Mahaveer Abhushan Bhandar, Kolhapur V. Income-tax Officer,

ITA 954/PUN/2014

• Counselvise Citation: [2017] 128 COUNSELVISE.COM (IT) 6942 (ITAT-PUNE)
• Duration Of Justice: 2 year(s) 10 month(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 17-03-2017
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: A
• Next Hearing Date: 04-01-2017
• Assessment Year: 2010-2011
• Appeal Filed On: 09-05-2014
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: ANIL CHAWARE
• Keywords: Business income; Search and seizure; Deemed to accrue or arise in india; Documents seized
• Section: 69C; 143(3); 133A; 234B; 131; 15

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH A, PUNE , . . , ' BEFORE MS. SUSHMA CHOWLA, JM AND SHRI R.K. PANDA, AM . / ITA NO.954/PUN/2014 # $ $ / ASSESSMENT YEAR: 2010-11 SHRI MAHAVEER ABHUSHAN BHANDAR, 214, C WARD, BHENDE GALLI, KOLHAPUR. . / APPELLANT PAN: AAFFS0537B VS. THE INCOME TAX OFFICER, CENTRAL, KOLHAPUR. . RESPONDENT / APPELLANT BY : SHRI M.K.KULKARNI / RESPONDENT BY : SHRI ANIL CHAWARE DATE OF HEARING : 15.03.2017 / DATE OF PRONOUNCEMENT: 17.03.2017 % / ORDER PER SUSHMA CHOWLA, JM: THE APPEAL FILED BY THE ASSESSEE IS AGAINST THE ORD ER OF COMMISSIONER OF INCOME TAX (APPEALS), KOLHAPUR DATED 29/01/2014 RELATING TO ASSESSMENT YEAR 201011 AGAINST ORDER PASSED U/S 143(3) R.W.S. 153C(2) OF THE INCOME TAX ACT, 1961 (IN SHORT THE ACT). ITA NO.954/PUN/2014 FOR A.Y 2010-11 SHRI MAHAVEER ABHUSHANI BHANDAR 2 2. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS O F APPEAL:- 1) ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW THE REQUISITION ISSUED UNDER S. 132A AB-INITI VOID RESULTING INTO I LLEGAL ASSESSMENT MADE BY THE A.O. AND CONFIRMED BY THE LD. CIT(A) AS THE POL ICE UNDER S.457 OF CRPC WERE BOUND TO PRODUCE THE SEIZED NATURAL BEFORE THE COURT AND SEEK INSTRUCTIONS/ORDERS FROM THE COURT ABOUT TRANSFER O F THE SEIZED MATERIAL. IN THE ABSENCE OF THIS THE REQUISITION U/S 132A ITSELF WAS INVALID. THE ASSESSMENT CONFIRMED U/S 153C BE STRUCK DOWN. 2) ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND I N LAW THE LD. CIT(A) WAS NOT JUSTIFIED IN REJECTING THE CLAIM OF REMUNERATIO N TO PARTNER UNDER S. 40(B) OF THE ACT HOLDING THAT SURRENDERED INCOME IN SURVEY U /S 133-A WAS DEEMED INCOME AND NOT BUSINESS INCOME. IT IS SETTLED LAW THAT THE INCOME RETURNED IN THE RETURN OF INCOME WHICH IS CREDITED TO P & L A/C IS BUSINESS INCOME ENTITLED TO DEDUCTION UNDER S. 40(B) OF THE ACT. T HE DEDUCTION BE ALLOWED. 3) ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND I N LAW THE UNDERLYING PURPOSE OF MAKING ASSESSMENT OF TOTAL INCOME U/S 15 3A/153C IS TO ASSESS THE INCOME WHICH WAS NOT DISCLOSED OR WOULD NOT HAVE BE EN DISCLOSED. THE PROVISIONS OF S. 153A/153C CANNOT BE INTERPRETED TO BE A FURTHER INNINGS FOR THE A.O. AND/OR ASSESSEE BEYOND PROVISIONS OF S.139 (RETURN OF INCOME). THE SURRENDERED INCOME WAS ALREADY DISCLOSED IN THE RET URN OF INCOME WHICH CANNOT BE TREATED AS DEEMED INCOME. THE CLAIM OF DEDUCTION UNDER S. 40(B) WAS WRONGLY REJECTED. IT BE ALLOWED. 4) ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND I N LAW THE INCOME DECLARED IN THE RETURN AFTER SEARCH AND SEIZURE ACTION OR IN THE BOOKS OF ACCOUNT IS NOT ASSESSABLE AS UNDISCLOSED INCOME UNDER S.69, 69A OR S.69B OF THE ACT. THE ASSESSEE WAS THEREFORE, ENTITLED TO DEDUCTION U/S 4 0(B) OF THE ACT. IT BE ALLOWED ACCORDINGLY. 5) ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND I N LAW THE LEVY OF INTEREST U/S 234A, 234B AND 234C IS NOT JUSTIFIED. 3. THE LD. AR FOR THE ASSESSEE POINTED OUT THAT THE GROUNDS OF APPEAL NO.1 IS NOT PRESSED. HENCE, THE SAME IS DISMISSED AS NOT PRESSED. 4. THE LD. AR FOR THE ASSESSEE FURTHER POINTED THAT THE ONLY ISSUE RAISED IN THE BALANCE GROUNDS OF APPEAL IS AGAINST THE CLAIM OF DEDUCTION U/S 40(B) OF THE ACT. 5. BRIEFLY, IN THE FACTS OF THE CASE, A PASSENGER B US CARRYING CASH AND JEWELLERY WAS INTERCEPTED BY THE BHUINJ POLICE AUTH ORITIES. THE CASH, JEWELLERY ITA NO.954/PUN/2014 FOR A.Y 2010-11 SHRI MAHAVEER ABHUSHANI BHANDAR 3 AND DOCUMENTS WERE SEIZED FROM TWO PERSONS WHO WERE ENGAGED IN COURIER BUSINESS. INFORMATION WAS PASSED ON TO INVESTIGATI ON WING AND CONSEQUENTLY SEIZURE ACTION U/S 132A OF THE ACT WAS CARRIED OUT ON 29/10/2010 AT BHUINJ POLICE STATION, SATARA. THE INVESTIGATION WING REQ UISITIONED THE GOODS AND DOCUMENTS SEIZED BY THE POLICE AS PER THE INVENTORY OF STOCK IN ANNEXURE AND VIDE PANCHNAMA DATED 29/10/2010. CERTAIN GOODS AND DOCUMENTS BELONGED TO THE ASSESSEE FIRM SHRI DILEEP JIVRAJ OSWAL, PART NER OF THE ASSESSEE FIRM WAS SUMMONED AND HIS STATEMENT WAS RECORDED U/S 131 OF THE ACT ON 24/12/2010. SINCE THE ASSETS AND DOCUMENTS WHICH WERE REQUISITI ONED AND SEIZED BELONGED TO THE ASSESSEE I.E. OTHER THAN THE PERSON WITH RESPECT TO WHOM SEARCH U/S 132A OF THE ACT WAS INITIATED, THE ASSES SING OFFICER ISSUED NOTICE U/S 153C OF THE ACT. IN RESPONSE, THERETO, THE ASS ESSEE FILED RETURN OF INCOME DECLARING INCOME OF RS.14,98,450/-. THE ASSESSEE W AS ENGAGED IN THE BUSINESS OF MANUFACTURING AND TRADING IN SILVER ART ICLES ON WHOLESALE BASIS AS PER THE ORDERS OF THE CUSTOMERS ESPECIALLY FROM MUM BAI, ETC,. DURING THE COURSE OF ASSESSMENT PROCEEDINGS THE ASSESSEE WAS A SKED TO PRODUCE THE BOOKS OF ACCOUNTS, BILLS AND VOUCHERS, WHICH WERE S O PRODUCED. 6. ON VERIFICATION OF THE CASE RECORDS, THE ASSESSI NG OFFICER NOTED THAT SURVEY ACTION U/S 133A OF THE ACT WAS CARRIED OUT A T THE BUSINESS PREMISES OF THE ASSESSEE ON 03/10/2010 RESULTING IN DECLARATION OF ADDITIONAL INCOME BY THE ASSESSEE ON ACCOUNT OF 187.066 KGS EXCESS STOCK IN THE FORM OF FINE SILVER, JEWELLERY / ARTICLES AND EXCESS CASH OF RS.3,05,884 /- AGGREGATING TO RS.30,02,440/-. THE ASSESSING OFFICER NOTED THAT T HE RETURNED INCOME EXCLUDING DISCLOSURE MADE DURING SURVEY ACTION WAS LESS THAN THE DECLARED INCOME OF THE PRECEDING YEAR I.E. ASSESSMENT YEAR 2 009-10. THE CASE OF THE ASSESSEE WAS SELECTED FOR SCRUTINY WHICH WAS OBJECT ED BY THE ASSESSEE. THE ITA NO.954/PUN/2014 FOR A.Y 2010-11 SHRI MAHAVEER ABHUSHANI BHANDAR 4 SAID CONTENTIONS OF THE ASSESSEE WERE REJECTED. TH E ASSESSING OFFICER FURTHER NOTED THAT THE ASSESSEE HAD DECLARED ADDITIONAL INC OME AS INCOME FROM BUSINESS AND CONSIDERED THE SAME FOR CALCULATING BO OK PROFIT U/S 40(B) OF THE ACT AND HAD DEBITED REMUNERATION TO PARTNERS AT RS. 24,72,783/-. THE ASSESSING OFFICER AFTER DELIBERATION ON THE ISSUE V IDE PARA 9.3 ONWARDS OBSERVED THAT THE ASSESSEE WAS FOUND OWNER OF STOCK OF SILVER JEWELLERY / ARTICLES AND EXCESS CASH, WHICH INVESTMENT WAS NOT RECORDED IN HIS BOOKS OF ACCOUNTS. FURTHER, THE ASSESSEE HAD OFFERED NO SAT ISFACTORY EXPLANATION NOR RECONCILED THE DECLARED VALUE OF ASSET / SILVER ART ICLES STOCK. THE ASSESSEE HAD ALSO FAILED TO EXPLAIN AS TO HOW AND FROM WHAT SOURCE HE INVESTED THE MONEY IN SILVER ARTICLES WITH REGARD TO ITS PURCHAS E. THE ASSESSING OFFICER THUS HELD THAT THE ADDITIONAL INCOME OF RS.30,02,44 0/- COULD NOT BE ADDED TO THE BUSINESS INCOME. THE ASSESSING OFFICER HELD TH AT THE SAID ADDITIONAL INCOME IS TO BE ADDED TO THE TOTAL INCOME AS DEEMED INCOME U/S 69A AND 69B OF THE INCOME TAX ACT. THE ASSESSING OFFICER REDUC ED DEDUCTION CLAIMED U/S 40(B) OF THE ACT TO RS.17,33,202/- AS AGAINST THE C LAIM OF THE ASSESSEE AT RS.24,72,783/-. 7. IN APPEAL, THE COMMISSIONER OF INCOME TAX (APPEA LS) NOTED THE NO OBJECTION OF THE ASSESSEE IN TAXING THE VALUE OF EX CESS CASH AND EXCESS STOCK U/S 69A AND 69B OF THE ACT. THE COMMISSIONER OF IN COME TAX (APPEALS) ALSO TOOK NOTE OF THE CLAIM OF THE ASSESSEE THAT SINCE I T DID NOT HAVE ANY OTHER SOURCE OF INCOME, THE EXCESS STOCK WHICH WAS DECLAR ED DURING SURVEY WAS BUSINESS INCOME. THE COMMISSIONER OF INCOME TAX (A PPEALS) HELD AS UNDER: 10.. THE FACT THAT EXCESS STOCK HAS BEEN PART OF ASSESSEES BUSINESS IS NOT DENIED. HOWEVER, THAT DOES NOT LED TO CONCLUSION THAT THE EXCESS STOCK STANDS EXPLAINED. THE FACT IS THA T THIS EXCESS STOCK WAS ACQUIRED OUT OF MONEY, THE SOURCE OF WHICH IS N OT KNOWN, THEREFORE, THE INVESTMENT IN THIS EXCESS STOCK IS NOT DISCLOSE D. IN VIEW OF THIS ITA NO.954/PUN/2014 FOR A.Y 2010-11 SHRI MAHAVEER ABHUSHANI BHANDAR 5 DISCUSSION, ALL THE GROUNDS TAKEN BY THE APPELLANT ON THIS ISSUE ARE REJECTED AND ACTION OF THE ASSESSING OFFICER IN ASS ESSING VALUE OF EXCESS STOCK UNDER SECTION 69B IS UPHELD. ON THE SA ME REASONING THE ACTION OF THE ASSESSING OFFICER IN ASSESSING EXCESS CASH UNDER SECTION 69A IS ALSO UPHELD. 8. THE ASSESSEE IS IN APPEAL AGAINST THE ORDER OF T HE COMMISSIONER OF INCOME TAX (APPEALS). 9. THE LD. AR FOR THE ASSESSEE POINTED OUT THAT THE RE WAS NO CHALLENGE TO THE ADDITION MADE U/S 69A AND 69B OF THE ACT AND ON LY ISSUE WHICH WAS ARISING IN THE PRESENT APPEAL WAS AGAINST THE REJEC TION OF CLAIM OF REMUNERATION TO PARTNERS U/S 40(B) OF THE ACT. HE POINTED OUT THAT THE ASSESSING OFFICER HAD MADE THE ADDITION AFTER THE D ECLARATION MADE BY THE ASSESSEE AGAINST WHICH THE ASSESSEE WAS NOT IN APPE AL. HOWEVER, SINCE THE SOURCE OF THE ADDITIONAL INCOME WAS THE BUSINESS IN COME, THE ASSESSEE WAS ENTITLED TO CLAIM THE DEDUCTION U/S 40(B) OF THE AC T. HE STRESSED THAT THE ISSUE STANDS COVERED BY THE ORDER THE TRIBUNAL IN ASSESSE ES OWN CASE IN ITA NO.1606/PN/2004 AND CONNECTED APPEALS RELATING TO ASSESSMENT YEARS 2000-01 & 2001-02, VIDE ORDER DATED 28/06/2007. 10. THE LD. DEPARTMENTAL REPRESENTATIVE FOR THE REV ENUE ON THE OTHER HAND WHILE PLACING RELIANCE ON THE ORDERS OF THE AS SESSING OFFICER AND COMMISSIONER OF INCOME TAX (APPEALS), ALSO PLACED R ELIANCE ON THE ORDER OF THE CHANDIGARH BENCH OF THE TRIBUNAL IN M/S. MAKSON DISTRIBUTORS VS. DCIT IN ITA NO.53/CHD/2011 RELATING TO ASSESSMENT YEAR 2006 -07, ORDER DATED 13/05/2011. 11. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE RECORDS. IN THE FACTS OF THE PRESENT CASE BEFORE US SEIZURE ACTION U/S 132A OF THE ACT WAS ITA NO.954/PUN/2014 FOR A.Y 2010-11 SHRI MAHAVEER ABHUSHANI BHANDAR 6 CARRIED OUT ON 29/10/2010 AFTER THE POLICE AUTHORIT Y INTERCEPTED A PASSENGER BUS IN WHICH TWO PERSONS WERE CARRYING CERTAIN ITEM S AND DOCUMENTS. ON INVESTIGATION AND VERIFICATION, THE SAID GOODS AND DOCUMENTS WERE FOUND TO BELONG TO THE ASSESSEE FIRM. CONSEQUENT THERETO PR OCEEDINGS U/S 153C OF THE ACT WERE INITIATED AGAINST THE ASSESSEE. SURVEY U/ S 133A OF THE ACT WAS ALSO CARRIED OUT AGAINST THE ASSESSEE AT HIS BUSINESS PR EMISES ON 03/02/2010 WHEREIN THE ASSESSEE HAD DECLARED ADDITIONAL INCOME ON ACCOUNT OF EXCESS STOCK AND EXCESS CASH, TOTALING RS.30,02,440/-. BO TH THE ASSESSING OFFICER AND COMMISSIONER OF INCOME TAX (APPEALS) HAD HELD T HAT THE SAID INCOME IS TO BE ADDED AS DEEMED INCOME U/S 69A AND 69B OF THE ACT. THE LD. AR FOR THE ASSESSEE AT THE OUTSET STATED THAT THERE WAS NO CHALLENGE TO THE AFORESAID ADDITION BEING MADE U/S 69A AND 69B OF THE ACT. TH E ASSESSEE HAD CLAIMED THE DEDUCTION U/S 40(B) OF THE ACT AT RS.24,72,783/ - BY TREATING THE ADDITIONAL INCOME AS BUSINESS INCOME. HOWEVER, THE SAME WAS R EDUCED TO RS.17,33,202/-. THE CASE OF THE ASSESSEE BEFORE US IS THAT SINCE IT HAD NO OTHER SOURCE OF INCOME BUT THE BUSINESS INCOME, THE N THE TOTAL INCOME WAS ITS BUSINESS INCOME, AGAINST WHICH IT HAD CORRECTLY CLA IMED THE DEDUCTION U/S 40(B) OF THE ACT. 12. THE LD. AR FOR THE ASSESSEE PLACED RELIANCE ON THE RATIO LAID DOWN IN ASSESSEES OWN CASE BEFORE THE TRIBUNAL IN ASSESSME NT YEAR 2000-01. THE ADDITIONAL INCOME DECLARED BY THE ASSESSEE WAS ASSE SSED AS INCOME FROM BUSINESS IN THE SAID YEAR AND WAS CONSIDERED FOR CA LCULATING THE BOOK PROFIT U/S 40(B) OF THE ACT. HOWEVER, FOR THE YEAR UNDER CONSIDERATION, THE ADDITIONAL INCOME OF RS.30,02,440/- WAS ADDED AS DEEMED INCOME U/S 69A AND 69B OF THE ACT. THE BUSINESS INCOME ON THE OTHER HAND WA S CALCULATED AFTER EXCLUDING THE SAID ADDITIONAL INCOME AND THE BOOK P ROFIT WAS RE-DETERMINED IN ITA NO.954/PUN/2014 FOR A.Y 2010-11 SHRI MAHAVEER ABHUSHANI BHANDAR 7 THE HANDS OF THE ASSESSEE AND THE REMUNERATION TO P ARTNERS WAS RESTRICTED TO 17,33,202/-. 13. WE FIND THAT SIMILAR ISSUE OF RESTRICTION OF TH E DEDUCTION U/S 40(B) OF THE ACT WHERE THE ADDITIONAL INCOME WAS ASSESSED AS DEE MED INCOME U/S 69A AND 69B OF THE ACT AROSE BEFORE THE TRIBUNAL IN M/S . MAKSON DISTRIBUTORS (SUPRA). THE TRIBUNAL VIDE PARA 7 HELD AS UNDER : 7. UNDER THE PROVISIONS OF INCOME TAX ACT, THE INT EREST AND SALARY PAID TO THE PARTNERS IS TO BE ALLOWED AS PER THE PROVISIONS OF SECTION 40(B) OF THE ACT WHICH IS IN CONNECTION WITH THE DETERMINATION OF BU SINESS INCOME. ONCE INCOME IN THE HANDS OF THE ASSESSEE HAS BEEN ASSESS ED AS DEEMED INCOME BY INVOKING THE PROVISIONS OF SECTION 69A, 69B & 69 C OF THE ACT AND IS NOT ASSESSED AS INCOME FROM BUSINESS UNDER INCOME TAX A CT, THE PROVISIONS OF SECTION 40(B) OF THE ACT IN CONNECTION WITH THE ALL OWANCE OF SALARY PAID TO THE PARTNERS CANNOT BE INVOKED TO ALLOW THE DEDUCTION O N ACCOUNT OF SUCH SALARY BEING PAID TO THE PARTNERS OF THE FIRM. THE ASSESS EE HAS RELIED UPON THE RATIO LAID DOWN BY THE CHANDIGARH BENCH OF THE TRIBUNAL I N BHANU MAL INDER LAL (SUPRA) WHEREIN VIDE ORDER DATED 22.10.2010, THE TR IBUNAL HAD DIRECTED THE ALLOWANCE OF SALARY IN RESPECT OF THE BUSINESS INCO ME ASSESSED IN THE HANDS OF THE ASSESSEE. THE SAID RATIO WAS LAID DOWN BY T HE TRIBUNAL IN THE FACTS OF THE CASE WHERE THERE WAS A SURVEY AND CERTAIN INCOM E WAS SURRENDERED, PART OF WHICH WAS ASSESSED AS BUSINESS INCOME IN THE HAN DS OF THE ASSESSEE AND PART AS ADDITIONAL INCOME OF THE ASSESSEE U/S 69A, 69B & 69C IN THE HANDS OF THE ASSESSEE. THE DIRECTION WAS GIVEN BY THE TRIBU NAL TO ALLOW THE SAID CLAIM OF SALARY PAID TO THE PARTNERS AGAINST THE BUSINESS INCOME EARNED BY THE ASSESSEE. IN THE FACTS OF THE CASE BEFORE US, THE SURRENDERED INCOME WAS ASSESSED AS ADDITIONAL INCOME U/S 69A, 69B & 69C OF THE ACT AND HENCE NO CLAIM OF SALARY PAID TO THE PARTNERS IS TO BE ALLOW ED AGAINST THE SAID INCOME. FURTHER, IN THE PRESENT CASE, ASSESSEE HAS FAILED T O CONTRAVENE THE OBSERVATIONS OF ASSESSING OFFICER AND CIT(A) IN RES PECT OF GENUINENESS OF THE AMENDMENT DEED, UNDER WHICH THE SALARY IS ALLEGED T O BE AID TO THE PARTNERS. UPHOLDING THE ORDER OF THE CIT (A), WE FIND NO MERI T IN THE CLAIM OF ASSESSEE AND HENCE THE SAME IS REJECTED. THE GROUND OF APPE AL NOS. 2 & 3 RAISED BY THE ASSESSEE ARE THUS DISMISSED. 8. IN THE RESULT, APPEAL OF THE ASSESSEE IS DISMISS ED. 14. THE ISSUE ARISING BEFORE US IS SQUARELY COVERED BY THE DECISION OF THE CHANDIGARH BENCH TRIBUNAL IN M/S. MAKSON DISTRIBUTO RS (SUPRA) WHERE THE INCOME IS ASSESSED IN THE HANDS OF THE ASSESSEE AS DEEMED INCOME UNDER THE PROVISIONS OF SECTION 69A AND 69B OF THE ACT AN D IS NOT ASSESSED AS BUSINESS INCOME, THEN THE REMUNERATION PAID TO THE PARTNERS IS TO BE CURTAILED ITA NO.954/PUN/2014 FOR A.Y 2010-11 SHRI MAHAVEER ABHUSHANI BHANDAR 8 IN RELATION TO THE BUSINESS INCOME ASSESSED IN THE HANDS OF THE ASSESSEE. ACCORDINGLY, WE UPHOLD THE ORDER OF THE COMMISSIONE R OF INCOME TAX (APPEALS) AND DISMISS THE GROUNDS OF APPEAL RAISED BY THE ASSESSEE. 15. THE GROUND OF APPEAL NO.5 RAISED BY THE ASSESSE E IS AGAINST CHARGING OF INTEREST U/S 234A, 234B AND 234C OF THE ACT, IS CONSEQUENTIAL, HENCE THE SAME IS DISMISSED. 16. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DI SMISSED. ORDER PRONOUNCED ON THIS 17 TH DAY OF MARCH, 2017. SD/- SD/- (R.K. PANDA) (SUSHMA CH OWLA) ' / ACCOUNTANT MEMBER / JUDICIAL MEMBER / PUNE ; DATED : 17 TH MARCH, 2017 . S S G G R R % & '()* +*( / COPY OF THE ORDER IS FORWARDED TO : THE APPELLANT; THE RESPONDENT; ! ! ' () THE CIT(A), KOLHAPUR; ! ! ' / THE CIT I, KOLHAPUR ; %&' (()*, ! )* , , / DR A, ITAT, PUNE; '-. / / GUARD FILE. %# / BY ORDER, % ( // TRUE COPY // 0 1 / ASSISTANT REGISTRAR, ! )* , / ITAT, PUNE