Smt. Meena Baldua, Jaipur V. Income Tax Officer, Ward-5(5), Jaipur

ITA 872/JPR/2018

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 2344 (ITAT-JAIPUR)
• Duration Of Justice: 8 month(s) 2 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-03-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2008-2009
• Appeal Filed On: 06-07-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: A K MEHLA
• Assessee Lawyers: MANISH TATIWALA
• Keywords: Rectification of order; Tangible material
• Section: 69C; 143(3); 142(1); 69B; 147; 148; 144

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S,A JAIPUR JH FOT; IKY JKO] U;KF;D LNL; ,OA JH FOE FLAG ;KNO] YS[KK LNL; DS LE{K BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM VK;DJ VIHY LA- @ ITA NO. 872/JP/2018 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2008-09 SMT. MEENA BALDUA, 304, UPASNA RESIDENCY, C-25, SAWAI JAISINGH HIGHWAY, COLLECTRATE CIRCLE, BANI PARK, JAIPUR. CUKE VS. THE ITO, WARD -5(5), JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: ABAPB 0137 G VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SHRI MANISH TATIWALA (C.A.) JKTLO DH VKSJ LS @ REVENUE BY : SHRI A. K. MEHLA (JCIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 05/03/2019 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT: 08/03/2019 VKNS'K@ ORDER PER: VIJAY PAL RAO, J.M. THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST TH E ORDER DATED 19.03.2018 OF LD. CIT (A), UDAIPUR FOR THE ASSESSME NT YEAR 2008-09. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS:- 1. THAT THE LEARNED COMMISSIONER OF INCOME TAX (AP PEALS-2), UDAIPUR HAS ERRED IN LAW AND IN FACTS IN TREATING T HE ASSESSMENT LEGALLY CORRECT. ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 2 2. THAT THE LEARNED COMMISSIONER OF INCOME TAX (APP EAL-2) HAS ERRED IN LAW AS WELL AS IN FACTS IN SUSTAINING ADDI TION MADE FOR PAYMENT OF CREDIT CARD. 3. THAT THE ASSESSEE HAS RIGHT TO ADD, AMEND OR ALT ER ANY GROUND OF APPEAL. 2. THE ASSESSEE IS AN INDIVIDUAL AND DID NOT FILE R ETURN OF INCOME U/S 139(1) OF THE ACT FOR THE YEAR UNDER CONSIDERATION. THE AO ISSUED NOTICE U/S 148 OF THE ACT ON 25.03.2015 AFTER RECO RDING THE REASONS THAT THE CREDIT CARD EXPENDITURE TO THE TUNE OF RS 15,29,050/- AND INTEREST RECEIVED IN THE SAVING BANK ACCOUNT OF RS. 39,000/- HAS ESCAPED ASSESSMENT. THE AO COMPLETED ASSESSMENT U/S 148 R.W.W. 144 OF THE I.T. ACT AND MADE THE ADDITION ON TOTAL AMOU NT OF RS. 15,68,050/-. THE ASSESSEE CHALLENGED THE ACTION OF THE AO BEFORE THE LD. CIT(A) AND CONTENDED THAT THE ASSESSEE EVEN DOE S NOT HAVE ANY CREDIT CARD THEREFORE, THE REASONS RECORDED BY THE AO FOR PAYMENT OF CREDIT CARD BILLS ARE NOT VALID REASONS FOR REOPENI NG OF THE ASSESSMENT OF THE ASSESSEE. THE LD. CIT(A) CALLED FOR A REMAND RE PORT AND AFTER CONSIDERING THE REMAND REPORT OF THE AO REJECTED TH E GROUND CHALLENGING THE VALIDITY OF THE OPENING. ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 3 3. BEFORE US, THE LD. AR OF THE ASSESSEE HAS SUBMI TTED THAT THE AO REOPENED THE ASSESSMENT BY RECORDING THAT AS PER AI R INFORMATION, THE ASSESSEE HAS PAID RS. 15,29,050/- FOR PAYMENT OF CR EDIT CARD BILLS AND ALSO RECEIVED INTEREST OF RS. 39,000/- BUT THE ASSE SSEE HAS NOT FILED ANY RETURN OF INCOME. THE LD. AR HAS POINTED OUT THAT T HE NOTICE ISSUED BY THE AO U/S 148 OF THE ACT WAS NOT RECEIVED BY THE A SSESSEE AND FURTHER THE ASSESSEE HAS CLEARLY RAISED THIS OBJECTION BEFO RE THE LD. CIT(A) AND POINTED OUT THAT THE ASSESSEE DOES NOT HAVE ANY CRE DIT CARD AND THEREFORE THE QUESTION OF PAYMENT OF CREDIT CARD BI LLS DOES NOT ARISE. IN THE REMAND REPORT THE AO HAS ACCEPTED THAT THERE WA S NO CREDIT CARD PAYMENT BY THE ASSESSEE HOWEVER, THE LD.CIT(A) HAS TREATED THE SAME AS CLERICAL MISTAKE AND SUSTAINED THE ADDITION MADE BY THE AO BY CONSIDERING THE SAME AS DEPOSIT MADE IN THE BANK AC COUNT. THE LD. AR OF THE ASSESSEE HAS RELIED UPON THE DECISION OF HON BLE BOMBAY HIGH COURT IN CASE OF HINDUSTAN LEVER LTD. VS. R.B. WADKAR 268 ITR 332 AND SUBMITTED THAT THE REASONS ARE REQUIRED TO BE R EAD AS THEY WERE RECORDED BY THE AO AND NO SUBSTITUTION OR DELETION IS PERMISSIBLE. THEREFORE, NO AMENDMENT, ALTERATION OR CHANGE CAN B E MADE TO THE REASONS RECORDED FOR REOPENING OF THE ASSESSMENT U/ S 148 OF THE ACT. EVEN IT IS NOT OPEN TO THE AO TO IMPROVE UPON THE R EASONS RECORDED AT ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 4 THE TIME OF ISSUING THE NOTICE EITHER BY ADDING OR SUBSTITUTING THE REASONS. THERE IS NO TANGIBLE MATERIAL HAVING NEXUS WITH THE REASONS RECORDED BY THE AO TO FORM THE BELIEF THAT INCOME A SSESSABLE TO TAX ON ACCOUNT OF PAYMENT OF CREDIT CARD BILLS HAS ESCAPED ASSESSEE. THE LD. AR HAS SUBMITTED THAT THE REASONS MUST PROVIDE A LI VE LINK TO THE FORMATION OF THE BELIEF THAT INCOME HAS ESCAPED ASS ESSMENT. IN SUPPORT OF HIS CONTENTION, HE HAS RELIED UPON THE DECISION OF HONBLE BOMBAY HIGH COURT IN CASE OF INFOTECH LTD. V/S ACIT 329 ITR 257. THE AO IN THE REASONS RECORDED HAS STATED THAT THE ASSESSEE H AS MADE PAYMENT OF CREDIT CARD BILLS BUT SUBSEQUENTLY IN THE REMAND REPORT HE HAS SUBMITTED THAT IT IS A CLERICAL MISTAKE IN THE REAS ONS RECORDED INSTEAD OF RECORDING CASH DEPOSIT IN THE SAVING BANK ACCOUNT O F THE ASSESSEE. THUS THE LD. AR HAS SUBMITTED THAT THE REOPENING OF THE ASSESSMENT AND CONSEQUENTLY REASSESSMENT ORDER IS NOT SUSTAINABLE AND LIABLE TO BE QUASHED. 4. ON THE OTHER HAND, LD. DR HAS SUBMITTED THAT THE ASSESSEE HAS NOT APPEARED BEFORE THE AO AND REASSESSMENT WAS PAS SED EX-PARTE. THE LD. CIT(A) HAS RECORDED THE FACT THAT IN THE NO TICE U/S 142(1) OF THE ACT THE AO HAS MENTIONED THE CASH DEPOSIT IN THE BA NK ACCOUNT AND NOT ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 5 THE CREDIT CARD PAYMENT. HE HAS RELIED UPON THE IMP UGNED ORDER OF THE LD. CIT(A). 5. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AS WELL AS RELEVANT MATERIAL ON RECORD. THERE IS NO DISPUTE THAT THE AS SESSEE DID NOT FILE ANY RETURN OF INCOME FOR THE YEAR UNDER CONSIDERATI ON. THE ASSESSING OFFICER HAS ISSUED NOTICE U/S 148 OF THE ACT ON 25. 03.2015 BY RECORDING THE REASONS AS UNDER:- AS PER AIR INFORMATION, THE ASSESSEE HAS PAID RS. 15,29,050/- FOR PAYMENT OF CREDIT CARD BILL & ALSO RECEIVED INT EREST OF RS. 39,000/- BUT AS PER ITD SYSTEMS NO RETURN OF INCOME FILED. THUS THE ASSESSEE DID NOT DISCLOSED FULLY & TRULY ALL MA TERIAL FACTS NECESSARY FOR HIS ASSESSMENT. THEREFORE, I HAVE REA SONS TO BELIEVE THAT INCOME OF RS. 15,29,050/- HAS ESCAPED ASSESSMENT. IN VIEW OF THE ABOVE, IT IS REQUESTED THAT NECESSAR Y APPROVAL AS LAID DOWN UNDER SUB SECTION (1) OF SECTION 151 OF T HE I.T. ACT, 1961 MAY KINDLY BE ACCORDED FOR ISSUANCE OF NOTICE U/S 148 OF THE ACT. IT IS CLEAR THAT THE AO HAS PROPOSED TO ASSESS THE INCOME ON ACCOUNT OF PAYMENT OF CREDIT CARD BILLS OF RS. 15,29,050/- AS WELL AS INTEREST OF RS. 39,000/- WHILE RECORDING THE REASONS FOR REOPENING. SINCE, NOBODY HAS APPEARED ON BEHALF OF THE ASSESSEE IN THE ASSESSMEN T PROCEEDINGS ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 6 THEREFORE, THE AO HAS PASSED THE EX-PARTE ORDER. TH E ASSESSING OFFICER WHILE PASSING THE ASSESSMENT ORDER HAS MADE THE ADD ITION AS UNDER:- WITH THESE REMARKS INCOME OF ASSESSEE ASSESSED U/ S 144 OF THE I.T. ACT, 1961 AS UNDER:- I) UNEXPLAINED PAYMENT OF CREDIT CARD BILL U/S 69C OF I.T. ACT, 1961 RS. 15,29,050/- II) UNDISCLOSED INTEREST RECEIVED IN CASH IN SB A/C 69B RS. 39,000/- TOTAL INCOME RS.15,68,050/- THUS, THE REASONS RECORDED AS WELL AS THE ADDITIONS FINALLY MADE BY THE AO IN THE ASSESSMENT ORDER CLEARLY SPELT OUT THE IN COME ON ACCOUNT OF UNEXPLAINED PAYMENT FOR CREDIT CARD BILLS U/S 69C O F THE ACT. THOUGH DURING THE APPELLATE PROCEEDINGS BEFORE THE LD. CIT (A), THE ASSESSING OFFICER IN THE REMAND REPORT HAS ACCEPTED THE FACT THAT THERE WAS NO PAYMENT BY THE ASSESSEE TOWARDS CREDIT CARD BILLS B UT THIS AMOUNT REPRESENTS THE CASH DEPOSITED IN THE BANK ACCOUNT. THEREFORE, THE REASONS RECORDED AND THE INCOME ASSESSED BY THE AO ON ACCOUNT OF PAYMENT OF CREDIT CARD BILLS ARE NOT BASED ON CORRE CT FACTS WHICH THE AO HAS STATED IN THE REMAND REPORT THAT THIS AMOUNT OF RS. 14,90,050/- REPRESENTS CASH DEPOSIT IN THE BANK ACCOUNT AND FUR THER INTEREST OF RS. 39,000/-. IF THE REASONS RECORDED BY THE AO ARE CON SIDERED IN LIGHT OF THE CORRECT FACTS OF THE CASE THEN IT IS CLEAR THAT AT THE TIME OF REOPENING OF THE ASSESSMENT THE AO HAS NOT APPLIED HIS MIND AND EVEN ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 7 WHILE PASSING THE REASSESSMENT ORDER THE AO HAS AGA IN MADE THE ADDITION ON ACCOUNT OF CREDIT CARD BILLS AND NOT AS CASH DEPOSITED IN THE BANK ACCOUNT. SUBSEQUENT RECTIFICATION OF MISTAKE I N THE REMAND REPORT WILL NOT SUBSTITUTE THE REASONS RECORDED BY THE AO FOR REOPENING OF THE ASSESSMENT. THE HONBLE BOMBAY HIGH COURT IN CASE O F HINDUSTAN LEVER LTD. VS. R.B. WADKAR (SUPRA) HAS HELD IN PARA 19 TO 23 AS UNDER:- 19. IN THE CASE IN HAND, IT IS NOT IN DISPUTE THAT THE ASSESSMENT YEAR INVOLVED IS 1996-97. THE LAST DATE OF THE SAID ASSESSMENT YEAR WAS 31ST MARCH, 1997 AND FROM THAT DATE IF FOU R YEARS ARE COUNTED, THE PERIOD OF FOUR YEARS EXPIRED ON 1ST MA RCH, 2001. THE NOTICE ISSUED IS DT. 5TH NOV., 2002 AND RECEIVE D BY THE ASSESSEE ON 7TH NOV., 2002. UNDER THESE CIRCUMSTANC ES, THE NOTICE IS CLEARLY BEYOND THE PERIOD OF FOUR YEARS. 20. THE REASONS RECORDED BY THE AO NOWHERE STATE THAT T HERE WAS FAILURE ON THE PART OF THE ASSESSEE TO DISCLOSE FULLY AND TRULY ALL MATERIAL FACTS NECESSARY FOR THE ASSESSMENT OF THAT ASSESSMENT YEAR. IT IS NEEDLESS TO MENTION THAT THE REASONS ARE REQUIRED TO BE READ AS THEY WERE RECORDED BY THE AO . NO SUBSTITUTION OR DELETION IS PERMISSIBLE. NO ADDITIO NS CAN BE MADE TO THOSE REASONS. NO INFERENCE CAN BE ALLOWED TO BE DRAWN BASED ON REASONS NOT RECORDED. IT IS FOR THE AO TO DISCLO SE AND OPEN HIS MIND THROUGH REASONS RECORDED BY HIM. HE HAS TO SPE AK THROUGH HIS REASONS. IT IS FOR THE AO TO REACH TO THE CONCL USION AS TO WHETHER THERE WAS FAILURE ON THE PART OF THE ASSESS EE TO DISCLOSE ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 8 FULLY AND TRULY ALL MATERIAL FACTS NECESSARY FOR HI S ASSESSMENT FOR THE CONCERNED ASSESSMENT YEAR. IT IS FOR THE AO TO FORM HIS OPINION. IT IS FOR HIM TO PUT HIS OPINION ON RECORD IN BLACK AND WHITE. THE REASONS RECORDED SHOULD BE CLEAR AND UNA MBIGUOUS AND SHOULD NOT SUFFER FROM ANY VAGUENESS. THE REASO NS RECORDED MUST DISCLOSE HIS MIND. REASONS ARE THE MANIFESTATI ON OF MIND OF THE AO. THE REASONS RECORDED SHOULD BE SELF-EXPLANA TORY AND SHOULD NOT KEEP THE ASSESSEE GUESSING FOR THE REASO NS. REASONS PROVIDE LINK BETWEEN CONCLUSION AND EVIDENCE. THE R EASONS RECORDED MUST BE BASED ON EVIDENCE. THE AO, IN THE EVENT OF CHALLENGE TO THE REASONS, MUST BE ABLE TO JUSTIFY T HE SAME BASED ON MATERIAL AVAILABLE ON RECORD. HE MUST DISCLOSE I N THE REASONS AS TO WHICH FACT OR MATERIAL WAS NOT DISCLOSED BY T HE ASSESSEE FULLY AND TRULY NECESSARY FOR ASSESSMENT OF THAT AS SESSMENT YEAR, SO AS TO ESTABLISH VITAL LINK BETWEEN THE REASONS A ND EVIDENCE. THAT VITAL LINK IS THE SAFEGUARD AGAINST ARBITRARY REOPENING OF THE CONCLUDED ASSESSMENT. THE REASONS RECORDED BY THE A O CANNOT BE SUPPLEMENTED BY FILING AFFIDAVIT OR MAKING ORAL SUBMISSION, OTHERWISE, THE REASONS WHICH WERE LACKING IN MATERI AL PARTICULARS WOULD GET SUPPLEMENTED, BY THE TIME THE MATTER REAC HES TO THE COURT, ON THE STRENGTH OF AFFIDAVIT OR ORAL SUBMISS IONS ADVANCED. 21. HAVING RECORDED OUR FINDING THAT THE IMPUGNED NOTIC E ITSELF IS BEYOND THE PERIOD OF FOUR YEARS FROM THE END OF THE ASST. YR. 1996-97 AND DOES NOT COMPLY WITH THE REQUIREMENTS O F PROVISO TO S. 147 OF THE ACT, THE AO HAD NO JURISDICTION TO RE OPEN THE ASSESSMENT PROCEEDINGS WHICH WERE CONCLUDED ON THE BASIS OF ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 9 ASSESSMENT UNDER S. 143(3) OF THE ACT. ON THIS SHOR T COUNT ALONE THE IMPUGNED NOTICE IS LIABLE TO BE QUASHED AND SET ASIDE. 22. SINCE WE ARE SETTING ASIDE THE IMPUGNED NOTICE ONLY ON THE FIRST GROUND OF CHALLENGE, IN OUR OPINION, IT IS NO T NECESSARY TO GO TO THE OTHER QUESTION AND RECORD OUR FINDINGS IN TH AT BEHALF. 23. IN THE RESULT, THE IMPUGNED NOTICE IS QUASHED AND S ET ASIDE. RULE IS MADE ABSOLUTE IN TERMS OF PRAYER CL. (A) WI TH NO ORDER AS TO COSTS. THEREFORE, FOR THE PURPOSE OF CONSIDERING THE VALID ITY OF REOPENING AND REASONS RECORDED BY THE AO TO ESTABLISH A LIVE LINK BETWEEN THE REASONS AND EVIDENCE ONLY REASONS RECORDED ARE TO BE LOOKED INTO AND NOT THE SUBSEQUENT EXPLANATION OF THE AO REGARDING THE MIST AKE IN THE REASONS. IN THE CASE IN HAND, THE AO HIMSELF AS ADMITTED THE MISTAKE IN THE REASONS RECORDED AND WE FIND THAT IT IS NOT ONLY MI STAKE IN THE REASONS RECORDED BUT THE AO HAS ALSO MADE THE ADDITION WHIL E PASSING THE IMPUGNED ASSESSMENT ORDER ON ACCOUNT OF CREDIT CARD BILLS U/S 69C OF THE I.T. ACT. THEREFORE, THE SUBSEQUENT EXPLANATION OF THE AO THAT THIS AMOUNT REPRESENTS THE CASH DEPOSIT IN THE BANK ACCO UNT WILL NOT REMOVE THE DEFECTS IN THE REASONS RECORDED. THE ASSESSING OFFICER IN THE REASONS RECORDED FOR REOPENING OF THE ASSESSMENT WA S PROPOSED TO ASSESS THE INCOME ON ACCOUNT OF UNEXPLAINED EXPENDI TURE INCURRED BY ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 10 THE ASSESSEE WHICH WAS ALSO ASSESSED TO TAX AT THE TIME OF PASSING THE REASSESSMENT ORDER. SUBSEQUENTLY, THE AO HAS COME O UT WITH THE EXPLANATION IN THE REMAND REPORT THAT THE AMOUNT RE PRESENTS THE INCOME ON ACCOUNT OF CASH DEPOSITED IN THE BANK ACC OUNT THEREFORE, IT IS RE-CATEGORIZATION OF TRANSACTION FROM UNEXPLAINED E XPENDITURE TO CASH DEPOSIT IN THE BANK ACCOUNT. THOUGH, THE LD. CIT(A) HAS STATED THAT IN THE NOTICE ISSUED U/S 142(1) OF THE I.T. ACT THE AO HAS MENTIONED THE CASH DEPOSIT IN THE BANK ACCOUNT HOWEVER, THE AO FI NALLY MADE THE ADDITION ON ACCOUNT OF PAYMENT OF CREDIT CARD BILLS THEN THE NOTICES ISSUED U/S 142(1) ITSELF WAS NOT CONSIDERED BY THE AO WHILE MAKING THE ADDITION. EVEN OTHERWISE THE NOTICE ISSUED U/S 142( 1) WOULD NOT SUBSTITUTE THE REASONS RECORDED BY THE AO. ACCORDIN GLY, IN VIEW OF THE UNDISPUTED FACTS THAT THE AMOUNT WHICH WAS PROPOSED TO ASSESS THE INCOME BY THE AO IN THE REASONS RECORDED IS NOT ACT UALLY REPRESENTS THE PAYMENT OF CREDIT CARD BILLS THEN, REOPENING BASED ON THE INCORRECT FACTS AND NON APPLICATION OF MIND IS NOT SUSTAINABLE IN L AW. HENCE, WE HOLD THAT THE REASONS RECORDED BY THE AO BASED ON INCORR ECT FACT IS NOT SUSTAINABLE IN LAW AND LIABLE TO BE QUASHED. SINCE, WE QUASHED THE REOPENING BEING INVALID THEREFORE, WE DO NOT PROPOS E TO GO INTO GROUND NO. 2 OF THE ASSESSEES APPEAL ON THE MERITS OF THE ADDITION. ITA NO. 872/JP/2018 SMT. MEENA BALDUA VS. ITO 11 IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOW ED. ORDER PRONOUNCED IN THE OPEN COURT ON 08/03/2019. SD/- SD/- FOE FLAG ;KNO FOT; IKY JKO (VIKRAM SINGH YADAV) (VIJAY PAL RAO) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 08/03/2019. * SANTOSH. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SMT. MEENA BALDUA, JAIPUR. 2. IZR;FKHZ@ THE RESPONDENT- ITO, WARD 5(5), JAIPUR. 3. VK;DJ VK;QDR@ CIT 4. VK;DJ VK;QDR@ CIT(A) 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR. 6. XKMZ QKBZY@ GUARD FILE {ITA NO. 872/JP/2018} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR