIN GH, TARN TARAN ROAD, AMRITSAR 2. ITO, WARD 3(3), AMRITSAR 3. THE CIT(A), 4. THE CIT, 5. THE SR DR, I.T.A.T., TRUE COPY BY ORDER (ASSISTANT REGISTRAR) INCOME TAX APPELLATE TRIBUNAL, AMRITSAR BENCH: AMRITSAR.