M/S VIKAS OIL MILL, Jaipur V. INCOME TAX OFFICER, Alwar

ITA 848/JPR/2017

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 3590 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 5 month(s) 15 day(s)
• Appeal Type: Income Tax (International Taxation) Appeal
• Pronouncement Date: 29-04-2019
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: SMC
• Assessment Year: 2013-2014
• Appeal Filed On: 13-11-2017
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: POONAM ROY DCIT DHK
• Keywords: Gross profit estimation; Depreciation
• Section: 37

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR JH FOT; IKY JKO] U;KF;D LNL; ,OA JH HKKXPAN] YS[KK LNL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM & SHRI BHAGCHAND, A M VK;DJ VIHY LA-@ ITA NO. 848/JP/2017 FU/KZKJ.K O'KZ@ ASSESSMENT YEAR : 2013-14 M/S VIKAS OIL MILLS, G-26, 27, INDUSTRIAL AREA, KHAIRTHAL, ALWAR (RAJ) CUKE VS. I.T.O., WARD 1(3), ALWAR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AABFV 2322 F VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI P.C. PARWAL (CA) JKTLO DH VKSJ LS@ REVENUE BY : SMT. POONAM ROY (DCIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 30/05/2018 MN?KKS'K.KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 31/05/2018 VKNS'K@ ORDER PER: BHAGCHAND, A.M. THE APPEAL FILED BY THE ASSESSEE EMANATES FROM THE ORDER OF THE LD. CIT(A), ALWAR DATED 16/08/2017 FOR THE A.Y. 2013- 14. 2. THERE WAS A DELAY OF 4 DAYS IN FILING OF THIS APPE AL. IT WAS PLEADED BEFORE THE BENCH THE ASSESSEE HAS SENT THE APPEAL P APERS TROUGH COURIER ON 06/11/2017 BUT THE SAME WAS DELIVERED IN THE ITAT ON 13/11/2017. THE LAST DATE OF FILING THE APPEAL WAS 0 9/11/2017 I.E. THURSDAY. SINCE 11/11/2017 & 12/11/2017 WAS SATURDAY AND SUNDAY, ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 2 THUS EFFECTIVELY, THERE WAS ONLY ONE DAY DELAY IN FI LING THE APPEAL. THEREFORE, HE PRAYED TO CONDONE THE DELAY. 3. ON THE OTHER HAND, THE LD DR HAS NOT SERIOUS OBJ ECTION ON THE PRAYER OF THE LD. AR FOR CONDONATION OF DELAY. 4. AFTER HEARING BOTH THE SIDES ON THE PRAYER OF CO NDONATION OF DELAY, AFTER CONSIDERING THE EXPLANATION IN DELAY F ILING THE APPEAL, WE FIND THAT THE REASONS ARE CONVINCING AND REASONABLE , THEREFORE, WE CONDONE THE DELAY. 5. THE ASSESSEE IS A FIRM ENGAGED IN THE BUSINESS OF CRUSHING OF MUSTARD SEED AND MANUFACTURING OF MUSTARD OILS AND CAKE. THE ASSESSEE HAS FILED ITS RETURN OF INCOME ON 04/9/201 3 DECLARING TOTAL INCOME OF RS. 5,630/-. FOR THE YEAR UNDER CONSIDERA TION, THE GROSS SALES WERE OF RS. 37,05,32,135/- AND THE GROSS PROFIT DECL ARED WAS 3.04%. IN THE IMMEDIATE PRECEDING YEAR, THE GROSS SALES WERE R S. 34,39,43,064/- AND G.P. WAS 4.13%. THUS THERE WAS SHARP FALL IN G.P. IN COMPARISON TO IMMEDIATE PRECEDING YEAR. THE ASSESSING OFFICER ASKE D TO EXPLAIN THE FALL IN G.P.. THE REPLY WAS NOT FOUND SUFFICIENT TO E XPLAIN SUCH SHARP FALL. THE ASSESSING OFFICER REJECTED THE BOOKS OF ACCOUNT AND MADE TRADING ADDITION OF RS. 6,16,774/- BY ESTIMATING THE GROSS PROFIT RATE AT 3.20% AS AGAINST THE GROSS PROFIT DECLARED BY THE ASSESSE E AT 3.04% BY ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 3 OBSERVING THAT THE ASSESSEE HAS DECLARED LOWER GROSS PROFIT IN COMPARISON TO THE PRECEDING YEARS AND HAS ALSO NOT FURNISHED DAY TO DAY STOCK REGISTER FOR VERIFICATION, IN ABSENCE OF SAME, THE VALUATION OF THE CLOSING STOCK COULD NOT BE VERIFIED. THE ASSESSI NG OFFICER HAS ALSO DISALLOWED OUT OF VARIOUS OTHER EXPENSES. THE LD. CIT( A) HAS CONFIRMED THE ADDITION OF RS. 6,16,774/- ON ACCOUNT OF TRADIN G ADDITON AND PARTLY CONFIRMED THE ACTION OF THE ASSESSING OFFICER WITH R EGARD OF DISALLOWANCE OF VARIOUS EXPENSES. 6. NOW THE ASSESSEE IS IN APPEAL BEFORE THE ITAT BY T AKING FOLLOWING GROUNDS OF APPEAL: 1.0 THAT THE LEARNED ASSESSING OFFICER HAS ERRED IN LAW AS WELL AS IN THE FACTS AND CIRCUMSTANCES OF THE CASE IN REJECTING TH E BOOKS OF ACCOUNTS BY INVOKING THE PROVISIONS OF SECTION 145(3) OF THE I. TAX ACT, 1961 AND ID CIT (A) HAS ERRED IN SUSTAIN THE SAME. 2.0 THAT THE LEARNED ASSESSING OFFICER HAS ERRED IN LAW AS WELL AS ON THE FACTS AND CIRCUMSTANCES OF THE CASE IN MAKING VARIO US OBSERVATIONS ON PAGE NO. 4 OF THE ASSESSMENT ORDER IN PARA NO. 1 TO 5, WHICH ARE AGAINST THE FACTS AND MATERIAL LYING ON THE ASSESSM ENT RECORD AND ID CIT (A) HAS ERRED IN SUSTAIN THE SAME. 3.0 THAT THE LEARNED ASSESSING OFFICER HAS ERRED IN LAW AS WELL AS ON THE FACTS AND CIRCUMSTANCES OF THE CASE IN APPLYING A G ROSS PROFIT RATE OF 3.20% AS AGAINST THE GROSS PROFIT RATE OF 3.04% AND THUS MAKING A TRADING ADDITION OF RS. 616774.00 WITHOUT GIVING AN Y OPPORTUNITY TO THE ASSESSEE AND THE ADDITION SO MADE IS WITHOUT AN Y BASIS AND IS JUST ON THE PRESUMPTION AND SURMISES OF THE LEARNED ASSE SSING OFFICER AND ID CIT (A) HAS ERRED IN SUSTAIN THE SAME.. ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 4 4.0 THAT THE LEARNED ASSESSING OFFICER HAS ERRED IN LAW AS WELL AS ON THE FACTS AND CIRCUMSTANCES OF THE CASE IN MAKING THE D ISALLOWANCES AND ID CIT (A) HAS ERRED IN SUSTAIN THE FOLLOWING DISALLOW ANCES:- 4.1 OUT OF TEA EXPENSES RS. 2890.00 4.2 OUT OF TRAVELLING EXPENSES RS. 3300.00 4.3 OUT OF VEHICLE REPAIR & MAINTENANCE EXPENSES RS . 10280.00 4.4 OUT OF DEPRECIATION ON VEHICLE RS. 6030.00 4.5 OUT OF TELEPHONE EXPENSES RS. 5280.00 4.6 OUT OF MISC. EXPENSES RS. 5794.00 4.7 OUT OF LABOUR CHARGES EXPENSES RS. 59960.00 7. GROUNDS NO. 1, 2 AND 3 OF THE APPEAL ARE RELATED TO REJECTION OF BOOKS OF ACCOUNT AND ESTIMATING THE GROSS PROFIT RA TE @ 3.20% AS AGAINST THE DECLARED GROSS PROFIT AT 3.04% BY THE A SSESSEE. AT THE OUTSET OF HEARING, THE LD AR OF THE ASSESSEE HAS SU BMITTED THAT THE ASSESSEE HAS SUBMITTED STOCK REGISTER ALONGWITH OTHE R DETAILS BEFORE THE ASSESSING OFFICER WHILE THE ASSESSING OFFICER HAS OB SERVED THAT THE ASSESSEE HAS FAILED TO PRODUCE THE SAME. HONBLE RA JASTHAN HIGH COURT IN VARIOUS CASES HAVE HELD THAT PAST HISTORY OF THE ASSESSEE IS THE BEST GUIDE TO ESTIMATE THE G.P.. IN ASSESSEES CASE, THE ASSESSING OFFICER HAS GIVEN SUFFICIENT WEIGHTAGE AND CONSIDERATION TO EXPL ANATION OF ASSESSEE AND APPLIED ONLY 3.20% WHILE PAST HISTORY GIVES AVER AGE G.P. MORE THAN THAT. THE FACTS ON RECORD SHOWS THAT THE G.P. IN IMME DIATE PRECEDING YEAR WAS 4.13% AND THE AVERAGE GROSS PROFIT OF IMMED IATE TWO PRECEDING YEARS COME TO 3.64%. THE ASSESSING OFFICE R HAS ESTIMATED THE G.P. ONLY AT 3.20%. THE ASSESSING OFFICER HAS G IVEN SUFFICIENT ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 5 WEIGHTAGE TO THE VARIOUS FACTORS FOR FALL IN G.P. NA RRATED BY THE ASSESSEE. HOWEVER, THE LD A.RS CONTENTION THAT THE ASSESSEE HAVE PRODUCED STOCK REGISTER FOR VERIFICATION WHILE THE ASSESSING OFFICER STATED THAT IT WAS NOT PRODUCED IS A FACT TO BE ASCERTAINED . THEREFORE WE RESTORE THE ISSUE BACK TO THE FILE OF THE LD. CIT(A) FOR DECIDING DE NOVO. HENCE, THESE GROUNDS OF APPEAL ARE ALLOWED FOR STAT ISTICAL PURPOSES ONLY. 8. IN THE GROUND NO. 4 OF THE ASSESSEE, THE ISSUE I S WITH REGARD TO DISALLOWANCE OF VARIOUS EXPENSES. ONE OF THE EXPENSE S OUT OF WHICH THE ASSESSING OFFICER HAS DISALLOWED AND THE LD. CIT(A) H AS PARTLY SUSTAINED THE ADDITION IS OUT OF LABOUR CHARGES EXPENSES. F ROM THE RECORDS, IT IS NOT CLEAR WHETHER THESE LABOUR CHARGES EXPENSES WERE INCURRED IN RESPECT OF THE PURCHASES OR IN RESPECT OF SALES. TH US, IT IS NOT CLEAR WHETHER THESE EXPENSES HAVE TO BE CONSIDERED TO ARRI VE AT G.P. OR N.P. HENCE, TO DETERMINE WHETHER THIS ISSUE HAS BEEN TAKE N CARE OF WHILE ESTIMATING THE GROSS PROFIT OR NOT, THE ISSUE NEED A RELOOK AT THE LEVEL OF LD. CIT(A). WE RESTORE THE ISSUE RELATING TO THIS EX PENSE TO THE FILE OF THE LD. CIT(A) TO BE DECIDED AFRESH. FURTHER WITH REGARD TO OTHER EXPENSES, THE LD. CIT(A) HAS SUSTAINED PART ADDITION BY HOLDIN G AS UNDER: TEA EXPENSES 6.3 I HAVE GONE THROUGH THE ASSESSMENT ORDER AS WE LL AS SUBMISSIONS MADE BY THE APPELLANT AND FIND THAT THE DISALLOWANCES HA VE BEEN MADE ON TEA REFRESHMENT EXPENSES. ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 6 6.4 ANY EXPENDITURE OF THE NATURE MENTIONED ABOVE I S CLAIMED UNDER SECTION 37 OF THE ACT. IN ORDER TO GET THE DEDUCTIO N UNDER SECTION 37 OF THE ACT, PRIMARY ONUS LIES ON THE ASSESSEE TO PROVE THAT SUCH EXPENDITURES ARE INCURRED WHOLLY AND EXCLUSIVELY FO R THE PURPOSE OF BUSINESS OR PROFESSION. 6.5 IN THE INSTANT CASE, THE ASSESSEE HAS FAILED TO PROVIDE SUPPORTING DOCUMENTS TO PROVE THAT SUCH EXPENDITURES ARE INCUR RED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS OR PROFESSI ON. HOWEVER, IN MY CONSIDERED VIEW A DISALLOWANCE OF 10% OF THE EXPENS ES CLAIMED ON THE ABOVE MENTIONED EXPENDITURES IS REASONABLE TO COVER THE DISCREPANCIES MENTIONED BY THE A.O IN THE ASSESSMENT ORDER. ACCOR DINGLY, THE ADDITION IS REDUCED TO RS. 2,890/- AND THE GROUND O F APPEAL ON THIS ISSUE IS PARTLY ALLOWED. TRAVELLING EXPENSES 7.3 I HAVE GONE THROUGH THE ASSESSMENT ORDER AS WEL L AS SUBMISSIONS MADE BY THE APPELLANT AND FIND THAT THE DISALLOWANCES HA VE BEEN MADE ON TRAVELLING EXPENSES. 7.4 ANY EXPENDITURE OF THE NATURE MENTIONED ABOVE I S CLAIMED UNDER SECTION 37 OF THE ACT. IN ORDER TO GET THE DEDUCTIO N UNDER SECTION 37 OF THE ACT, PRIMARY ONUS LIES ON THE ASSESSEE TO PROVE THAT SUCH EXPENDITURES ARE INCURRED WHOLLY AND EXCLUSIVELY FO R THE PURPOSE OF BUSINESS OR PROFESSION. 7.5 IN THE INSTANT CASE, THE ASSESSEE HAS FAILED TO PROVIDE SUPPORTING DOCUMENTS TO PROVE THAT SUCH EXPENDITURES ARE INCUR RED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS OR PROFESSI ON. HOWEVER, IN MY CONSIDERED VIEW A DISALLOWANCE OF 10% OF THE EXPENS ES CLAIMED ON THE ABOVE MENTIONED EXPENDITURES IS REASONABLE TO COVER THE DISCREPANCIES ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 7 MENTIONED BY THE A.O IN THE ASSESSMENT ORDER. ACCOR DINGLY, THE ADDITION IS REDUCED TO RS. 3,300/- AND THE GROUND O F APPEAL ON THIS ISSUE IS PARTLY ALLOWED. VEHICLE REPAIR & MAINTENANCE EXPENSES 8.3 I HAVE GONE THROUGH THE ASSESSMENT ORDER AS WEL L AS SUBMISSIONS MADE BY THE APPELLANT AND FIND THAT THE DISALLOWANCES HA VE BEEN MADE ON VEHICLE REPAIR AND MAINTENANCE EXPENSES. 8.4 ANY EXPENDITURE OF THE NATURE MENTIONED ABOVE I S CLAIMED UNDER SECTION 37 OF THE ACT. IN ORDER TO GET THE DEDUCTIO N UNDER SECTION 37 OF THE ACT, PRIMARY ONUS LIES ON THE ASSESSEE TO PROVE THAT SUCH EXPENDITURES ARE INCURRED WHOLLY AND EXCLUSIVELY FO R THE PURPOSE OF BUSINESS OR PROFESSION. 8.5 IN THE INSTANT CASE, THE ASSESSEE HAS FAILED TO PROVIDE SUPPORTING DOCUMENTS TO PROVE THAT SUCH EXPENDITURES ARE INCUR RED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS OR PROFESSI ON. HOWEVER, IN MY CONSIDERED VIEW A DISALLOWANCE OF 10% OF THE EXPENS ES CLAIMED ON THE ABOVE MENTIONED EXPENDITURES IS REASONABLE TO COVER THE DISCREPANCIES MENTIONED BY THE A.O IN THE ASSESSMENT ORDER. ACCOR DINGLY, THE ADDITION IS REDUCED TO RS. 10,280/- AND THE GROUND OF APPEAL ON THIS ISSUE IS PARTLY ALLOWED. DEPRECIATION ON VEHICLE 9.3 I HAVE CONSIDERED THE ORDER PASSED BY THE AO AN D SUBMISSIONS FILED BY THE APPELLANT. AS SECTION 38(2) OF THE ACT, PROPORT IONATE DISALLOWANCE OF DEPRECIATION IS REQUIRED TO BE MADE ON ACCOUNT O F USAGE OF THE ASSETS FOR PURPOSES OTHER THAN BUSINESS. I HAVE ALS O RELIED UPON THE HONBLE PATNA HIGH COURT JUDGMENT ON THE ISSUE IN T HE CASE OF COMMISSIONER OF INCOME TAX VS K. L. BHASIN & CO. ON 18 OCTOBER, 1984 ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 8 EQUIVALENT CITATIONS: (1987) 59 CTR PAT 112. ACCORD INGLY, THE DISALLOWANCE OF DEPRECIATION ON VEHICLES IS REDUCED TO RS. 6,030/- AND THE APPELLANTS GROUND OF APPEAL ON THE ISSUE IS PA RTLY ALLOWED. TELEPHONE EXPENSES 10.3 I HAVE GONE THROUGH THE ASSESSMENT ORDER AS WE LL AS SUBMISSIONS MADE BY THE APPELLANT AND FIND THAT THE DISALLOWANCES HA VE BEEN MADE BASICALLY ON THE ISSUE OF PERSONAL ELEMENT OF USAGE S OF TELEPHONES. 10.4 ANY EXPENDITURE OF THE NATURE MENTIONED ABOVE IS CLAIMED UNDER SECTION 37 OF THE ACT. IN ORDER TO GET THE DEDUCTIO N UNDER SECTION 37 OF THE ACT, PRIMARY ONUS LIES ON THE ASSESSEE TO PROVE THAT SUCH EXPENDITURES ARE INCURRED WHOLLY AND EXCLUSIVELY FO R THE PURPOSE OF BUSINESS OR PROFESSION. 10.5 IN THE INSTANT CASE, THE ASSESSEE HAS FAILED TO PROVIDE SUPPORTING DOCUMENTS TO PROVE THAT SUCH EXPENDITURES ARE INCUR RED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS OR PROFESSI ON. BESIDES, ELEMENTS OF PERSONAL NATURE CANNOT BE RULED OUT IN THE USAGE TELEPHONE IN ABSENCE OF MAINTENANCE OF SEPARATE CALL REGISTER. T HEREFORE, IN MY CONSIDERED VIEW A DISALLOWANCE OF 10% OF THE EXPENS ES CLAIMED ON THE ABOVE MENTIONED EXPENDITURES IS REASONABLE TO COVER THE DISCREPANCIES MENTIONED BY THE A.O IN THE ASSESSMENT ORDER. ACCOR DINGLY, THE ADDITION ON THIS ISSUE IS REDUCED TO RS. 5,280/- AN D THE GROUND OF APPEAL ON THIS ISSUE IS PARTLY ALLOWED. MISC. EXPENSES 11.3 I HAVE GONE THROUGH THE ASSESSMENT ORDER AS WE LL AS SUBMISSIONS MADE BY THE APPELLANT AND FIND THAT THE DISALLOWANCES HA VE BEEN MADE BASICALLY ON THE ISSUE OF MISC EXP. ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 9 11.4 ANY EXPENDITURE OF THE NATURE MENTIONED ABOVE IS CLAIMED UNDER SECTION 37 OF THE ACT. IN ORDER TO GET THE DEDUCTIO N UNDER SECTION 37 OF THE ACT, PRIMARY ONUS LIES ON THE ASSESSEE TO PROVE THAT SUCH EXPENDITURES ARE INCURRED WHOLLY AND EXCLUSIVELY FO R THE PURPOSE OF BUSINESS OR PROFESSION. 11.5 IN THE INSTANT CASE, THE ASSESSEE HAS FAILED T O PROVIDE SUPPORTING DOCUMENTS TO PROVE THAT SUCH EXPENDITURES ARE INCUR RED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS OR PROFESSI ON THEREFORE, IN MY CONSIDERED VIEW A DISALLOWANCE OF 10% OF THE EXPENS ES CLAIMED ON THE ABOVE MENTIONED EXPENDITURES IS REASONABLE TO C OVER THE DISCREPANCIES MENTIONED BY THE A.O IN THE ASSESSMEN T ORDER. ACCORDINGLY, THE ADDITION IS REDUCED TO RS. 5,794/- AND THE GROUND OF APPEAL ON THIS ISSUE IS PARTLY ALLOWED. 9. WE HAVE HEARD THE LD AR WITH REGARD TO VARIOUS EX PENSES DISALLOWED BY THE ASSESSING OFFICER AND PARTLY SUSTA INED BY THE LD. CIT(A). AFTER HEARING BOTH THE SIDES, WE ARE OF THE V IEWS THAT THE LD. CIT(A) HAS GIVEN SUFFICIENT CONSIDERATION TO THE PLE ADINGS OF THE ASSESSEE AND SUSTAINED ONLY PART ADDITION. THERE IS NO FURTHER SCOPE FOR REDUCTION IN THE ADDITION, THEREFORE, WE SUSTAIN TH E DISALLOWANCE FOR THE REASON THAT THE ASSESSEE HAS FAILED TO FULLY ESTABL ISH THAT ALL THESE EXPENSES WERE INCURRED WHOLLY AND EXCLUSIVE FOR THE B USINESS AND PROFESSION OF THE ASSESSEE. ACCORDINGLY, THIS GROUN D OF ASSESSEES APPEAL IS DISMISSED. ITA 848/JP/2017_ VIKAS OIL MILLS VS ITO 10 10. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PA RTLY ALLOWED FOR STATISTICAL PURPOSES ONLY. ORDER PRONOUNCED IN THE OPEN COURT ON 31/05/2018. SD/- SD/- FOT; IKY JKO HKKXPAN (VIJAY PAL RAO) (BHAGCHAND) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 31 ST MAY, 2018 *RANJAN VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- M/S VIKAS OIL MILLS, ALWAR. 2. IZR;FKHZ @ THE RESPONDENT- THE ITO, WARD 1(3), ALWAR. 3. VK;DJ VK;QDR @ THE CIT 4. VK;DJ VK;QDRVIHY @ THE CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ @ DR, ITAT, JAIPUR 6. XKMZ QKBZY @ GUARD FILE (ITA NO. 848/JP/2017) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR