ACIT, Jaipur V. SAMBHAV GEMS LTD., Jaipur

ITA 929/JPR/2013

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 99344 (ITAT-JAIPUR)
• Duration Of Justice: 1 year(s) 10 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-10-2015
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2010-2011
• Appeal Filed On: 29-11-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: O P BHATEJA
• Assessee Lawyers: G G MUNDRA C A DHK
• Keywords: Opportunity of being heard
• Section: 143(3)

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 VH-VKJ-EHUK] YS[KK LNL; ,OA JH YFYR DQEKJ] U;KF; D LNL; DS LE{K BEFORE: SHRI T.R.MEENA, AM & SHRI LALIET KUMAR, JM VK;DJ VIHY LA -@ ITA NO. 929/JP/2013 FU/KZKJ.K O'K Z @ ASSESSMENT YEAR : 2010-11 ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR. CUKE VS. M/S SAMBHAV GEMS LTD. F-64, GEM & JEWELLERY ZONE, EPIP, SITAPURA IND. AREA, JAIPUR. LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO. AAFCS 3365 L VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT JKTLO DH VKSJ LS@ REVENUE BY : SHRI O.P. BHATEJA (ADDL.CIT) FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI G.G. MUNDRA (CA) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 29/09/2015. MN?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 09/10/2015. VKNS'K@ ORDER PER T.R. MEENA, A.M. THIS IS AN APPEAL FILED BY THE REVENUE AGAINST THE ORDER DATED 02/09/2013 OF THE LEARNED C.I.T.(A)-II, JAIPUR FOR A.Y. 2010-11. THE SOLE GROUND OF APPEAL IS REPRODUCED AS UNDER:- (I) DELETING TRADING ADDITION OF RS. 54,98,268/- M ADE BY A.O., WITHOUT APPRECIATING THAT NEITHER QUANTITATIVE AND QUALITATIVE DETAILS OF STOCK WERE MAINTAINED NOR DAY TO DAY STOCK REGISTER OF RAW 2 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. MATERIAL CONSUMED WAS KEPT BY ASSESSEE WHICH RENDERED THE ACCOUNT BOOKS DEFECTIVE AND UNRELIABLE. 2. THE ASSESSEE DERIVED INCOME FROM MANUFACTURING AN D EXPORT OF GEMS, STONES AND JEWELLERY ETC. THE ASSESSEE FILED IT S RETURN ON 13/10/2010 DECLARING TOTAL INCOME OF RS. 48,44,449/ -. THE CASE WAS SCRUTINIZED U/S 143(3) OF THE INCOME TAX ACT, 1961 ( HEREINAFTER REFERRED AS THE ACT). THE ASSESSEE FILED DETAILS REQUIRED BY THE ASSESSING OFFICER I.E. PRODUCED BOOKS OF ACCOUNT AND VOUCHERS ETC. WHI CH WERE EXAMINED ON TEST CHECK BY THE ASSESSING OFFICER. THE LD ASSE SSING OFFICER OBSERVED THAT THE ASSESSEE HAD SHOWN FOLLOWING BUSINESS RESUL TS FROM A.Y. 2007-08 TO A.Y. 2010-11, WHICH IS AS UNDER:- A.Y. SALES RS. G.P. RS. G.P. RATE 2007-08 3218.71 LACS 379.00 LACS 11.77% 2008-09 2740.98 LACS 404.00 LACS 14.74% 2009-10 1845.30 LACS 355.28 LACS 20.62% 2010-11 2248.47 LACS 349.74 LACS 15.55% DURING THE YEAR UNDER CONSIDERATION, THE ASSESSEE H AD SHOWN TOTAL TURNOVER OF MORE THAN RS. 22.48 CRORES UPON WHICH G ROSS PROFIT OF MORE THAN RS. 3.49 CRORES HAD BEEN DECLARED THEREBY GIV ING GP RATE OF 15.55% AS AGAINST GP OF MORE THAN RS. 3.55 CRORES DECLARED ON TOTAL TURNOVER OF MORE THAN RS. 18.45 CRORES THEREBY GIVING G.P. RAT E @ 20.62% FOR THE 3 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. A.Y. 2009-10. THE ASSESSEES SALE HAD INCREASED BY R S. 4.00 CRORES WHEREAS THE GROSS PROFIT RATE DECLINED BY ABOUT 5% I N COMPARISON TO THE IMMEDIATE PRECEDING YEAR. THE ASSESSING OFFICER GAVE REASONABLE OPPORTUNITY OF BEING HEARD ON THIS ISSUE. THE ASSESS EE ALSO FILED REPLY VIDE LETTER DATED 05/2/2013, WHICH HAS BEEN REPRODUC ED ON PAGE 2 AND 3 OF THE ASSESSMENT ORDER BY THE ASSESSING OFFICER. A FTER CONSIDERING THE ASSESSEES REPLY, THE LD ASSESSING OFFICER HELD THA T THE ASSESSEE HAD NOT MAINTAINED DAY TO DAY QUANTITATIVE AND QUALITATIVE DETAILS PERTAINING TO VARIOUS ITEMS PURCHASES AND SOLD, OPENING STOCK ETC . IN ABSENCE OF THESE DETAILS, THE VERACITY OF THE TRADING ACCOUNT CANNOT BE VERIFIED IN TERMS OF QUANTITATIVE AS WELL AS QUALITATIVE DETAILS, THEREFO RE, CLOSING STOCK DISCLOSED BY THE ASSESSEE CANNOT VERIFY. AS PER THE LD ASSESSING OFFICER, THESE FACTS HAD BEEN ADMITTED BY THE ASSESSEE DURIN G THE COURSE OF ASSESSMENT PROCEEDINGS. IN THE AUDIT REPORT IN FORM NO. 3CD THE AUDITORS HAVE MADE REMARKS IN THIS REGARD. THE ASSESSEE WAS AS KED TO GIVE THE DETAILS OF YIELD PERCENTAGE BUT THE ASSESSEE ADMITT ED THAT THERE WAS NO POSSIBILITY TO GIVE THESE DETAILS ON THE BASIS OF B OOKS OF ACCOUNT MAINTAINED BY IT. SIMILARLY HE ALSO FOUND LARGE VAR IATION IN CUT STONES. THE ASSESSEE HAD NOT SHOWN UNIFORM OR COMPATIBLE PRODUCT ION OR RE-CUT LOSS 4 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. WHICH COULD JUSTIFY THE CORRECTNESS AND TRUTHFULNESS OF THE BOOKS OF ACCOUNT. SIMILARLY THE REJECTION OF GOODS ALSO NOT VERIFIABLE FROM THE RECORD, THEREFORE, THE ASSESSING OFFICER GAVE A NOT ICE AS TO WHY BOOKS OF ACCOUNT SHOULD NOT BE REJECTED U/S 145(3) OF THE AC T AND ALSO PROPOSED TO APPLY 18% GROSS PROFIT RATE AS APPLIED IN THE A. Y. 2008-09. THE ASSESSEE AGAIN REPLIED VIDE LETTER DATED 20/2/2013, WHICH HAS BEEN REPRODUCED BY THE ASSESSING OFFICER ON PAGE NO. 5 A ND 6 OF THE ASSESSMENT ORDER. AFTER CONSIDERING THE ASSESSEES REPLY, THE LD ASSESSING OFFICER HELD THAT THE FACTS AND CIRCUMSTANCES OF TH E CASE AND THE SUBMISSION OF THE ASSESSEE WAS CONSIDERED BY HIM AS ALSO MENTIONED IN PRECEDING PARA THAT THE ASSESSEE HAD NOT MAINTAINED ANY QUANTITATIVE AND QUALITATIVE DETAILS OF OPENING AND CLOSING STOCK AN D HAD ALSO NOT MAINTAINED ANY DAY TO DAY STOCK REGISTER OR MANUFAC TURING REGISTER. THEREFORE, HE REJECTED THE BOOK RESULT U/S 145(3) OF THE ACT. HE RELIED ON THE DECISIONS OF HON'BLE SUPREME COURT IN THE CASE OF CIT VS. BRITISH PAINTS INDIA LTD. 188 ITR 44 (SC) AND CST VS. H.ESUF ALI, H.M. ABDUL ALI 90 ITR 271 (SC). AFTER DISCUSSING THE LEGAL POSITION , THE LD ASSESSING OFFICER HELD THAT GROSS PROFIT RATE @ 20% WAS APPLIED IN A.Y. 2002-03 AND SUBSEQUENT YEARS MAINLY IN THE GROUND THERE WERE UNV ERIFIABLE PURCHASES 5 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. FROM CERTAIN BOGUS PARTIES. HOWEVER, DURING THE CURR ENT YEAR NO UNVERIFIABLE PURCHASES WERE FOUND FROM ANY OF SUCH B OGUS PARTIES AS IN THE PAST. FURTHER HE ALSO CONSIDERED THE FLUCTUATIO N IN THE GP ON ACCOUNT OF DOLLAR PRICE AND GLOBAL RECESSION IN FOREIGN TRA DE SPECIFICALLY IN GEM AND JEWELLERY ITEMS. FINALLY HE APPLIED G.P. RATE @ 18% A S APPLIED IN A.Y. 2008-09 ON TOTAL TURNOVER OF RS. 22,48,47,524/- WHI CH GAVE G.P. AT RS. 4,04,72,554/- AGAINST THE G.P. DECLARED OF RS. 3,49 ,74,286/-. THE DIFFERENCE OF RS. 54,98,268/- WAS ADDED IN THE INCOM E OF THE ASSESSEE. 3. BEING AGGRIEVED BY THE ORDER OF THE ASSESSING OF FICER, THE ASSESSEE CARRIED THE MATTER BEFORE THE LD CIT(A), WHO HAD DEL ETED THE ADDITION BY OBSERVING THAT THE LD ASSESSING OFFICER APPLIED G.P . RATE ON THE BASIS OF ASSESSMENT MADE IN A.Y. 2008-09 AS THE LD PREDECESS OR VIDE ORDER DATED 12/12/2011 DECIDED THE APPEAL FOR A.Y. 2008-09, IN WHICH THE TRADING ADDITION MADE BY THE ASSESSING OFFICER WAS DELETED. HE HAS REPRODUCED THE FINDING OF THE LD CIT(A) FOR A.Y. 2008-09 ON PAG ES NOS. 11 TO 14 OF THE ORDER. HE FURTHER HELD THAT THE LD ASSESSING OF FICER HAD MADE CERTAIN THEORETICAL OBSERVATIONS FOR REJECTING THE BOOKS OF ACCOUNT. THE ASSESSING OFFICER HAD FAILED TO PINPOINT ANY MATERIAL DEFECT IN THE BOOKS OF ACCOUNT, THE SALES AND PURCHASES OF THE APPELLANT HAD BEEN A CCEPTED AS GENUINE. 6 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. THE GRIEVANCE OF THE A.O. HINGES AROUND THE WASTAGE A ND YIELD SHOWN BY THE APPELLANT. HOWEVER, THE BOOKS OF ACCOUNT WERE AUD ITED AND THERE COULD NOT BE ANY STANDARD RATE OF YIELD FOR FINISHE D GOODS OR WASTAGE IN THE MANUFACTURING. SIMILARLY THE PERCENTAGE OF WASTA GE/REJECTION WOULD ALSO DEPEND ON THE QUALITY OF RAW MATERIAL. HE FURTH ER RELIED ON THE DECISION IN THE CASE OF HONBLE PUNJAB & HARYANA HI GH COURT IN THE CASE OF CIT VS. OM OVERSEAS 315 ITR 185 (P&H) ON REJECTION OF BOOKS OF ACCOUNT, NOT POINTED OUT ANY SPECIFIC DEFECT. THE LD ASSESSING OFFICER HAD REJECTED THE BOOKS OF ACCOUNT ONLY ON THE GROUND TH AT THE ASSESSEE HAD NOT BEEN ABLE TO GET RECORDS OF RAW MATERIAL CONSUME D IN RESPECT OF EACH AND EVERY ITEM PURCHASED BY THE ASSESSEE. BY CONSID ERING HIS PREDECESSORS ORDER AS WELL AS THE HONBLE ITAT ORDER IN ASSESSEES OWN CASE, HE HELD THAT THE LD ASSESSING OFFICER WAS NOT RIGHT IN REJECTING THE BOOKS RESULT AND APPLIED A GP RATE @ 18%. HE ALSO RE FERRED PARA 3.9 OF ASSESSMENT ORDER WHEREIN THE LD ASSESSING OFFICER HI MSELF ADMITTED THAT THERE WAS NO UNVERIFIABLE PURCHASES DURING THE YEAR AND FALLEN IN THE DOLLAR PRICE OF GLOBAL RECESSION, WHICH AFFECTED TH E JEWELLERY BUSINESS. THE GROSS PROFIT RATE DECLARED DURING THE YEAR IS MORE THAN ALL THE YEARS EXCEPT A.Y. 2009-10. THE LD ASSESSING OFFICER ISSUED THE SHOW CAUSE 7 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. NOTICE FOR REJECTION OF BOOK RESULT AS WELL AS APPLI CATION OF G.P. RATE ON THE BASIS OF FINDING GIVEN FOR A.Y. 2008-09, WHICH HAS B EEN DELETED BY THE LD CIT(A) AND CONFIRMED BY THE HONBLE ITAT. THEREFORE, H E ALLOWED THE APPEAL. 4. NOW THE REVENUE IS IN APPEAL BEFORE US. THE LD DR HAS VEHEMENTLY SUPPORTED THE ORDER OF THE ASSESSING OFFICER. AT TH E OUTSET, THE LD AR OF THE ASSESSEE HAS REITERATED THE ARGUMENTS MADE BEFO RE THE LD CIT(A). HE FURTHER ARGUED THAT THE ISSUE INVOLVED IN APPEAL IS COVERED IN FAVOUR OF THE ASSESSEE FOR APPEAL ORDER IN A.Y.2008-09 PASSED BY THE HONBLE BENCH IN THE CASE OF ASSESSEE COMPANY VIDE ORDER DATED 28/08 /2014 IN ITA NO. 220/JP/2012. THE HONBLE BENCH IN THE CASE OF ASSESS EE FOR A.Y. 2002-03 AND 2007-08 HAD REFERRED THE SAID APPEAL ORDER. THER EFORE, HE PRAYED TO DECIDE THE APPEAL ACCORDINGLY AS THE FACTS AND CIRC UMSTANCES OF THE ASSESSEES CASE ARE IDENTICAL. IN THE YEAR UNDER CO NSIDERATION, THE TURNOVER OF THE ASSESSEE WAS MORE THAN RS. 22.48 CRO RES AND GROSS PROFIT DECLARED MORE THAN RS. 3,49 CRORES WITH G.P. RATE @ 1 5.55% IN COMPARISON TO A.Y. 2009-10 WHERE GROSS TURNOVER WAS MORE THAN RS. 18.45 CRORES WITH G.P. MORE THAN RS. 3.55 CRORES WITH G.P. @ 19.25%. THE GP WAS LESSER BY ABOUT 5.54 CRORES ONLY IN A.Y. 2 009-10, WHICH IS 8 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. EVIDENT FROM STATISTICS SUBMITTED BY THE ASSESSEE D URING THE ASSESSMENT PROCEEDINGS. IN A.Y. 2009-10, IT WAS ACHIEVED HIGHER G.P. RATE THE EXPORT PRICE OF GOODS WERE RAISED AND REALIZATION FROM EXPO RT SALE IN US DOLLAR CONVERTED INTO RUPEES WAS MORE BECAUSE OF HIGHER EXC HANGE RATE BUT THE SAME AFFECTED TO TURNOVER OF COMPANY WHICH FELL DOW N BY 33%IN THIS YEAR AS COMPARED TO IMMEDIATELY PRECEDING YEAR AND BY AB OUT 44% FROM A.Y. 2008-09. THE ASSESSEE COMPANY, THEREFORE, TO ACHIEVE MORE TURNOVER COMPETITIVE FOREIGN MARKET AND TO ACHIEVE HIGHER TO TAL GROSS PROFIT HAS TO SCALE DOWN EXPORT SALE PRICES WHICH RESULTED IN LOWER RATE OF GROSS PROFIT BUT MORE TOTAL GROSS PROFIT. FURTHER SUBMITTED TO T HE LD ASSESSING OFFICER THAT IN A.Y. 2010-11 EXCHANGE RATE OF US DOLLAR IN WHICH EXPORTS ARE MADE WERE CONTINUOUSLY FALLING DOWN AND IT RESULTED IN LESSER REALIZATION OF EXPORT VALUE BY OVER RS. 61 LACS WHICH EFFECTED G .P. RATE BY ABOUT 2.74% (STATEMENT SUBMITTED IN SUPPORT OF CONTENTION ) AND FURTHER COST OF RAW MATERIAL INCREASED DUE TO CONTINUOUS INCREASE IN GOLD PRICE AND OTHER METAL INCREASES UPTO 4.27% WHICH ALSO EFFECTED G.P. RATE (COMPARATIVE STATEMENT OF RAW MATERIAL COST IS SUBMITTED). THUS TH E FALL IN G.P. RATE OF THIS YEAR IN COMPARISON TO EXCEPTIONAL RESULTS FOR A.Y. 2009-10 ARE FULLY EXPLAINED AND THE SAME IS HIGHER AS COMPARED TO ALL THE EARLIER YEARS. HE 9 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. FURTHER ARGUED THAT THE LD ASSESSING OFFICER WAS WRON G IN COMPARING THE RESULTS OF THIS YEAR ONLY WITH A.Y. 2009-10 WITHOUT E XAMINING THE HISTORY OF THE CASE WHILE THE TURNOVER OF ASSESSEE COMPANY FOR A.Y. 2009-10 WAS LOWEST. THE HISTORY OF DECLARED RESULTS FOR ALL PAST YEARS WILL SHOW THAT IN THIS A.Y. 2010-11, G.P. RATE IS HIGHER FROM ALL PAS T YEARS EXCEPT IN A.Y. 2009-10. THE TURNOVER OF A.Y.(S) 2002-03, 2004-05 AN D 2005-06 ARE SIMILAR TO THIS YEAR AND MARGINALLY LOWER FROM A.Y.( S) 2003-04, 2006-07 AND 2007-08 WHEREIN DECLARED GROSS PROFIT RATE WAS MU CH LOWER BUT THOSE WERE ALSO ACCEPTED IN ASSESSMENT. THUS LOOKING TO THE SE FACTS THE DECLARED GROSS PROFIT RATE OF THE YEAR IS FAIR AND REASONABLE AND FALL FROM DECLARED GROSS PROFIT RATE IN THIS YEAR FROM A.Y. 2 009-10 HAVING BEEN FULLY EXPLAINED AND SO DECLARED GROSS PROFIT FOR THE YEAR DESERVES TO BE ACCEPTED. THE APPEAL ORDER PASSED BY THE CIT(A) IS AF TER CONSIDERING ALL THE ABOVE FACTS AND PAST HISTORY OF THE CASE AND IS A DETAILED AND FULLY REASONED ORDER WHICH DESERVES TO BE CONFIRMED. ACCOR DINGLY, HE PRAYED THAT THE APPEAL FILED BY THE DEPARTMENT HAS NO MERI TS AND DESERVES TO BE DISMISSED. 5. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON RECORD. THE COORDI NATE BENCH HAD 10 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. DECIDED THE IDENTICAL ISSUE FOR A.Y. 2008-09 IN ITA NO. 220/JP/2012 WHEREAS THE FOLLOWING OBSERVATIONS HAVE BEEN MADE BY THE BENCH: WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED TH E MATERIALS AVAILABLE ON RECORD. DURING THE COURSE OF HEARING, THE LD DR COULD NOT CONTROVERT THE FINDINGS OF THE LD CIT(A) IN ASSESSEES CASE AND IN THE PAST ALSO THE CASES OF T HE ASSESSEE ON THIS ISSUE WERE DECIDED IN FAVOUR OF THE ASSESSEE . THUS IN VIEW OF THE ABOVE FACTS AND CIRCUMSTANCES OF THE CAS E, WE DO NOT FIND ANY REASON TO DEVIATE FROM THE DECISIONS G IVEN BY THE COORDINATE BENCH IN THE CASE OF THE ASSESSEE. THEREF ORE, WE CONFIRM THE ORDER OF THE LD CIT(A) ON THIS ISSUE. WE HAVE VERIFIED THE FACTS, WHICH ARE IDENTICAL TO A.Y. 2008-09. THE SIMILAR TRADING ADDITIONS WERE MADE BY THE ASSESSIN G OFFICER BY REJECTING THE BOOKS OF ACCOUNT, NOT MAINTAINING QUANTITATIVE AND QUALITATIVE DETAILS OF STOCK AND DAY TO DAY STOCK REGISTER OF RAW MATERI AL CONSUMED. DURING THE YEAR, THE ASSESSEES TURNOVER HAS GONE UP WHEREA S THE G.P. RATE HAS GONE DOWN COMPARED TO IMMEDIATE PRECEDING YEAR BUT I S MORE COMPARED TO A.Y. 2007-08 AND 2008-09 EXCEPT A.Y. 2009-10. THE LD AR HAD EXPLAINED THE REASONS FOR MORE G.P. RATE IN THE A.Y . 2009-10. AS THE LD CIT(A) HAS DISCUSSED THE REASONS FOR DECLINE OF GP R ATE I.E. COMPETITION IN MARKET, DOLLAR PRICE AND RECESSION IN INTERNATIONAL MARKET, WHICH HAS NOT 11 ITA NO. 929/JP/2013 ACIT VS M/S SAMBHAV GEMS LTD. BEEN CONTROVERTED BY THE LD DR. THEREFORE, WE UPHOLD THE ORDER OF THE LD CIT(A). 6. IN THE RESULT, THE REVENUES APPEAL IS DISMISSED . ORDER PRONOUNCED IN THE OPEN COURT ON 09/10/2015. SD/- SD/- YFYR DQEKJ VH-VKJ-EHUK (LALIET KUMAR) (T.R. MEENA) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 09 TH OCTOBER, 2015. RANJAN* VKNS'K DH IZFRFYFI VXZSFKR @ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ @ THE APPELLANT- THE ACIT, CIRCLE-5, JAIPUR. 2. IZR;FKHZ @ THE RESPONDENT- M/S SAMBHAV GEMS LTD., JAIPUR. 3. VK;DJ VK;QDR @ 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.929/JP/2013) VKNS'KKUQLKJ @ BY ORDER, LGK;D IATHDKJ @ ASST. REGISTRAR