SHRI MERH KSHTRIYA SABHA, AJMER V. INCOME TAX OFFICER (EXEMPTION), AJMER

MA 68/JPR/2020

• Counselvise Citation: [2021] 108 COUNSELVISE.COM (IT) 4462 (ITAT-JAIPUR)
• Duration Of Justice: 6 month(s) 10 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 30-04-2021
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: SMC
• Assessment Year: 2016-2017
• Appeal Filed On: 20-10-2020
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Charitable institution; Set aside
• Section: 10; 254(2)

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENC HES A JAIPUR JH LAANHI XKSLKBZ] U;KF;D LNL; ,OA JH FOE FLAG ;KNO] YS[KK LNL; DS LE{K BEFORE: SHRI SANDEEP GOSAIN, JM & SHRI VIKRAM SING H YADAV, AM M.A. NO. 68/JP/2020 (ARISING OUT OF ITA NO. 587/JP/2019) FU/KZKJ.K O'K Z@ ASSESSMENT YEARS : 2016-17 SHRI MERH KSHTRIYA SABHA, PATTI KATLA, NAYA BAZAR, AJMER CUKE VS. INCOME TAX OFFICER (EXEMPTION), AJMER LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN/GIR NO.: AAFTS9079J VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ L S@ ASSESSEE BY : SH. SUNIL PORWAL (CA) JKTLO DH VKSJ LS @ REVENUE BY : SH. A. S. NEHRA (ADDL.CIT) LQUOKBZ DH RKJH[ K@ DATE OF HEARING : 16/04/2021 MN?KKS'K.KK DH RKJH[ K@ DATE OF PRONOUNCEMENT: 30/04/2021 VKNS'K@ ORDER PER: VIKRAM SINGH YADAV, A.M. THE PRESENT MISCELLANEOUS APPLICATION HAS BEEN FILE D BY THE ASSESSEE AGAINST THE ORDER PASSED BY THE CO-ORDINAT E BENCH IN ITA NO. 587/JP/2019 DATED 22/09/2020. 2. DURING THE COURSE OF HEARING, THE LD AR DRAWN OU R REFERENCE TO THE FINDINGS OF THE TRIBUNAL AND SUBMITTED THAT THE ASS ESSEE IS DULY REGISTERED AS CHARITABLE AND RELIGIOUS TRUST UNDER SECTION 12A(A) AND THUS, THE PROVISIONS OF SECTION 115BBC HAVE BEEN WR ONGLY INVOKED BY THE AO AND THE TRIBUNAL INSTEAD OF DECIDING THE MATTER HAS SET-ASIDE THE MATTER TO THE FILE OF THE LD CIT(A). IT WAS ACCORD INGLY SUBMITTED THAT THE M.A. NO. 68/JP/2020 SH. MERH KSHTRIYA SABHA, AJMER VS. ITO (EXEMPTI ON), AJMER 2 MATTER MAY BE RECALLED AND DECIDED AFRESH BY THE TR IBUNAL. FURTHER, THE LD AR HAS RELIED ON THE MISC. APPLICATION SO FILED BY THE ASSESSEE AND THE CONTENTS THEREOF READ AS UNDER:- THAT VIDE GROUND NO. 2 OF SAID APPEAL IT WAS REQUE STED TO DECIDE THE ISSUE OF VOLUNTARY CONTRIBUTION RECEIVED (SAHYOG RA SHI) OF RS. 31,69,001/- CONSIDERED AS ANONYMOUS DONATION U/SEC. 115 BBC OF INCOME TAX ACT, 1961. INSPITE THIS AMOUNT CONSIDERE D AS 'INCOME' FOR THE YEAR AS PER RETURN FILED AND IN VIEW OF PROVISI ON OF SECTION 115BBC OF ACT. PRAYER THE GROUND NO. 2 HAS BEEN SET ASIDE TO L D. CIT(A) BY BENCH ON THE PRETEXT THAT THEREFORE, WE FIND THAT THESE DETAILS SO SUBMITTED BY THE ASSESSEE NEEDS TO BE FULLY EXAMINED AND BASIS S UCH EXAMINATION, A FINDING SHOULD BE CLEARLY RECORDED AS TO WHETHER AN D TO WHAT EXTENT, THE DONATION SO RECEIVED QUALITY AS ANONYMOUS DONATION OR NOT FURTHER SECTION 115BBC ANONYMOUS DONATION & TO BE T AXED IN CERTAIN CASES DEFINES:- 1) WHERE THE TOTAL-INCOME OF AN ASSESSEE, BEING A P ERSON IN RECEIPT OF INCOME ON BEHALF OF ANY UNIVERSITY OR O THER EDUCATIONAL INSTITUTION REFERRED TO IN SUB-CLAUSE (IIIAD) OR SU B-CLAUSE (VI) OR ANY HOSPITAL OR OTHER INSTITUTION REFERRED TO IN SUB-CL AUSE (IIIAE) OR SUB- CLAUSE (VIA) OR ANY FUND OR INSTITUTION REFERRED TO IN SUB-CLAUSE (IV) OR ANY TRUST OR INSTITUTION REFERRED TO IN SUB-CLAUSE (V) OF CLAUSE (23C) OF SECTION 10 OR ANY TRUST OR INSTITUTION REFERRED TO IN SECTION 11, INCLUDES ANY INCOME BY WAY OF ANY ANONYMOUS DONATION, THE IN COME-TAX PAYABLE SHALL BE THE AGGREGATE OF M.A. NO. 68/JP/2020 SH. MERH KSHTRIYA SABHA, AJMER VS. ITO (EXEMPTI ON), AJMER 3 (I) THE AMOUNT OF INCOME-TAX CALCULATED AT THE RATE OF THIRTY PER CENT ON THE AGGREGATE OF ANONYMOUS DONATIONS RECEIVED IN EXCESS OF THE HIGHER OF THE FOLLOWING, NAMELY: (A) FIVE PER CENT OF THE TOTAL DONATIONS RECEIVED BY THE ASSESSEE; OR (B) ONE LAKH RUPEES, AND (II) THE AMOUNT OF INCOME-TAX WITH WHICH THE ASSES SEE WOULD HAVE BEEN CHARGEABLE HAD HIS TOTAL INCOME BEEN REDUCED B Y THE AGGREGATE OF ANONYMOUS DONATIONS RECEIVED IN EXCESS OF THE AMOUNT REFERRED TO IN SUB-CLAUSE (A) OR SUB-CLAUSE (B) OF CLAUSE (I), AS THE CASE MAY BE. 2) THE PROVISIONS OF SUB-SECTION (1) SHALL NOT APPL Y TO ANY ANONYMOUS DONATION RECEIVED BY- (A) ANY TRUST OR INSTITUTION CREATED OR ESTABLISHED WHOLLY FOR RELIGIOUS PURPOSES; (B) ANY TRUST OR INSTITUTION CREATED OR ESTABLISHED WHOLLY FOR RELIGIOUS AND CHARITABLE PURPOSES OTHER THAN ANY ANONYMOUS DO NATION MADE WITH A SPECIFIC DIRECTION THAT SUCH DONATION IS FO R ANY UNIVERSITY OR OTHER EDUCATIONAL INSTITUTION OR ANY HOSPITAL OR OT HER MEDICAL INSTITUTION RUN BY SUCH TRUST OR INSTITUTION.' THUS FROM ABOVE; IT IS CLEAR THAT VIDE SECTION 115B BC(2) IT IS SETTLED THAT SUCH THE PROVISIONS OF SUB SECTION (1) SHALL NOT AP PLY TO TRUST OR INSTITUTIONS CREDITED OR ESTABLISHED WHOLLY FOR CHA RITABLE OR RELIGIOUS PURPOSES; SINCE THE ASSESSEE HAS BEEN GRANTED REGISTRATION U/ SEC. 12A(A) / 80(G) OF ACT, THERE IS NO DOUBT THAT TRUST IS NOT A 'CHARITA BLE AND RELIGIOUS TRUST', M.A. NO. 68/JP/2020 SH. MERH KSHTRIYA SABHA, AJMER VS. ITO (EXEMPTI ON), AJMER 4 THE SAID REGISTRATION IS STILL IN FORCE AS ON DATE; NOR A.O. HAS DOUBTED FOR SAME. FURTHER IN FOLLOWING DECIDED CASES IT HAS BEEN HELD THAT (A) M/S SARASWATI EDUCATIONAL V/S DEPARTMENT OF INC OME TAX (ITAT LUCKNOW BENCH ORDER DATED 17.06.2015) APPEAL NO. 77 6/LKW/2014 A. Y. 2010-11 (B) CIT V/S UTTARANCHAL WELFARE SOCIETY (2014), 42 TAXMAN.COM 361. (C) DELHI COURT IN CASE OF DIRECTOR OF INCOME TAX ( EXEM.) V.S KESHAV SOCIAL 278 ITR 152 (DELHI). (D) DIRECTOR OF INCOME TAX V/S HANSRAJ SAMARAK SOCI ETY (2013) 35 TAXMAN.COM 642 (DELHI) IT HAS BEEN HELD THAT ONCE THE ASSESSEE TRUST HAS TAK EN ENTIRE RECEIPT OF DONATION TO IT'S INCOME AND SAME WAS APPLIED FOR CH ARITABLE PURPOSES NO ADDITION U/SEC. 68/115BBE CAN BE MADE. BESIDES INDIVIDUAL DONORS DETAILS. IDENTITY ALSO FI LED TO A.O JUSTIFY THE FUNDS SO RECEIVED. CBDT CIRCULAR NO. 14/2006 DATED 28.12.2006 FURTHER MADE THE FACTS CLEAR OF TAXABILITY OF SUCH DONATION (AMOUNT RECEIVED). THUS WHEN THE LAW IS VERY CLEAR ON THE PROVISION OF APPLICABILITY OF SECTION 115BBC SPECIFICALLY IN VIEW OF CBDT CIRCULA R NO. 14/2006 DATED 28/12/2006 AND NO WHERE THE TRUST HAS BEEN HE LD OTHER THAN A CHARITABLE AND RELIGIOUS TRUST THE PROVISION OF S ECTION 115BBC CANNOT BE APPLIED IS A FACT OF FINDING APPLIED AND THUS IT IS REQUESTED TO DECIDE THE ISSUE THAN TO SET ASIDE TO CIT(A), AJ MER. 3. THE LD DR IS HEARD WHO HAS SUBMITTED THAT THERE IS NO MISTAKE IN THE ORDER SO PASSED BY THE TRIBUNAL. IT WAS SUB MITTED THAT THE M.A. NO. 68/JP/2020 SH. MERH KSHTRIYA SABHA, AJMER VS. ITO (EXEMPTI ON), AJMER 5 TRIBUNAL HAS RIGHTLY SET-ASIDE THE MATTER TO THE FI LE OF THE LD CIT(A) TO EXAMINE THE DETAILS/INFORMATION SUBMITTED BY THE ASSESSEE AND TO WHAT EXTENT, THE DONATIONS QUALIFY AS ANONYMOUS DON ATIONS AND THERE IS THUS NO INFIRMITY IN THE SAID FINDINGS OF THE TRIBUNAL AS THERE WAS NO FINDINGS OF EITHER THE AO OR THE LD CIT(A) R EGARDING SUCH DETAILS/INFORMATION AND IN ABSENCE OF SUCH FINDINGS , THE TRIBUNAL CANNOT BE EXPECTED TO STEP INTO THE SHOES OF THE AO AND EXAMINE THE DETAILS AND RECORD ITS FINDING ON FACTS FOR THE FIRST TIME. IT WAS SUBMITTED THAT IN ANY CASE, ONCE A DECISION HAS BEE N TAKEN BY THE TRIBUNAL TO SET-ASIDE THE MATTER TO THE LOWER AUTHO RITIES, SUCH A DECISION CANNOT BE SUBJECT MATTER OF RECTIFICATION WITHIN THE PROVISIONS OF SECTION 254(2) WHICH CAN BE INVOKED F OR THE LIMITED PURPOSES OF RECTIFICATION OF ANY MISTAKE WHICH IS A PPARENT ON RECORD. 4. REGARDING THE CONTENTION OF THE AR THAT THE ASSE SSEE HAS BEEN GRANTED REGISTRATION UNDER SECTION 12A(A)/80(G) OF THE ACT AND IS THUS A CHARITABLE AND RELIGIOUS TRUST AND PROVISION S OF SECTION 115BBC ARE NOT APPLICABLE, THE LD DR DRAWN OUR REFE RENCE TO CLAUSE (B) OF SUB-SECTION (2) OF SECTION 115BBC AND IT WAS SUBMITTED THAT MERELY REGISTRATION UNDER SECTION 12A(A) IS NOT SUF FICIENT FOR THE ASSESSEE TO CLAIM IMMUNITY FROM PROVISIONS OF SECTI ON 115BBC AND WHAT IS REQUIRED TO BE EXAMINED IS WHETHER THE COND ITIONS SO SPECIFIED THEREIN ARE FULFILLED IN TERMS OF WHETHER TRUST IS ESTABLISHED WHOLLY FOR RELIGIOUS AND CHARITABLE PURPOSES AND WH AT ARE THE OBJECTS AND ACTIVITIES OF SUCH TRUST AND SECONDLY, EVEN WHE RE THE TRUST IS ESTABLISHED WHOLLY FOR RELIGIOUS AND CHARITABLE PUR POSES, WHETHER ANY ANONYMOUS DONATION ARE MADE WITH A SPECIFIC DIRECT ION THAT SUCH DONATION IS FOR ANY UNIVERSITY OR OTHER EDUCATIONAL INSTITUTION OR ANY HOSPITAL OR OTHER MEDICAL INSTITUTION RUN BY SUCH TRUST AND IN THE M.A. NO. 68/JP/2020 SH. MERH KSHTRIYA SABHA, AJMER VS. ITO (EXEMPTI ON), AJMER 6 LATTER CASE, THE IMMUNITY FROM PROVISIONS OF SECTIO N 155BBC IS NOT AVAILABLE. IT WAS FURTHER SUBMITTED THAT DURING TH E APPELLATE PROCEEDINGS, THE DR HAS SPECIFICALLY BROUGHT THIS F ACT TO THE NOTICE OF THE BENCH AND OUR REFERENCE WAS DRAWN TO PARA 5 OF THE TRIBUNAL ORDER WHERE THE BENCH HAS NOTED THE CONTENTIONS OF THE DR AS UNDER: IT WAS FURTHER SUBMITTED THAT ONE OF THE OBJECTS OF THE ASSESSEES TRUST BEING SETTING UP OF EDUCATIONAL IN STITUTIONS AND CARRYING OUT ACTIVITIES IN THE FIELD OF EDUCATI ON AND WHICH WAS CONSIDERED WHILE GRANTING THE APPROVAL UNDER SE CTION 12A(A) OF THE ACT, MERELY BECAUSE THE ASSESSEE HAS NOT SET UP ANY EDUCATIONAL INSTITUTION OR HAS NOT CARRY ON ANY ACTIVITIES IN THE EDUCATIONAL SPHERE DOESNT MEAN THAT THE ASSESS EE TRUST IS NOT SETUP FOR EDUCATIONAL PURPOSES AND THEREFORE, T HE PROVISIONS OF SECTION 1115BBC ARE CLEARLY APPLICABL E AS THE ASSESSEE HAS FAILED TO SUBMIT THE IDENTITY AND OTHE R REQUISITE DETAILS ABOUT THE DONORS FROM WHOM THE DONATION HAS BEEN RECEIVED DURING THE YEAR. 5. IT WAS FURTHER SUBMITTED BY THE LD DR THAT SINCE THERE WAS NO FINDINGS OF EITHER THE AO OR THE LD CIT(A) REGARDIN G SATISFACTION OF THE CONDITIONS SO SPECIFIED IN SECTION 115BBC(2)(B) , THE TRIBUNAL HAS SET-ASIDE THE SAME TO BE EXAMINED BY THE LD CIT(A) AFTER PROVIDING REASONABLE OPPORTUNITY TO THE ASSESSEE. IT WAS ACC ORDINGLY SUBMITTED THAT THERE IS NO BASIS TO INTERFERE IN TH E FINDINGS OF THE TRIBUNAL AND THE MISC. APPLICATION SO FILED BY THE ASSESSEE MAY BE DISMISSED. M.A. NO. 68/JP/2020 SH. MERH KSHTRIYA SABHA, AJMER VS. ITO (EXEMPTI ON), AJMER 7 6. WE NOW REFER TO THE ORDER OF THE TRIBUNAL IN I TA NO. 587/JP/2019 DATED 22.09.2020 AND THE OPERATIVE PART AND FINDINGS OF THE TRIBUNAL READ AS UNDER: 6. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. THE LIMITED ISSUE UND ER CONSIDERATION IS THE TAXABILITY OF AN AMOUNT OF RS. 31,69,001/- R ECEIVED BY THE ASSESSEE WHICH HAS BEEN TREATED AS ANONYMOUS DONATI ONS BY THE ASSESSING OFFICER BY INVOKING THE PROVISIONS OF SEC TION 115BBC IN ABSENCE OF REQUISITE DETAILS OF THE DONORS WHICH HA VE CONTRIBUTED THE SAID AMOUNT TO THE ASSESSEE TRUST. THE LD. AR H AS SUBMITTED THAT THE DETAILS WERE DULY SUBMITTED BEFORE THE ASS ESSING OFFICER AND WHICH HAS BEEN CONFIRMED BY THE ASSESSING OFFIC ER SUBSEQUENTLY, VIDE LETTER NO. 519 DATED 21.01.2019. ON PERUSAL OF THE SAID LETTER, WE FIND THAT IT IS A LETTER WRITTE N BY THE ITO(EXEMPTION), AJMER TO THE TREASURER OF THE ASSES SEE TRUST WHICH HE HAS ENCLOSED A COPY OF THE LEDGER ACCOUNT FOR THE PERIOD 1 ST APRIL 2015 TO 31 ST MARCH, 2016 CONTAINING ENTRIES RELATING TO INDIVIDUAL DONORS. TO WHAT EXTENT, THE LEDGER CONT AINS THE IDENTITY OF THE DONORS IN TERMS OF NAME AND ADDRESS AND OTHE R REQUISITE PARTICULARS AS PRESCRIBED AS SO SOUGHT BY THE AO IS NOT CLEAR BUT IT IS A MATTER OF RECORD THAT THE SAID LEDGER WAS PROD UCED BEFORE THE ASSESSING OFFICER AND IS PART OF THE ASSESSMENT REC ORDS AND THEREFORE, DOESNT QUALIFY AS AN ADDITIONAL EVIDENC E. THEREFORE, WE FIND THAT THESE DETAILS SO SUBMITTED BY THE ASSESSE E NEEDS TO BE DULY EXAMINED AND BASIS SUCH EXAMINATION, A FINDING SHOULD BE CLEARLY RECORDED AS TO WHETHER AND TO WHAT EXTENT, THE DONATIONS SO RECEIVED QUALIFY AS ANONYMOUS DONATIONS OR NOT. THEREFORE, IN THE FACTS AND CIRCUMSTANCES OF THE PRESENT CASE, WE SET ASIDE THE M.A. NO. 68/JP/2020 SH. MERH KSHTRIYA SABHA, AJMER VS. ITO (EXEMPTI ON), AJMER 8 MATTER TO THE FILE OF LD. CIT(A) TO CONSIDER THE DE TAILS SO SUBMITTED BY THE ASSESSEE AND DECIDE THE MATTER AFRESH ON MER ITS AS PER LAW INCLUDING THE CONTENTION OF THE ASSESSEE REGARDING APPLICABILITY OF SECTION 115BBC AFTER PROVIDING REASONABLE OPPORTUNI TY TO THE ASSESSEE. GROUND NO. 2 AND 3 ARE DISPOSED OFF ACCO RDINGLY. 7. AFTER HEARING THE CONTENTIONS ADVANCED BY BOTH THE PARTIES AND CAREFULLY EXAMINING THE ORDER AND FINDINGS OF THE T RIBUNAL, WE ARE OF THE CONSIDERED VIEW THAT THERE IS NO MERIT IN PRESENT M ISC. APPLICATION FILED BY THE ASSESSEE. THE TRIBUNAL AFTER TAKING INTO CO NSIDERATION ALL RELEVANT FACTS AND MATERIAL ON RECORD AS WELL AS SUBMISSIONS /CONTENTIONS ADVANCED BY BOTH THE PARTIES HAS REMANDED THE MATTE R BACK TO THE FILE OF THE LD CIT(A) TO EXAMINE THE DETAILS SO SUBMITTED B Y THE ASSESSEE IN RELATION TO DONATION TO DETERMINE WHETHER THE SAME QUALIFY AS ANONYMOUS DONATIONS OR NOT AND SECONDLY, THE APPLIC ABILITY OF PROVISIONS OF SECTION 115BBC AS PER LAW WHICH APPARENTLY INCLU DE EXAMINATION OF PROVISIONS OF SECTION 115BBC(2) AND THE IMMUNITY SO PROVIDED THEREIN ON SATISFACTION OF CONDITIONS SPECIFIED THEREIN. IN OU R VIEW, BOTH THE ISSUES ARE INTER-CONNECTED IN TERMS OF WHETHER THE DONATIO NS SO RECEIVED ARE ANONYMOUS DONATIONS OR NOT AND SECONDLY, WHETHE R THE DONATIONS ARE MADE WITH A SPECIFIC DIRECTION BY THE DONORS T HAT SUCH DONATION IS FOR ANY UNIVERSITY OR OTHER EDUCATIONAL INSTITUT ION OR ANY HOSPITAL OR OTHER MEDICAL INSTITUTION RUN BY SUCH TRUST. IN O UR CONSIDERED VIEW, WHERE THERE ARE NO FINDINGS RECORDED BY THE LOWER A UTHORITIES IN THIS REGARD AND THE MATTER HAS BEEN SET-ASIDE BY THE TRI BUNAL TO THE FILE OF THE LD CIT(A) TO EXAMINE THE SAME AND RECORD HIS FI NDINGS AFTER DUE EXAMINATION AND AS PER LAW, THE DECISION SO TAKEN B Y THE TRIBUNAL IS CLEARLY BASED ON APPRECIATION AND DULY CONSIDERATIO N OF ALL RELEVANT FACTS AND CIRCUMSTANCES OF THE CASE AND CANNOT BE SUBJECT MATTER OF M.A. NO. 68/JP/2020 SH. MERH KSHTRIYA SABHA, AJMER VS. ITO (EXEMPTI ON), AJMER 9 RECTIFICATION WITHIN THE LIMITED SCOPE OF SECTION 2 54(2) AS THE SAME WOULD EFFECTIVELY AMOUNT TO REVIEW OF ITS OWN DECISION WH ICH IS CLEARLY OUTSIDE THE PURVIEW AND HAS INFACT NOW BEEN ENVISAGED AND I NTENDED WHILE INTRODUCING THE SAID PROVISIONS IN THE STATUTE. IN THE RESULT, MISCELLANEOUS APPLICATION SO FILED B Y THE ASSESSEE IS DISMISSED IN LIGHT OF AFORESAID DISCUSSIONS. ORDER PRONOUNCED IN THE OPEN COURT ON 30/04/2021. SD/- SD/- LANHI XKSLKBZ FOE FLAG ;KNO ( SANDEEP GOSAIN ) (VIKRAM SINGH YADAV) U;KF;D LNL;@ JUDICIAL MEMBER YS[KK LNL;@ ACCOUNTANT MEMBER TK;IQJ@ JAIPUR FNUKAD@ DATED:- 30/04/2021. * GANESH KR. VKNS'K DH IZFRFYFI VXZSFKR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- SH. MERH KSHTRIYA SABHA, AJMER 2. IZR;FKHZ@ THE RESPONDENT- ITO (EXEMPTION), AJMER 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 {M.A NO. 68/JP/2020} VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASST. REGISTRAR