JASHWINDER SINGH SACHDEV, MUMBAI V. DCIT CC 47, MUMBAI

ITA 84/MUM/2011

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 84565 (ITAT-MUMBAI)
• Duration Of Justice: 3 year(s) 11 month(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-12-2014
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: I
• Next Hearing Date: 27-11-2014
• Assessment Year: 2007-2008
• Appeal Filed On: 05-01-2011
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: SACHIDANAND DUBEY
• Assessee Lawyers: LAKHMINARAYANAN
• Keywords: Gift; Depreciation; Principle of natural justice; Bonafide belief; Wrong claim
• Section: 132

Judgement Text

I IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH I, MUMBAI . . . . , ! ! ! ! '!! '!! '!! '!! !# !# !# !# , $ $ $ $ BEFORE SHRI RAJENDRA, ACCOUNTANT MEMBER AND SHRI VIVEK VARMA, JUDICIAL MEMBER ITA NO. : 84/MUM/2011 (ASSESSMENT YEAR: 2007-08) JASWINDER SINGH SACHDEV, 306, BEACH HEAVEN, JUHU TARA ROAD, JUHU, VILE PARLE (W), MUMBAI - 400 049 % .: PAN: AVYPS 0172 J VS DCIT, CC-47, MUMBAI %' (APPELLANT) ()%' (RESPONDENT) APPELLANT BY : SHRI LAKHMINARAYANAN RESPONDENT BY : SHRI SACHIDANAND DUBEY *! + ,- /DATE OF HEARING : 27-11-2014 ./0 + ,- / DATE OF PRONOUNCEMENT : 26-12-2014 2 2 2 2 O R D E R '!! '!! '!! '!! !# !# !# !# , : :: : PER VIVEK VARMA, JM: THE APPEAL IS FILED BY THE ASSESSEE AGAINST THE ORDER OF CIT(A)-36, MUMBAI, DATED 18.11.2010, WHEREIN, THE FOLLOWING GROUNDS HAVE BEEN RAISED: ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW: 1. THE LEARNED CIT(A) ERRED IN NOT DELETING IN FULL TH E PENALTY OF RS. 96,05, 076/- LEVIED BY THE AO UNDER SECTION 271(1)( C) OF THE ACT BUT RESTRICTING IT TO AN AMOUNT OF RS. 48,02,538/-. 2. THE LEARNED CIT(A) FAILED TO APPRECIATE THAT THE PE NALTY HAD BEEN LEVIED IN RESPECT OF THE ENTIRE ASSESSED INCOME OF RS. 1,44,34,460/- EVEN THOUGH ADMITTEDLY APPELLANT HAD VOLUNTARILY FI LED RETURN OF INCOME DECLARING RS. 1,32,72,830/- BEFORE ISSUE OF ANY NOTICE OF AO. 3. THE LEARNED CIT(A) FAILED TO APPRECIATE THAT PENATL Y IS NOT LEVIABLE IN RESPECT OF THE FOLLOWING TWO ADDITIONS ALSO: (A) DEPRECIATION OF RS. 5,61,630/- ON FLAT CLAIMED BY A PPELLANT STOCKBROKER WHO CARRIED ON BUSINESS FROM RESIDENCE ALSO (B) GIFT OF RS. 3 LAKS EACH RECEIVED FROM FATHER AND MO THER IN LAW FOR HIS TWO DAUGHTERS. 4. IT IS REQUESTED THAT PENALTY LEVIED ON ENTIRE ASSES SED INCOME MAY PLEASE BE DELETED. 5. IT IS SUBMITTED THAT DISALLOWANCE OF CLAIM REG. DEP RECIATION AND GIFT MADE UNDER BONAFIDE BELIEF DOES NOT JUSTIFY LEVY OF PENALTY. JASWINDER SINGH SACHDEV, ITA 84/M/2011 2 6. IT IS PRAYED THAT THE PENALTY OF RS. 48,02,538/- MA Y PLEASE BE ORDERED TO BE DELETED. 7. THE APPELLANT CRAVES LIBERTY TO ADD, AMEND, ALTER, AND/OR WITHDRAW ANY OF THE ABOVE GROUNDS OF APPEAL. 2. SOLITARY ISSUE INVOLVED IN THIS APPEAL IS SUSTAINING THE PENALTY UNDER SECTION 271(1)(C) AT RS. 48,02,538/- BY THE C IT(A), AS AGAINST RS. 96,05,076/- LEVIED BY THE AO. 3. THE BRIEF FACTS ARE THAT ON 17.10.2006, A SEARCH UNDER SECTION 132(1) WAS CONDUCTED ON THE ASSESSEE AND AS A CONSEQUENCE OF WHICH, ASSESSMENTS UNDER SECTION 153A/1 43(3) WERE FRAMED FOR ASSESSMENT YEAR 2001-02 TO 2006-07. IN STANT ASSESSMENT YEAR IS THE SEARCH YEAR . THE ASSESSEE FILED HIS RETURN OF INCOME OF RS. 23.03.2009 DECLARING THE TOTAL INCOME AT RS. 1,32,72,830/-. HOWEVER, THE AO COMPLETED THE ASSESSMENT ON 30.03.2009 AT GROSS TOTAL FIGURE OF RS. 1,44,72,590/-. 4. IN THE ASSESSMENT PRECEDING FOR THE CURRENT YEAR, T HE AO MADE ADDITIONS UNDER TWO HEADS, I.E. GIFTS AGGREGATING TO RS 6,00,000/-, RECEIVED FROM FATHER AND MOTHER IN LAW OF RS 3,00,000/- EACH AND DISALLOWANCE OF DEPRECIATION COMPUTED O N RESIDENCE, USED FOR PURPOSE OF BUSINESS. 5. THE AO DISALLOWED/ADDED BACK THE ADDITIONS MADE ON THESE COUNTS WHICH SHOWED A DIFFERENCE OF RS. 11,99,760/-, B UT INITIATED PENAL PROCEEDINGS ON THE ENTIRE INCOME ASSESSED AT RS. 1,44,72,590/-. THE AO, THEREFORE, COMPUTED THE TAX ON THIS INCOME AT RS. 48,02,538/-, BUT LEVIED THE PENALTY AT 200%, I.E. AT RS. 96,05,076/-. 6. AGGRIEVED THE ASSESSEE APPROACHED THE CIT(A) BEFORE WHOM, THE ASSESSEE SUBMITTED THAT THE CASE COULD NOT B E REPRESENTED BEFORE THE AO, BECAUSE, HIS FATHER WAS SERIOU SLY ILL AND WHO LATER ON EXPIRED. TAKING THIS FACT INTO CONSIDERATIO N, THE JASWINDER SINGH SACHDEV, ITA 84/M/2011 3 CIT(A) REDUCED THE PENALTY TO THE AMOUNT OF TAX COMPUTE D ON ASSESSED INCOME OF RS. 1,44,72,590/-. 7. SINCE THERE WAS NO COMPLIANCE FORM THE ASSESSEE BEFOR E THE AO, AND PLACING CERTAIN PAPERS BEFORE THE CIT(A), FOR TH E FIRST TIME, THE CIT(A) CALLED FOR REMAND REPORT FROM THE AO. 8. THE AO IN HIS REMAND REPORT GAVE THE FULL DETAILS OF PERSONAL NON COMPANIES AS WELL AS TAX NON-COMPLIANCE. THE AO, THEREFORE, SUBMITTED THAT PENALTY HAD BEEN RIGHTLY LEVIED, AS THE ASSESSEE HAD NOT BEEN FILING HIS RETURNS OF INCOME. 9. AS PER THE PRINCIPALS OF NATURAL JUSTICE, THE CIT(A) FORWARDED THE REMAND REPORT TO THE ASSESSEE, WHO SUBM ITTED HIS REPLY ON 15.11.2010. 10. THE CIT(A), AFTER CONSIDERING THE REPLY OF THE ASSESSE E ON THE REMAND REPORT, OBSERVED, 11. A SEARCH WAS CONDUCTED IN THE CASE OF THE APPE LLANT ON 17.10.2006. HE HAD NEVER FILED ANY RETURN OF INC OME THOUGH HE WAS HAVING SUBSTANTIAL INCOME FOR YEARS TOGETHER. THE APPELLANT WAS DEALING IN STOCKS AS A DAY TRADER AND OUT OF THE EARNINGS FROM THIS BUSINESS, THE APPELLANT HAD MADE HUGE FIXED DEPOSITS RECEIPTS RUN NING IN CRORES. THE APPELLANT ALSO FILED FORM NO. 15G & 15H WITH THE BANK AND RECEIVED THE FULL INTEREST INCOME FROM THE BANK FDS WHICH WAS ALSO CONCEALED FROM THE DEPARTMENT. ONLY WHEN THE SEARCH TOOK PLACE, THE TR UST REGARDING SHARE BUSINESS, HIS INCOME AND APPLICATIO N OF THIS INCOME TO CREATE FDRS WAS UNEARTHED. THE DUE D ATE FOR FILING RETURN OF INCOME FOR AY 2007-08 WAS OCTO BER 2007. HOWEVER, THE APPELLANT FILED THE RETURN OF IN COME ONLY ON 23.03.2009 I.E. AFTER DELAY OF 17 MONTHS. T HE APPELLANT ALSO DID NOT PAY TAX ON THE ADMITTED INCOME, IN THIS REGARD, THE APPELLANT WAS ASKED TO CLARIFY WHETHER THE TAXES HAVE BEEN PAID ON ADMITTED INCOME OR NOT. THE APPELLANT VIDE LETTER DATED 23/01/2010 HAS STATED AS UNDER: 'I MET YOUR HONOUR ON 21' JANUARY IN THE ABOVE MATTER TO CLARIFY THE POSITION REGARDING PAYMENT OF TAX ON ADMITTED INCOME. IT MAY BE EXPLAINED THAT I HAD GIVEN BANK GUARANTEE FOR RS.2,47,00,0001- FROM SARASWAT CO-OP. BANK TO THE I. T DEPARTMENT ADVISING THEM TO ADJUST THE TAXES DUE. AT THE TIME OF FILING THE RETURN, I HAD PAID TAX OF RS 11,00,000/- . I WAS UNDER THE IMPRESSION THAT THE AG WOULD HAVE JASWINDER SINGH SACHDEV, ITA 84/M/2011 4 PAID THE BALANCE OUT OF THE BANK GUARANTEE. AFTER I RECEIVED ENQUIRY FROM YOUR OFFICE, I CONTACTED MY A R SHRI G.Y WAGH. HE IS ON LEAVE UPTO 27.01.2010. FROM HIS OFFICE, I LEARNT THAT A TAX OF RS.22,2 7,000/- HAD BEEN PAID AND I OBTAINED THE ORIGINAL TAX CHALLAN FROM THE OFFICE (COPY ENCLOSED). AS THE AG IS ON LE AVE, I WILL GET THE DETAILS REGARDING BALANCE PAYMENT ON LY AFTER HIS RETURN '. 12. IT CAN BE SEEN FROM THE ABOVE, EVEN AFTER THE APPELLATE PROCEEDINGS STARTED, THE APPELLANT HAD NO T PAID THE TAXES ON THE ADMITTED INCOME. THE APPELLANT VIDE LETTER DATED 16' NOVEMBER 2010 STATED THAT THE TAXES WERE FULLY PAID BY 29' MARCH 2010 AND AT PRESENT NO TAX IS DUE TO BE PAID. HE ALSO ENCLOSED THE CHALLANS FOR THE SAME. HENCE, THE APPEAL OF THE APPELLANT IS NOT BARRED BY 249(4) AND HEARD AND DECIDED. 13. THE APPELLANT WAS DOING SHARE TRADING BUSINESS AND CONVERTING THE INCOME FROM THE SAME IN FIXED DE POSIT RECEIPTS. WITH THE INTENTION TO EVADE TAX, HE WAS A LSO FILING FORM NO. 15G & 15H WITH THE BANK, SO THAT NO TAX IS DEDUCTED AT SOURCE. FURTHER, EVEN AFTER SEARCH, THE APPELLANT HAD NOT FILED THE RETURN OF INCOME FOR 17 MONTHS AND TAXES ON THE SAME WERE ALSO NOT PAID TIL L THE COMMENCEMENT OF THE APPELLATE PROCEEDINGS. IT IS AL SO CLEAR FROM THE FACT THAT THE APPELLANT DID NOT CONT EST THE ADDITION IN APPEAL AS HE HAD NOTHING TO SAY ON THE MATTER. ALL THE ABOVE ACTS POINT TO THE FACT THAT T HE APPELLANT WANTED TO AND EVADED PAYMENT OF TAX. 14. THE APPELLANT HAD ALSO ARGUED THAT THE PENALTY SHOULD BE LEVIED ONLY ON THE TAXES SOUGHT TO BE EVADED ON THE DIFFERENCES OF RETURNED INCOME AND ASSESSED INCOME AND ALSO THAT THE IMMUNITY UNDER SECTION. 271(1)(C) TO EXPLANATION 5 SHOULD BE AVAILABLE HAVE CONSIDERED THE ARGUMENT. RECENTLY, HON'BLE ITAT, 'A ' BENCH, MUMBAI IN THE CASE OF M AJIT B ZOTA VS ACIT, CENTRAL CIRCLE-35, MUMBAI 400020 IN ITA. NO.7325/MUM/2008 DATED 16/07/20'0 CONFIRMED THE PENALTY ON THE ABOVE ISSUE. THEREFORE RESPECTFULLY FOLLOWING THE ORDER OF THE HON'BLE ITAT, THE PENALTY IS CONFIRMED ON THIS ACCOUNT ALSO. 15. THE AO HAS LEVIED THE PENALTY OF 200% AS THE APPELLANT NEITHER FILED ANY SUBMISSION NOR APPEARED BEFORE HIM TO CLARIFY THE MATTER. THE PENALTY HAS BEEN LEVIED ON 25/09/2009 WHILE THE FATHER OF THE APPELLANT WHO WAS HOSPITALIZED WITH BRAIN STROKE DIED ON 14/09/2009. HENCE, IT CAN BE SEEN THAT THE APPELLANT WAS PREVENTED FROM APPEARING OR FILING THE DETAILS BEFORE THE AO DUE T O HIS FATHER'S ILLNESS AND DEATH. IN VIEW OF THE ABOV E, PENALTY IS CONFIRMED AT 100% ON TAXES SOUGHT TO BE EVADED INSTEAD OF 200% AS LEVIED BY THE AO. THE APPELLANT THEREFORE GETS RELIEF OF RS. 48 LACS AND THE APPEAL IS PARTLY ALLOWED . JASWINDER SINGH SACHDEV, ITA 84/M/2011 5 11. THE CIT(A), SUSTAINED THE LEVY OF PENALTY BUT REDUCED THE QUANTUM TO 100% OF TAX SOUGHT TO BE EVADED. 12. AGAINST THIS ORDER, THE ASSESSEE IS NOW BEFORE THE ITAT. 13. BEFORE US, THE AR REITERATED HIS INNOCENCE AND SUBMISSIONS MADE BEFORE THE REVENUE AUTHORITIES AND FURTH ER SUBMITTED THAT IF AT ALL THE PENALTY IS TO BE LEVIED THEN IT MUST BE RESTRICTED ONLY TO THE ADDITION MADE TO THE ROI AND IN ANY CASE, NO PENALTY IS TO BE LEVIED ON DEPRECIATION OF RS. 5,61,630/- AND RS. 6,00,000/- RECEIVED AS GIFTS FROM FATHER AND MOTHER IN LAW. 14. THE DR ON THE OTHER HAND SUBMITTED THAT PENALTY H AS BEEN LEVIED ON CONCEALMENT OF INCOME, SINCE THE ASSESSEE, THOUGH HAVING TAXABLE INCOME, WAS NOT FILING HIS RETURN. IT WAS ONLY AFTER THE SEARCH ON HIS PREMISES UNDER SECTION 132 (1), THAT THE ASSESSEE FILED HIS RETURN OF INCOME. THE DR SUBMITTED THAT NOT ONLY IS THIS MOST APPROPRIATE CASE FOR LEVY OF PENALT Y BUT THE CIT(A) WAS MORE THAN REASONABLE TO REDUCE THE QUANTUM OF PENALTY, WHICH, AT LEAST, SHOULD BE SUSTAINED. 15. WE HAVE HEARD THE RIVAL ARGUMENTS AND HAVE PERUSE D THE ORDERS OF THE REVENUE AUTHORITIES. 16. IT IS AN UNDISPUTED FACT THAT THE ASSESSEE HAD NOT BEEN FILING HIS ROI OVER THE YEARS, DESPITE THE FACT THAT HE HA D ENJOYED OVERALL TAXABLE INCOME. IT IS ALSO A FACT THAT THE FACTUM OF THE ASSESSEE NOT FILING THE ROI DESPITE HAVING TAXABLE INCOME WAS UNEARTHED WHEN THE DEPARTMENT UNDERTOOK SEARCH OPER ATIONS OVER THE ASSESSEE. IT WAS ONLY AFTER THE SEARCH AND A FTER A CONSIDERABLY LONG GAP OF 17 MONTHS THAT THE ASSESSEE FINALLY FILED HIS ROI. ALL THESE FACTS CULMINATE INTO THE POSITIVE ASSUMPT ION THAT THE ASSESSEE IS CALLOUS, AND NOT INCLINED TO PAY TAXE S VOLUNTARILY. THIS HAS BEEN PROVED BY THE CIT(A), WHEN HE MADE JASWINDER SINGH SACHDEV, ITA 84/M/2011 6 THE OBSERVATION, FURTHER, EVEN AFTER SEARCH, THE APPELLANT HAD NOT FILED THE RETURN OF INCOME FOR 17 MONTHS AND TAXES O N THE SAME WERE ALSO NOT PAID TILL THE COMMENCEMENT OF THE APPELL ATE PROCEEDINGS. IT IS ALSO CLEAR FROM THE FACT THAT THE APP ELLANT DID NOT CONTEST THE ADDITION IN APPEAL AS HE HAD NOTHING TO S AY ON THE MATTER. ALL THE ABOVE ACTS POINT TO THE FACT THAT THE APPELLANT WANTED TO AND EVADED PAYMENT OF TAX . THIS OBSERVATION, AS MADE BY THE CIT(A) IN THE IMPUGNED ORDER, COULD NOT BE CONTROVERTED BY THE AR BEFORE US. 17. ON THE OTHER HAND, THE ASSESSEE BEFORE THE CIT(A) A ND THE AR BEFORE US, PLACED HEAVY RELIANCE ON THE DECISION OF HON BLE SUPREME COURT OF INDIA, IN THE CASE OF CIT VS RELIANCE PETROPRODUCTS LTD., REPORTED IN 322 ITR 158. WE CANNOT ACCEPT THE ARGUMENTS OF THE AR THAT THE CASE OF CIT VS RELIANC E PETROPRODUCTS LTD. (SUPRA) , FULLY COVERS THE CASE OF THE ASSESSEE. THIS IS BECAUSE OF THE FACT THAT IN THE CASE OF RELIANCE PETROPRODUCTS LTD. ( SUPRA ), THE HONBLE SUPREME COURT FOUND THAT THEIR FOUND CERTAIN CLAIMS WHICH WERE NOT ALLOWABLE, BUT SINCE COMPLETE DETAILS HAD BEEN FURNISHED, THE HONBLE SUP REME COURT CONCLUDED THAT THE FACTS HAD BEEN SHOWN BUT THE ASSESSEE HAD MADE A WRONG CLAIM. THIS WAS AN IMPORTANT FACTOR THA T THE ASSESSEE HAD DISCLOSED ALL MATERIAL FACTS AND HAD NOT TRIED TO CONCEAL THE PARTICULARS OF INCOME. THE HONBLE APEX COURT HELD, IN SUCH A CASE THE LEVY OF PENALTY CANNOT BE SUSTAINED. BUT HERE IN THE INSTANT CASE, IT WAS A CASE WHERE THE ASSESSEE D ID NOT FILE HIS RETURN OF INCOME EVEN THOUGH HE HAD TAXABLE INCOME. THIS IS A CLEAR CASE OF CONCEALMENT OF INCOME. AS OBSERVED EARLIER IN THE ORDER, THE DETECTION OF THE ASSESSEE HAVING TAXABLE INCOM E CAME TO LIGHT ONLY WHEN THE ASSESSEE WAS SEARCHED UNDER SE CTION 132. THIS CANNOT BE TAKEN INTO THE REALM OF ASSESSEE FURNISHING THE DETAILS AND DISALLOWED BY THE REVENUE AUTHORITIES. RATHER, IT WOULD FALL INTO THE CATEGORY OF CONCEALMENT, WITH AN INTENTION TO JASWINDER SINGH SACHDEV, ITA 84/M/2011 7 CONCEAL THE PARTICULARS OF INCOME AND EVADE TAX, WHICH WOU LD SQUARELY FALL WITHIN THE PRECINCT OF SECTION 271(1)(C). 18. WE, THEREFORE, SUSTAIN THE INITIATION AND LEVY OF PENALTY UNDER SECTION 271(1)(C). 19. ON THE ARGUMENTS OF THE AR BEFORE US AND BEFORE TH E CIT(A), THAT PENALTY COULD ONLY BE LEVIED ON THE DIFFERENCE OF AMOUNTS ASSESSED AND INCOME RETURNED AND ALSO THAT NO PENALTY COULD BE LEVIED ON DEPRECIATION CLAIMED ON THE USAGE OF A RESIDENTIAL PROPERTY FOR HIS CONDUCT OF BUSINESS AND GIFTS RECEIVED FROM FATHER AND MOTHER IN LAW, ALSO CANNOT BE ACCEPTED. 20. FIRST, AND THE FOREMOST, ASSESSEE FILED HIS ROI AFTER TH E SEARCH, THEREFORE, THE ENTIRE INCOME DECLARED IN THE ROI BECAME CONCEALMENT ON THE DUE DATE OF RETURN OR BEING LIBERAL ON 31 ST MARCH. 21. THIS IS SO BECAUSE THE ASSESSEE WAS LEGALLY BOUND TO FILE HIS TAXABLE RETURN ON OR BEFORE THE DUE DATE OR LATEST BY 31 ST MARCH, THE ASSESSEE BROKE BOTH THESE DEADLINES AND THE REFORE, BECAME A DEFAULTER AND THEREFORE, THE ENTIRE INCOME BECAM E CONCEALED INCOME. HENCE THE QUESTION CANNOT ARISE THAT O NLY THE DIFFERENCE NEED BE TAKEN FOR THE PURPOSE OF QUANTIFICATION O F CONCEALMENT AND LEVY OF PENALTY. 22. WE, THEREFORE, AT THE OUTSET, SUSTAIN THE PENALTY LEVIE D ON THE INCOME SO RETURNED. 23. WE CANNOT CONSIDER THE ARGUMENT OF THE AR THAT AT LEAST, PENALTY SHOULD NOT BE LEVIED ON CLAIM OF DEPRECIATION AND TH E TWO GIFTS OF RS. 3,00,000/- EACH RECEIVED FROM FATHER AND M OTHER IN LAW. OUR DECISION ON THESE, ONCE AGAIN, SHALL BE THE OBSERVATION BY US IN THE PRECEDING PARAS. JASWINDER SINGH SACHDEV, ITA 84/M/2011 8 24. IN THE LIGHT OF OUR OBSERVATIONS, AS MADE BY US TO S USTAIN THE LEVY OF PENALTY, FOLLOWING THE SAME, WE REJECT THE ARGU MENTS AND THE GOA RAISED ON THESE ISSUES. 25. WE, THEREFORE, SUSTAIN THE LEVY OF PENALTY UNDER SECT ION 271(1)(C), AS COMPUTED BY THE CIT(A), CONSEQUENTIALLY, WE REJE CT THE ARGUMENTS AND GOA RAISED BY THE ASSESSEE. 26. AS A RESULT, THE APPEAL AS FILED BY THE ASSESSEE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 26 TH DECEMBER, 2014. SD/- SD/- ( ) ( '!! '!! '!! '!! !# !# !# !# ) (RAJENDRA) ( VIVEK VARMA ) ACCOUNTANT MEMBER J UDICIAL MEMBER MUMBAI, DATE: 26 TH DECEMBER, 2014 (,/ COPY TO:- 1) %' / THE APPELLANT. 2) ()%' / THE RESPONDENT. 3) THE CIT(A) -36, MUMBAI. 4) THE CIT(CENTRAL)-I, MUMBAI/CIT(CENTRAL) -I, MUMBAI. 5) '!56 (,* I , , / THE D.R. I BENCH, MUMBAI. 6) 67# 8 COPY TO GUARD FILE. 2* / BY ORDER / / TRUE COPY / / 9 / : , DY. / ASSTT. REGISTRAR I.T.A.T., MUMBAI *<=:* !.*. *CHAVAN, SR.PS