Appeal details
Counselvise Citation
[2022] 106 COUNSELVISE.COM (IT) 9393 (ITAT-RAJKOT)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
5 month(s) 2 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
06-09-2022
Appeal Filed By
Assessee
Order Result
Allowed
Bench Allotted
DB
Assessment Year
2017-2018
Appeal Filed On
03-04-2022
Judgement Text
आयकर अपीलीय अिधकरण, राजकोट Ɋायपीठ IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER And SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER आयकर अपील सं./ITA No. 73/Rjt/2022 िनधाᭅरण वषᭅ/Asstt. Years: 2017-2018 M/s Bhimji Velji Sorathia Construction Private Limited, Plot No.112-113, Arbuda Nagar, Adipur, Kutch-370205. PAN: AAFCB4960Q Vs. The Principal Commissioner of Income Tax, Rajkot-1, Rajkot. (Applicant) (Respondent) Assessee by : Shri Mehul Ranpura, A.R Revenue by : Shri Sanjeev Jain, CIT.D.R सुनवाई कᳱ तारीख/Date of Hearing : 01/07/2022 घोषणा कᳱ तारीख /Date of Pronouncement: 07/09/2022 आदेश/O R D E R PER BENCH : The captioned appeal has been filed at the instance of the Assessee against the order of the Learned Principal Commissioner of Income Tax, Rajkot-1, dated 03/02/2022 arising in the matter of revision order passed under s. 263 of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Year 2017-18. 2. The only interconnected issue raised by the assessee is that the learned Principal CIT erred in holding the assessment framed under section 143(3) of the ITA no.73/Rjt/2022 A.Y. 2017-18 2 Act as erroneous insofar prejudicial to the interest of Revenue under the provisions of section 263 of the Act. 3. The brief facts are that the assessee is a Private Limited company and claimed to be engaged in the business of Civil Contract and sub contract for road work, canal work, civil railway work etc. The assessee has filed its revised return of income on 03-10-2017, declaring total income of Rs. 10,05,13,060.00 only. The case of the assessee was selected for complete scrutiny under CASS. The AO has complete the assessment u/s 143(3) of the Act after making the two addition as detailed under: 1 Claim of CSR expenses disallowed 24,08,834/- 2 Income u/s 2(24)(x) 1,35,936/- 4. Thereafter the AO rectified his assessment order dated 06-06-2020 and reduced addition made on account of Income u/s 2(24)(x) of the Act of Rs. 1,35,936/- as the assessee itself disallowed the same and added to the income. 5. However, the ld. PCIT on examination of the case records of the assessee, found that the assessee has not deducted TDS on transportation expenses amounting to Rs. 6,41.41,573/- claimed in respect of 37 parties. The assessee during the assessment proceeding has neither filed the PAN of these parties nor filed any declaration in respect of non-deduction of TDS from these parties. Furthermore, the amount paid to these parties was exceeding the threshold limit. Therefore, the AO should have disallowed the impugned expenses by 30% of such expenses u/s 40(a)(ia) of the Act. But the AO had omitted to disallow the same. 5.1 Further, the ld. PCIT found that the assessee had claimed expense of Rs. 86,20,934/- in profit & loss account as recovery by principal contractor on account of damage/ slow work in progress. The ld. PCIT observed that these expenses are penal in nature and therefore, the same are not allowable as expenses. Therefore, ITA no.73/Rjt/2022 A.Y. 2017-18 3 the AO should have disallowed such expense but the AO has omitted to disallow the same. According to the learned PCIT, these two issues were not verified during the assessment proceedings by the AO. Accordingly, the PCIT initiated the proceedings under section 263 of the Act vide show cause notice dated 16 January 2022. 6. The assessee in response to such show cause notice submitted that the assessment order passed by the AO is neither erroneous nor prejudicial to the interest of Revenue as the AO has made proper inquiries and verification before during the assessment proceedings. The assessee provided all the details, documents and clarification at the time of assessment proceeding as per the questionnaire issued by the AO along with notice u/s 142(1) of the Act. 6.1 Similarly, the assessee further submitted that during the assessment proceeding it have provided all the details and documents in respect of deduction and non-deduction of TDS on all the expenses, in response to information called u/s 142(1) of the Act. The assesse also submitted that it has already furnished the PAN of all parties including the transporter. 6.2 Likewise, the assessee in respect its claim for the expenses of Rs. 86,20,934/- submitted, that this amount has been recovered by the principal from the bills raised by it on account of star rate, and quantity, measurements difference, testing charges and stores/materials issued by the principal contractee. Furthermore, these expenses were borne by the principal contractee on behalf of it. Therefore the expenses are not penal in nature and thus no disallowance is required. 7. However, the ld. PCIT after considering the assessment records and submission of the assessee, observed as under: 1) The assessee has 1 st time furnished non-deduction of TDS declaration form of these 37 parties. Such declarations were not provided before the AO. ITA no.73/Rjt/2022 A.Y. 2017-18 4 Therefore it is clear that the AO was not carried out full verification of the issue of non-deduction of TDS. 2) The assessee furnished detailed submission in respect of expenses amounting to Rs. 86,20,934/- but these were not provided to the AO during the assessment proceedings. Therefore, the same needs to be verified by the AO. 7.1 In view of the above, the Ld. PCIT held that the assessment has been framed without necessary verification. Therefore, the same is erroneous insofar prejudicial to the interest of Revenue. 8. Being aggrieved by the order of the learned PCIT, the assessee is in appeal before us. 9. The learned AR before us filed a paper book running from pages 1 to 270 and contended that the assessment was framed by the AO after considering the necessary details and verification and application of mind. The learned AR in support of his contention drew our attention on pages 29 to 37 where copy of the notice under section 142(1) of the Act dated 23-10-2019 was placed where the assessee was asked to furnish the details of the expenses where the TDS was not deducted by the assessee as well as the detail of expenses where the assessee has paid above Rs.1 lacs. Likewise, the learned AR also drew our attention on pages 38 to 55 of the paper book where the reply of the assessee in response to the notice issued under section 142(1) of the Act as mentioned above was placed. 9.1 Likewise, the learned AR also drew our attention on pages 56 to 76 of the paper book where the breakup of head wise expenses with the amount paid above Rs. 1 lac was filed, in response to the notice issued under section 142(1) of the Act as mentioned above was placed. Thus, the learned AR contended that there cannot ITA no.73/Rjt/2022 A.Y. 2017-18 5 be said that the assessment order is erroneous and causing prejudice to the interest of Revenue in the given facts and circumstances. 9.2 The Ld. AR of the assessee further submitted that the PAN of the 37 transporters were already provided under the list of sundry creditors to the AO during the assessment proceeding. The learned AR in support of his contention drew our attention on pages 34 where the copy of the notice under section 142(1) of the Act dated 23-10-2019 was placed where the assessee was asked to furnish the list of sundry creditors along with PAN in prescribed format. Likewise, the learned AR also drew our attention on pages 77 to 106 of the paper book where the party wise details of sundry creditors for 3 years was furnished in response to the notice issued under section 142(1) of the Act as mentioned above was placed. Thus, the learned AR contended that it cannot be said that the assessment order is erroneous and causing prejudice to the interest of Revenue in the given facts and circumstances. 9.3 The Ld. AR of the assessee also contended that the assessment was framed by the AO after considering the necessary details and verification and application of mind. The learned AR in support of his contention drew our attention on pages 29 to 37 where copy of the notice under section 142(1) of the Act dated 23-10-2019 was placed where the assessee was asked to furnish the head wise breakup of expenses paid by assessee above Rs. 1 lac as well as the details of any penalty imposed during the year under consideration for any violation of law. Likewise, the learned AR also drew our attention on pages 38 to 55 of the paper book where the reply of the assessee in response to the notice issued under section 142(1) of the Act as mentioned above was placed. likewise, the learned AR also drew our attention on pages 56 to 76 of the paper book where the breakup of head wise expenses where amount paid was above Rs. 1 lac , this list also contains the expenses paid under dispute which was furnished in response to the notice issued under section 142(1) of the Act as mentioned above. Thus, the learned AR contended that there ITA no.73/Rjt/2022 A.Y. 2017-18 6 cannot be said that the assessment order is erroneous and causing prejudice to the interest of Revenue in the given facts and circumstances. 9.4 The Ld. AR before us also contended that the these expenses were recovered by the Principal contractee from the assessee against the RA bills on account of star rate, and quantity measurement difference and testing charges and store/ material issued by the principal contractee and expenses done by the principal on behalf of the assessee. Therefore, the nature of such deduction is not penal in nature and it is not an expenses on account of penalty for contravention of any of the provision of law for the time being in force. 10. On the contrary, the learned DR vehemently supported the order of the authorities below. 11. We have heard the rival contentions of both the parties and perused the materials available on record. The issue in the present case relates whether the assessment order has been passed by Ld. AO without making inquiries or verification with respect to the disallowance of transportation expenses where the TDS has not been deducted by the assessee as well as expenses claim in respect of amount deducted by the principal contractee as discussed above and hence the assessment is erroneous insofar prejudicial to the interest of the Revenue and thus requiring revision by Pr. CIT u/s 263 of the Act. 11.1 An inquiry made by the Assessing Officer, considered inadequate by the Commissioner of Income Tax, cannot make the order of the Assessing Officer erroneous. In our view, the order can be erroneous if the Assessing Officer fails to apply the law rightly on the facts of the case. As far as adequacy of inquiry is considered, there is no law which provides the extent of inquiries to be made by the Assessing Officer. It is Assessing Officer’s prerogative to make inquiry to the extent he feels proper. The Commissioner of Income Tax by invoking revisionary powers ITA no.73/Rjt/2022 A.Y. 2017-18 7 under section 263 of the Act cannot impose his own understanding of the extent of inquiry. There were a number of judgments by various Hon’ble High Courts in this regard. 11.2 Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon’ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot be set aside u/s 263 of the Act on the ground of inadequate inquiry. The relevant observation of Hon’ble Delhi High Court reads as under: “12. ..... There are judgments galore laying down the principle that the Assessing Officer in the assessment order is not required to give detailed reason in respect of each and every item of deduction, etc. Therefore, one has to see from the record as to whether there was application of mind before allowing the expenditure in question as revenue expenditure. Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between “lack of inquiry” and “inadequate inquiry”. If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass orders under section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of “lack of inquiry”, that such a course of action would be open. ——— From the aforesaid definitions it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him, the order should have been written more elaborately. This section does not visualise a case of substitution of the judgment of the Commissioner for that of the Income-tax Officer, who passed the order unless the decision is held to be erroneous. Cases may be visualised where the Income-tax Officer while making an assessment examines the accounts, makes enquiries, applies his mind to the facts and circumstances of the case and determines the income either by accepting the accounts or by making some estimate himself. The Commissioner, on perusal of the records, may be of the opinion that the estimate made by the officer concerned was on the lower side and left to the Commissioner he would have estimated the income at a figure higher than the one determined by the Income-tax Officer. That would not vest the Commissioner with power to re- examine the accounts and determine the income himself at a higher figure. It is because the Income-tax Officer has exercised the quasi-judicial power vested in him in accordance with law and arrived at conclusion and such a conclusion cannot be termed to be erroneous simply because the Commissioner does not feel satisfied with the conclusion. There must be some prima facie material on record to show that tax which was lawfully exigible has not been imposed or that by the application of the relevant statute on an incorrect or incomplete interpretation a lesser tax than what was just has been imposed. 15. Thus, even the Commissioner conceded the position that the Assessing Officer made the inquiries, elicited replies and thereafter passed the assessment order. The grievance of the Commissioner was that the Assessing ITA no.73/Rjt/2022 A.Y. 2017-18 8 Officer should have made further inquires rather than accepting the explanation. Therefore, it cannot be said that it is a case of ‘lack of inquiry’.” 11.3 The Hon’ble Bombay High Court in case of Gabriel India Ltd. [1993] 203 ITR 108 (Bom), discussed the law on this aspect in length in the following manner: “The consideration of the Commissioner as to whether an order is erroneous in so far as it is prejudicial to the interests of the Revenue, must be based on materials on the record of the proceedings called for by him. If there are no materials on record on the basis of which it can be said that the Commissioner acting in a reasonable manner could have come to such a conclusion, the very initiation of proceedings by him will be illegal and without jurisdiction. The Commissioner cannot initiate proceedings with a view to starting fishing and roving enquiries in matters or orders which are already concluded. Such action will be against the well-accepted policy of law that there must be a point of finality in all legal proceedings, that stale issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity. 11.4 The Mumbai ITAT in the case of Sh. Narayan Tatu Rane Vs. ITO, I.T.A. No. 2690/2691/Mum/2016, dt. 06.05.2016 examined the scope of enquiry under Explanation 2(a) to section 263 in the following words:- “20. Further clause (a) of Explanation states that an order shall be deemed to be erroneous, if it has been passed without making enquiries or verification, which should have been made. In our considered view, this provison shall apply, if the order has been passed without making enquiries or verification which a reasonable and prudent officer shall have carried out in such cases, which means that the opinion formed by Ld Pr. CIT cannot be taken as final one, without scrutinising the nature of enquiry or verification carried out by the AO vis- à-vis its reasonableness in the facts and circumstances of the case. Hence, in our considered view, what is relevant for clause (a) of Explanation 2 to sec. 263 is whether the AO has passed the order after carrying our enquiries or verification, which a reasonable and prudent officer would have carried out or not. It does not authorise or give unfettered powers to the Ld Pr. CIT to revise each and every order, if in his opinion, the same has been passed without making enquiries or verification which should have been made. In our view, it is the responsibility of the Ld Pr. CIT to show that the enquiries or verification conducted by the AO was not in accordance with the enquries or verification that would have been carried out by a prudent officer. Hence, in our view, the question as to whether the amendment brought in by way of Explanation 2(a) shall have retrospective or prospective application shall not be relevant.” 11.5 The Hon’ble Supreme Court in recent case of Principal Commissioner of Income-tax 2 v. Shree Gayatri Associates*[2019] 106 taxmann.com 31 (SC), held that where Pr. CIT passed a revised order after making addition to assessee's income under section 69A in respect of on-money receipts, however, said ITA no.73/Rjt/2022 A.Y. 2017-18 9 order was set aside by Tribunal holding that AO had made detailed enquiries in respect of such on-money receipts and said view was also confirmed by High Court, SLP filed against decision of High Court was liable to be dismissed. The facts of this case were that pursuant to search proceedings, assessee filed its return declaring certain unaccounted income. The Assessing Officer completed assessment by making addition of said amount to assessee's income. The Principal Commissioner passed a revised order under section 263 on ground that Assessing Officer had failed to carry out proper inquiries with respect to assessee's on money receipt. In appeal, the Tribunal took a view that Assessing Officer had carried out detailed inquiries which included assessee's on-money transactions and Tribunal, thus, set aside the revised order passed by Commissioner. The Hon’ble High Court upheld Tribunal's order. The Hon’ble Supreme Court while dismissing the SLP filed by the Department held as under:- “We have heard learned counsel for the Revenue and perused the documents on record. In particular, the Tribunal has in the impugned judgment referred to the detailed correspondence between Assessing Officer and the assessee during the course of assessment proceedings to come to a conclusion that the Assessing Officer had carried out detailed inquiries which includes assessee's on-money transactions. It was on account of these findings that the Tribunal was prompted to reverse the order of revision. No question of law arises. Tax Appeal is dismissed” 11.6 The Supreme Court in the another recent case of Principal Commissioner of Income-tax-2, Meerut v. Canara Bank Securities Ltd[2020] 114 taxmann.com 545 (SC), dismissed the Revenue’s SLP holding that 263 proceedings are invalid when AO had made enquiries and taken a plausible view in law, with the following observations: “Having heard learned counsel for the parties and having perused the documents on record, we see no reason to interfere with the view of the Tribunal. The question whether the income should be taxed as business income or as arising from the other source was a debatable issue. The Assessing Officer has taken a plausible view. More importantly, if the Commissioner was of the opinion that on the available facts from record it could be conclusively held that income arose from other sources, he could and ought to have so held in the order of revision. There was simply no necessity to remand the proceedings to the Assessing Officer when no further inquiries were called for or directed” 11.7 From an analysis of the above judicial precedents, the principle which emerges is that the phrase 'prejudicial to the interests of the revenue' has to be ITA no.73/Rjt/2022 A.Y. 2017-18 10 read in conjunction with an erroneous order passed by the Assessing Officer. Every loss of revenue as a consequence of an order of the Assessing Officer cannot be treated as prejudicial to the interests of the revenue, for example, when an Assessing Officer adopts one of the course permissible in law and it has resulted in loss of revenue; or where two views are possible and the Assessing Officer has taken one view with which the Commissioner of Income-tax does not agree, it cannot be treated as an erroneous order causing prejudice to the interests of the Revenue unless the view taken by the Assessing Officer is unsustainable in law, or the AO has completely omitted to make any enquiry altogether or the order demonstrates non-application of mind. 11.8 Now coming to the facts before us, we find that the AO during the course of assessment proceedings, made enquiries on this issue and after consideration of written submissions filed by the assessee and documents / evidence placed on record, and then framed the assessment under section 143(3) accepting the return of income. This fact can be verified from the notice under section 142(1) of the Act by the AO and reply of the assessee thereto against such notice. In respect of non-deduction of TDS i. Notice dated 23-10-2019: 38. Furnish details of TDS deducted for various expenses with supporting TDS return & proof of payment of TDS to Govt. treasury details of expenses where TDS not deducted with explanation for non-deduction and disallowance in computation. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX 44. Furnish breakup of head wise expenses where amount paid was above Rs.1.00 lac in the following format. Name Address Amount paid Head/nature of expense TDS deducted Amount outstading payable Date of subsequent payment XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX ITA no.73/Rjt/2022 A.Y. 2017-18 11 27. Party wise details of sundry creditors in the following format. Sr.N o Name & complete postal address of the creditor which have been shown as outstanding/ to be payable as on 31.03.2017 PA N Balalnc e as on 31-03- 2015 Balanc e on 31-03- 2016 Balanc e as on 31-03- 2017 Date of subseque nt payment Balance as on 31.03.201 8 ii. Reply dated 04-11-2019 38. DETAILS OF QUARTERLTY STATEMENT OF TDS DEDUCTED We attached herewith copy of challans of TDS paid with acknowledgement of TDS returns filed for the F.Y. 2016-17. We attached herewith copy of quarterly TDS returns with acknowledgements. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX 44. BREAK UP OF HEAD WISE EXPENSES MORE THAN RS.1.00 LAKH We attached herewith a statement showing break up of head wise expenses more than 1 lakhs during the year under consideration. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX We attached herewith a statement showing details of sundry creditors as per given format. In respect of expenses of Rs. 86,20,934/- i. Notice dated 23-10-2019: 44. Furnish breakup of head wise expenses where amount paid was above Rs.1.00 lac in the following format. Name Address Amount paid Head/nature of expense TDS deducted Amount outstading payable Date of subsequent payment ITA no.73/Rjt/2022 A.Y. 2017-18 12 46. Details of penalty imposed during the year for any violation of law and whether the same has been disallowed in computation of income. ii. Reply dated 04-11-2019 44. BREAK UP OF HEAD WISE EXPENSES MORE THAN RS.1.00 LAKH We attached herewith a statement showing break up of head wise expenses more than 1 lakhs during the year under consideration. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX 46. DETAILS OF PENALTY We attached herewith computation of income for the year under consideration. We have already disallowed RTO penalty of Rs.4,758/- and interest on TDS of Rs.1,30,344/- in return of income filed. Breakup of head wise expenses where amount paid was above rs.1.00 lac Name Amount Head/nature of expenses TDS deducte d Amount outstandin g payable Date of subsequen t payment HCC- ASHAPURA ROADLINES -KBC BRANCH 37,99,655.0 0 RECOVERY/DEDUCTIO N BY PRINCIPAL - - RUNNING A/C XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX National Highway, Dn./Surjbari Sefty Wall in Creak 17,72,174.00 RECOVERY/DEDUCTION BY PRINCIPAL - - RUNNING A/C XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX R & B PANCHAYAT DN. SATAPAR- MITHIROHAR ROAD 28,13,637.00 RECOVERY/DEDUCTION BY PRINCIPAL - - RUNNING A/C XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX SSNNL KBC- KUTCH BRANCH CANAL 2,35,468.00 RECOVERY/DEDUCTION BY PRINCIPAL - - RUNNING A/C ITA no.73/Rjt/2022 A.Y. 2017-18 13 11.9 From the above it is revealed it is not the case that the AO has not made any enquiry. Indeed the ld. Pr. CIT initiated proceedings under section 263 of the Act on the ground that the AO has not made enquiries or verification which should have been made in respect of non- deduction of TDS as well as expenses claimed in respect of amount deducted by the principal contractee. It is not the case of the Pr. CIT that the Ld. AO did not apply his mind to the issue on hand or he had omitted to make enquiries altogether. In the instant set of facts, the AO had made enquiries and after consideration of materials placed on record accepted the genuineness of the claim of the assessee. 11.10 At this juncture, it is also important to note that the learned PCIT in his order passed under section 263 of the Act has made reference to the explanation 2 of section 263 of the Act. It was attempted by the learned PCIT to hold that there were certain necessary enquiries which should have been made by the AO during the assessment proceedings but not conducted by him. Therefore, on this reasoning the order of the AO is also erroneous insofar prejudicial to the interest of revenue. In this regard, we make our observation that the learned PCIT has not invoked the explanation 2 of section 263 of the Act in the show cause notice dated 17 January 2022 about the same. Therefore, the opportunity with respect to the explanation 2 of section 263 of the Act was not afforded to the assessee. Thus, on this count the learned PCIT erred in taking the course of such provisions while deciding the issue against the assessee. Secondly, the learned PCIT has also not specified the nature and the manner in which the enquiries which should have been conducted by the AO in the assessment proceedings. Thus, in the absence of any specific finding of the learned PCIT with respect to the enquiries which should have been made, we are not convinced by his order passed under section 263 of the Act. 11.11 In view of the above and after considering the facts in totality, we hold that there is no error in the assessment framed by the AO under section 143(3) causing ITA no.73/Rjt/2022 A.Y. 2017-18 14 prejudice to the interest of revenue. Thus, the revisional order passed by the learned PCIT is not sustainable and therefore we quash the same. Hence the ground of appeal of the assessee is allowed. 12. In the result, the appeal filed by the assessee is allowed. Order pronounced in the Court on 07/09/2022 at Ahmedabad. Sd/- Sd/- (SIDDHARTHA NAUTIYAL) (WASEEM AHMED) JUDICIAL MEMBER ACCOUNTANT MEMBER (True Copy) Ahmedabad; Dated 07/09/2022 Manish
