HAJI DAUD KHAN, Jaipur V. ITO, Jaipur

ITA 840/JPR/2015

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 4855 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 6 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-12-2016
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: SMC
• Assessment Year: 2010-2011
• Appeal Filed On: 03-12-2015
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: POONAM RAI D DHK
• Keywords: Sale consideration of property below Jantri Value; Capital asset; Additional evidence; Question of law; Fair market value; Valuation report
• Section: 50C; 37

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES (SMC), JAIPUR JH HKKXPUN] YS[KK LNL; DS LE{K BEFORE: SHRI BHAGCHAND, ACCOUNTANT MEMBER VK;DJ VIHY LA-@ ITA NO. 840/JP/2015 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2010-11 SHRI HAJI DAUD KHAN FLAT NO.101, BLOCK-A DIAMOND RESIDENCY, JHOTWARA, JAIPUR CUKE VS. THE ITO WARD- 3 (1) JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO .: BHMPD 9351 D VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY: SHRI VIJAY GOYAL, CA JKTLO DH VKSJ LS@ REVENUE BY :SMT. POONAM RAI, DCIT-DR LQUOKBZ DH RKJH[K@ DATE OF HEARING : 07/12/2016 ?KKS'K .KK DH RKJH[K@ DATE OF PRONOUNCEMENT : 9 /12/2016 VKNS'K@ ORDER PER BHAGCHAND, AM THE ASSESSEE HAS FILED AN APPEAL AGAINST THE ORDE R OF THE LD. CIT(A)-1, JAIPUR DATED 23-09-2015 FOR THE ASSESSME NT YEAR 2010-11 RAISING THEREIN FOLLOWING GROUNDS OF APPEAL:- 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. CIT(A) ERRED IN CONFIRMING THE ADDITION OF RS. 43,98,575/- ON ACCOUNT OF LONG TER M CAPITAL GAIN ON SALE OF PLOT BY TAKING THE SALE CONSIDERATI ON OF RS. 84,75,000/- ON THE BASIS OF VALUE ADOPTED BY THE RE GISTRATION ITA NO. 840/JP/2015 SHRI HAJI DAUD KHAN VS. ITO WARD- 3(1), JAIPUR . 2 AUTHORITY AS AGAINST SALE CONSIDERATION OF RS. 35,0 0,000/- DECLARED IN THE SALE DEED. 2. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW THE LD. CIT(A) ERRED IN CONFIRMING THE ACTION OF THE AO AS WELL AS VALUATION OFFICER IN DETERMINI NG THE FAIR MARKET VALUE OF THE PROPERTY SOLD BY THE ASSES SEE AT RS. 84,75,000/- AGAINST ACTUAL SALE CONSIDERATION RECEI VED, ACCEPTED BY THE SUB-REGISTRAR AT THE TIME OF REGIST RATION OF SALE DEED AT RS. 35,00,000/- FOR STAMP DUTY PURPOSE . IT IS CONTENDED THAT THE FAIR MARKET VALUE OF THE PROPERT Y DETERMINED BY THE VALUATION OFFICER / AO IS SOLELY BASED ON THE DECISION OF STAMP DUTY AUTHORITIES WHO HAD MADE THE UPWARD REVISION OF THE STAMP DUTY VALUATION OF THE PROPERTY TREATING THE SAME AS COMMERCIAL PROPERTY AGAINST RE SIDENTIAL PROPERTY DECLARED BY THE ASSESSEE AND ACCEPTED BY T HE SUB- REGISTRAR WHILE REGISTERING THE SALE DEED. NO ANY O THER MATERIAL WAS BROUGHT ON RECORD TO JUSTIFY THE MARKE T VALUE OR NO INDEPENDENT ENQUIRIES WERE CONDUCTED. 2.1 THE FACTS ON THE ISSUE IN QUESTION AS EMERGES F ROM THE ORDER OF THE LD. CIT(A) IS REPRODUCED AS UNDER:- 3.1.2 DETERMINATION (I) I HAVE CAREFULLY PERUSED THE SUBMISSIONS OF TH E ASSESSEE, THE REMAND REPORT SUBMITTED BY THE AO AND THE REJOINDER TO THE REMAND REPORT. THE ONLY DISPUTE IN THIS CASE IS REGARDING THE VALUATION OF THE PROPERTY SOLD BY THE ASSESSEE DURI NG THE YEAR UNDER CONSIDERATION. THE ASSESSEE HAS SHOWN THE SALE CONS IDERATION AT RS. 35,00,000/- AND FOR THE PURPOSES OF THE STAMP DUTY, THE PROPERTY WAS VALUED AT RS. 22,29,050/- AND SUBSEQUENTLY, THE SUB -REGISTRAR REVALUED THE PROPERTY AT RS. 84,89,500/- AND CHARGED STAMP D UTY THEREON. FURTHER, THE VALUATION ADOPTED BY THE SUB REGISTRAR WAS ALSO CONFIRMED BY THE COLLECTOR (STAMPS). (II) DURING ASSESSMENT PROCEEDINGS, THE ASSESSEE CO NTESTED THE REVALUATION OF THE PROPERTY AT RS. 84,89,500/- AND SUBMITTED THAT THE SAME SHOULD NOT BE TAKEN INTO ACCOUNT FOR COMPU TING CAPITAL GAINS ITA NO. 840/JP/2015 SHRI HAJI DAUD KHAN VS. ITO WARD- 3(1), JAIPUR . 3 THEREOF AND REQUESTED THAT THE MATTER MAY BE REFERR ED TO THE VALUATION CELL FOR DETERMINING THE FAIR MARKET VALUE OF THE P ROPERTY. ON A REFERENCE FROM AO, THE ASSISTANT VALUATION OFFICER DETERMINED THE FAIR MARKET VALUE OF THE PROPERTY ON THE DATE OF SA LE OF THE PROPERTY AT RS. 84,75,000/-. THE AO INVOKED THE PROVISIONS OF S ECTION 50C OF THE ACT AND DETERMINED THE LONG TERM CAPITAL GAINS BY T AKING THE SALE CONSIDERATION AT RS. 84,75,000/-. (III) DURING APPELLATE PROCEEDINGS, THE ASSESSEE FILED A COPY OF THE LETTER ISSUED BY JAIPUR DEVELOPMENT AUTHORIT Y (JDA) ON 29.03.2014 I.E. AFTER PASSING OF THE ASSESSMENT ORD ER BY THE AO ON 18.03.2014. AS PER THE SAID LETTER OF JDA, THE MAST ER DEVELOPMENT PLAN, 2011 WAS APPLICABLE IN 2009 TO THE PROPERTY U NDER CONSIDERATION I.E. 1, OFFICERS CAMPUS EXTENSION AND AS ON 15.10.2 009 I.E. THE DATE OF SALE OF THE PROPERTY BY THE ASSESSEE, THE SAID PROP ERTY WAS SHOWN AS RESIDENTIAL IN MASTER DEVELOPMENT PLAN, 2011. THE A SSESSEE PRAYED FOR THE ADMISSION OF THE ABOVE LETTER AS ADDITIONAL EVI DENCE. THE AO IN HIS REMAND REPORT OBJECTED TO THE ADMISSION OF THE ABOV E ADDITIONAL EVIDENCE AS THE SAME WAS NOT PRODUCED BEFORE HIM. I T WOULD BE RELEVANT TO MENTION HERE IN BRIEF SOME OF THE JUDIC IAL PRONOUNCEMENTS FOR ADMISSION OF ADDITIONAL EVIDENCE AS UNDER: M/S NISRAJ REAL ESTATE & EXPORT PVT. LTD., SIKAR VS . ACIT 42 TAX WORLD 121 ITAT (JAIPUR) WHETHER CIT(A) CAN ADMIT ADDITIONAL EVIDENCE FOR DISPOSAL OF APPEAL ON MERITS?- HELD YES, SINCE POWE RS OF FIRST APPELLATE AUTHORITY ARE VERY WIDE AND CO-TERMINUS W ITH THOSE OF THE AO IN AS MUCH AS SUB-RULE(4) OF RULE 46A(1) AND (2) EMPOWER THE CIT(A) TO DIRECT THE PRODUCTION OF ANY DOCUMENT OR EXAMINATION OF WITNESS TO ENABLE HIM TO DISPOSE OF THE APPEAL ON MERIT. FURTHER, HELD THAT SINCE CIT(A) IS NO MORE EMPOWERED TO RESTORE BACK ANY MATTER TO AO, IT NECE SSITATED COMPULSORY ADMISSION OF THE EVIDENCE PRODUCED BEFOR E HIM IN THE INTEREST OF JUSTICE. ANMOL COLOURING INDIA PVT LTD. VS ITO 121 TTJ 269 ITAT (JAIPUR) IN THIS CASE THE ASSESSEE HAD GIVEN ALL THE EVIDENC ES TO HIS COUNSEL FOR FILING WITH THE AO. BUT HE DID NOT FILE THE SAME. THEREAFTER THERE WAS CHANGE IN THE COUNSEL WHO FILE D ALL THE EVIDENCES BEFORE CIT(A) AS ADDITIONAL EVIDENCE. IT WAS HELD THAT IN THESE CIRCUMSTANCES ADDITIONAL EVIDENCE SHO ULD BE ITA NO. 840/JP/2015 SHRI HAJI DAUD KHAN VS. ITO WARD- 3(1), JAIPUR . 4 ACCEPTED BY THE CIT(A). CIT VS SURETECH HOSPITAL & RESEARCH CENTRE LTD. 211 CTR 360 (BOMBAY ) APPEAL [CIT(A)] ADDITIONAL EVIDENCE - ADMISSIBILITY - RULE 46A PROVIDES THAT NOTWITHSTANDING R. 46A(1) TH E APPELLATE AUTHORITY CAN PERMIT PRODUCTION OF DOCUMENTS TO ENA BLE HIM TO DISPOSE OF THE APPEAL - FINDING RECORDED BY THE TRI BUNAL THAT THE DOCUMENTS PRODUCED BY THE ASSESSEE BEFORE THE L D. CIT (A) WERE NECESSARY FOR DISPOSAL OF THE APPEAL ON MERITS - IT WAS JUSTIFIED IN HOLDING THAT THE CIT(A) OUGHT TO HAVE EXERCISED ITS POWER TO ADMIT ADDITIONAL EVIDENCE- NO QUESTION OF LAW ARISES. ITO VS. BAJOURIA FOUNDATION 71 TTJ (CAL) 343 FILING OF ADDITIONAL EVIDENCE BEFORE CIT (A) WAS COVERED BY RULE 46A( 1) (C) AS WELL AS THE SCHEME O F POWERS VESTED IN HIM UNDER SEC. 250(4)- THERE WAS NO INFIR MITY IN ADMITTING THE ADDITIONAL EVIDENCE. IT IS SETTLED IN LAW THAT WHEN A STATUTORY AUTHORITY HAS THE POWERS TO DO SOM ETHING, THEN IT HAS A CORRESPONDING DUTY TO EXERCISE SUCH P OWERS WHENEVER CIRCUMSTANCES WARRANTING EXERCISE OF SUCH POWERS EXIT. THE CASE BEFORE US, IN OUR CONSIDERED VIEW, W AS A FIT CASE WHERE THE CIT(A) SHOULD HAVE EXERCISED HIS POW ERS TO MAKE FURTHER INQUIRIES. WE, THEREFORE, SEE NO LEGAL INFIRMITY IN CIT(A) S PROCESSING ON MERITS OF THE CLAIM AND ADMITTING NECESSARY ADDITIONAL EVIDENCE FOR THAT PURPOSE. WE ALSO FIND SUPPORT FROM THE VIEW TAKEN BY A CO-ORDINATE BENCH OF THIS TRIBUNAL IN THE CASE OF ELECTRA (JAIPUR) (P) LTD., (SUPRA) IN VIEW OF THE ABOVE JUDICIAL PRONOUNCEMENTS, THE LETTER DATED 29.03.2014 OF JDA IS ADMITTED AS ADDIT IONAL EVIDENCE UNDER RULE 46A OF THE IT RULES. IN HIS REMAND REPORT, IT WAS SUBMITTED BY THE AO THAT:- THE SUBMISSION OF THE AO IS IN HINDI AT PA GE 10 & 11 OF LD. CIT(A)S ORDER. (IV) I HAVE GONE THROUGH THE ABOVE POINTS RAISED BY THE AO IN HIS REMAND REPORT AND THE LETTER DATED 29.03.201 4 ISSUED BY THE JDA. IT IS PERTINENT TO MENTION HERE THAT THE JDA H AS ISSUED THAT LETTER ON THE BASIS OF THE MASTER DEVELOPMENT PLAN, 2011 A ND NO SPOT VERIFICATION WAS DONE THEREOF WHEREAS THE ASSISTANT VALUATION OFFICER, ITA NO. 840/JP/2015 SHRI HAJI DAUD KHAN VS. ITO WARD- 3(1), JAIPUR . 5 MADE THE VALUATION OF THE PROPERTY AT RS. 84,75,000 /- AFTER MAKING THE SPOT VERIFICATION AND TAKING INTO CONSIDERATION ALL THE RELEVANT FACTS THEREOF. FURTHER, THE SUB REGISTRAR AS WELL AS THE COLLECTOR (STAMPS) DETERMINED THE VALUATION OF THE PROPERTY AT RS. 84, 89,500/- AND ASSESSEE HAS NOT FILED ANY APPEAL TO THE RAJASTHAN TAX BOARD AGAINST THE DECISION OF SUB REGISTRAR / COLLECTOR (STAMPS). HENCE THE LETTER DATED 29.03.2014 ISSUED BY THE JDA IS OF NO HELP TO THE ASSESSEE AS THE AO HAS ADOPTED THE SALE CONSIDERATION ON THE BASIS OF THE VALUATION REPORT OF THE VALUATION OFFICER (RS. 84,75,000) AS IF IS LOWER THAN THE VALUATION TAKEN BY THE SUB REGISTRAR I.E. THE REGIS TERING AUTHORITY. IT WOULD BE RELEVANT TO REPRODUCE HERE THE PROVISIONS OF SECTION 50C OF THE ACT AS UNDER:- [SPECIAL PROVISION FOR FULL VALUE OF CONSIDERATION IN CERTAIN CASES. 50C. [1 ] WHERE THE CONSIDERATION RECEIVED OR ACCRUING AS A RESULT OF THE TRANSFER BY AN ASSESSEE OF A CAP ITAL ASSET, BEING LAND OR BUILDING OR BOTH, IS LESS THAN THE VA LUE ADOPTED OR ASSESSED[OR ASSESSABLE] BY ANY AUTHORITY OF A STATE GOVERNMENT [HEREAFTER IN THIS SECTION REFERRED TO AS THE 'STAM P VALUATION AUTHORITY' ] FOR THE PURPOSE OF PAYMENT OF STAMP DU TY IN RESPECT OF SUCH TRANSFER, THE VALUE SO ADOPTED OR A SSESSED [OR ASSESSABLE] SHALL, FOR THE PURPOSES OF SECTION 48. BE DEEMED TO BE THE FULL VALUE OF THE CONSIDERATION RECEIVED OR ACCRUING AS A RESULT OF SUCH TRANSFER. [2] WITHOUT PREJUDICE TO THE PROVISIONS OF SUB-SECT ION [1 ], WHERE (A) THE ASSESSEE CLAIMS BEFORE ANY ASSESSING OFFICER THAT THE VALUE ADOPTED OR ASSESSED [OR ASSE SSABLE] BY THE STAMP VALUATION AUTHORITY UNDER SUB-SECTION [1] EXC EEDS THE FAIR MARKET VALUE OF THE PROPERTY AS ON THE DATE OF TRAN SFER; (B) THE VALUE SO ADOPTED OR ASSESSED [OR ASSESSABL E] BY THE STAMP VALUATION AUTHORITY UNDER SUB-SECTION [1] HAS NOT BEEN DISPUTED IN ANY APPEAL OR REVISION OR NO REFER ENCE HAS BEEN MADE BEFORE ANY OTHER AUTHORITY, COURT OR THE HIGH COURT, THE ASSESSING OFFICER MAY REFER THE VALUATION OF TH E CAPITAL ASSET TO A VALUATION OFFICER AND WHERE ANY SUCH REFERENCE IS M ADE, THE PROVISIONS OF SUB-SECTIONS (2), (3), [4], (5) AND ( 6) OF SECTION 16A, CLAUSE (I) OF SUB-SECTION (1 ] AND SUB-SECTIONS (6) AND (7) OF SECTION 23A, SUB-SECTION [5) OF SECTION 24, SECTION 34AA, S ECTION 35 AND SECTION 37 OF THE WEALTH-TAX ACT, 1957 (27 OF 1957) , SHALL, WITH NECESSARY MODIFICATIONS, APPLY IN RELATION TO SUCH REFERENCE AS THEY ITA NO. 840/JP/2015 SHRI HAJI DAUD KHAN VS. ITO WARD- 3(1), JAIPUR . 6 APPLY IN RELATION TO A REFERENCE MADE BY THE ASSESS ING OFFICER UNDER SUB-SECTION (1) OF SECTION 16A OF THAT ACT. [ EXPLANATION L].FOR THE PURPOSES OF THIS SECTION, ' VALUATION OFFICER' SHALL HAVE THE SAME MEANING AS IN CLAUSE (R) OF SEC TION 2 OF THE WEALTH-TAX ACT, 1957 (27OF1957). [EXPLANATION 2FOR THE PURPOSES OF THIS SECTION, TH E EXPRESSION 'ASSESSABLE' MEANS THE PRICE WHICH THE STAMP VALUAT ION AUTHORITY WOULD HAVE, NOTWITHSTANDING ANYTHING TO THE CONTRAR Y CONTAINED IN ANY OTHER LAW FOR THE TIME BEING IN FORCE, ADOPTED OR A SSESSED, IF IT WERE REFERRED TO SUCH AUTHORITY FOR THE PURPOSES OF THE PAYMENT OF STAMP DUTY. ] (3) SUBJECT TO THE PROVISIONS CONTAINED IN SUB-SECT ION (2), WHERE THE VALUE ASCERTAINED UNDER SUB-SECTION (2) EXCEEDS THE VALUE ADOPTED OR ASSESSED [OR ASSESSABLE] BY THE STAMP VALUATION AUT HORITY REFERRED TO IN SUB-SECTION (1), THE VALUE SO ADOPTED OR ASSESSED [OR ASSESSABLE] B Y SUCH AUTHORITY SHALL BE TAKEN AS THE FULL VALUE OF THE CONSIDERATION RECEIVED OR ACCRUING AS A RESULT OF TRANSFER]. (V) IN VIEW OF THE ABOVE DISCUSSION AND PROVISION S OF SECTION 50C OF THE ACT, IT IS HELD THAT THE AO HAS RIGHTLY TAKE N THE SALE CONSIDERATION AT RS. 84,75,000/- U/S 50C OF THE IT ACT AND THUS HE HAS RIGHTLY MADE ADDITION OF RS. 49,75,000/- ON ACCOUNT OF LONG TERM CAPITAL GAINS TO THE INCOME OF THE ASSESSEE. THUS, THIS GROUND OF APPEAL IS HEREBY REJECTED. 4. IN THE RESULT, THE APPEAL IS DISMISSED. 2.2 DURING THE COURSE OF HEARING, THE LD. AR OF THE PRAYED THAT THE LD. CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS. 35.00 LACS. THE LD. AR OF THE ASSESSEE RELIED ON THE ORDER ITAT JAIPUR BEN CH IN THE CASE OF ANITA SODHI VS. ITO (ITA NO. 169/JP/2014 DATED 13-05-2016 ) PRAYING THAT THE ISSUE IN QUESTION IS COVERED BY THE DECISION OF ITA T JAIPUR BENCH (SUPRA). 2.3 THE LD. DR RELIED ON THE ORDERS OF THE AUTHORIT IES BELOW. ITA NO. 840/JP/2015 SHRI HAJI DAUD KHAN VS. ITO WARD- 3(1), JAIPUR . 7 2.4 I HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. IT IS OBSERVED THAT IN THE MAS TER DEVELOPMENT PLAN - 2011 OF THE JDA, THIS PLOT WAS SHOWN FOR RESIDENTIA L PURPOSES. THE REGISTERED DOCUMENT ALSO MENTIONS THAT THE PLOT WAS ONLY FOR RESIDENTIAL PURPOSE. JDA PATTA AND SITE PLAN ALSO SHOW THAT PLO T WAS FOR RESIDENTIAL PURPOSE. HOWEVER, SPOT INSPECTION REPORT SHOWS THAT THIS PLOT WAS OF CAPABLE OF BEING EXPLOITED FOR COMMERCIAL PURPOSES AS SURROUNDING PROPERTIES WERE BEING USED FOR COMMERCIAL PURPOSES. THE STAMP VALUATION AUTHORITY HAS ADOPTED THE COMMERCIAL RATE FOR VALUATION OF THE PLOT. THE ASSESSEE'S REQUEST TO CONVERT THE LAND TO COMMERCIAL WAS DECLINED BY JDA. THUS THE LOCATION OF THE PLOT WAS CAPABLE TO BE UTILIZED FOR COMMERCIAL PURPOSES BUT LEGALLY THE PLOT WAS NO T COMMERCIAL. THIS IS ALSO A FACT THAT THERE IS A DIFFERENCE IN MARKET VA LUE OF THE AUTHORIZED COMMERCIAL PROPERTY AND ILLEGALLY USED FOR COMMERCI AL PURPOSES. THIS FACT HAS NOT BEEN TAKEN INTO CONSIDERATION WHILE AR RIVING AT THE FAIR MARKET VALUE OF THE PLOT ON THE DATE OF TRANSFER FOR THE P URPOSE OF PROVISIONS OF SECTION 50C OF THE ACT. THEREFORE, IN THE INTEREST OF JUSTICE AND EQUITY, THE ISSUE IS RESTORED TO THE FILE OF THE AO TO DECIDE I T AFRESH AFTER ASCERTAINING THE FAIR MARKET VALUE OF THE PROPERTY WITH DUE WEIG HTAGE GIVEN TO THE FACT ITA NO. 840/JP/2015 SHRI HAJI DAUD KHAN VS. ITO WARD- 3(1), JAIPUR . 8 THAT PLOT WAS NOT A COMMERCIAL PLOT BUT CAPABLE TO BE ILLEGALLY EXPLOITED FOR COMMERCIAL PURPOSES. THUS THE APPEAL OF THE ASS ESSEE IS ALLOWED FOR STATISTICAL PURPOSES. 3.0 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOWE D FOR STATISTICAL PURPOSES . ORDER PRONOUNCED IN THE OPEN COURT ON 09 /12/2 016. SD/- HKKXPUN ( BHAGCHAND) YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 09 /12/ 2016 *MISHRA VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SHRI HAJI DAUD KHAN , JAIPUR 2. IZR;FKHZ@ THE RESPONDENT- THE ITO, WARD- 3(1), JAIPUR 3. VK;DJ VK;QDRVIHY@ CIT(A). 4. VK;DJ VK;QDR@ CIT, 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO. 840/JP/201) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ @ ASSISTANT. REGISTRAR