RAVI HALDIA,C/O HALDIA MULTIPOINT HOUSE V. DCIT, CIRCLE-1, JAIPUR, JAIPUR

MA 4/JPR/2025

AI Insights

The case revolves around a Miscellaneous Application filed by Shri Ravi Haldia against the order of the Income Tax Appellate Tribunal, which had previously decided on his appeals for the assessment years 2005-06 and 2007-08. The primary contention was regarding the addition of Rs. 36,41,232/- as unexplained expenditure under section 69C of the IT Act, 1961. The Tribunal had earlier applied an average rate of gross profit to the assessee's income, which the assessee argued should also apply to the disputed addition. The Tribunal, upon reviewing the submissions and the precedents cited, agreed with the assessee's position and allowed the application, thereby deleting the addition.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 774282 (ITAT-JAIPUR)
• Duration Of Justice: 8 month(s) 8 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 08-09-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: 2007-2008
• Appeal Filed On: 31-12-2024
• Other Referred Cases: Kachwala Gems Vs. JCIT, CIT Vs. Golcha Properties P. Itd., CIT Vs. La Medica, CIT Vs. Vaibhav Gems, Malpani House of Stones Vs. CIT
• Laws Referred To: Income Tax Act 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: DHARM SINGH MEENA
• Assessee Lawyers: DHEERAJ BORAD
• Keywords: Set aside; Unexplained expenditure; Unexplained investment; Rejection of books of accounts; Rectification of order; Loose papers
• Section: 154; 153A; 69C; 260A

Judgement Text

" vk;dj vihyh; vf/kdj.k] t;iqj U;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM MA No. 04/JP/2025 (Arising out of vk;dj vihy la- ITA No. 65/JP/2024) fu/kZkj.k o\"kZ@Assessment Year : 2007-08 Shri Ravi Haldia Haldia Multipoint House, 2nd Floor, Corner Thatheron Ki Gali, Choura Rasta, Jaipur cuke Vs. DCIT Circle-01, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AACPH 3653 A vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Dheeraj Borad, CA jktLo dh vksj ls@ Revenue by : Shri Dharm Singh Meena, JCIT a lquokbZ dh rkjh[k@ Date of Hearing : 12/08/2025 mn?kks\"k.kk dh rkjh[k@Date of Pronouncement : 08/09/2025 vkns'k@ ORDER PER: RATHOD KAMLESH JAYANTBHAI, AM By way of the Present Miscellaneous Application, the assessee challenges the finding of Co-ordinate Bench in ITA No. 65/JP/2024 praying therein the relevant mistake apparent on record while passing the common order in ITA No. 64 & 65/JP/2024, the relevant contents as advanced the miscellaneous application which reads as under:- Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 2 Sub: Application by the assessee Ravi Haldiau/s 254(2) of the I.T. Act 1961for A.Y. 2007-08 in relation to appellate order passed by the Hon’ble Income Tax Appellant Tribunal, Jaipur Benches, “B” Jaipur in ITA No. 65/JPR/2024 vide common order in ITA Nos. 64 & 65 /JPR/2024 for A.Y. 2005-06 and 2007-08 respectively. With reference to the above mentioned order in appellant’s case the humble appellant craves leave to submit as under:- 1. That the appellant assessee’s appeal bearing ITA No. 65/JPR/2024in Ravi Haldia v/s The DCIT, Circle-1, Jaipur has been decided by the Hon’ble Tribunal vide a common appellate order for A.Y. 2005-06 & 2007-08. 2. That, while concluding the above mentioned common order the Hon’ble Bench vide para no. 11 hasobserved as under: “11. The fact of the case in ITA No. 65-JP-2024 is similar to the case in ITA No. 64-JP-2024 and we have heard both the parties and persuaded the materials available on record. The bench has noticed that the issues raised by the assessee in this appeal No. 65/JP/2024 is equally similar on set of facts and grounds. Therefore, it is not imperative to repeat the facts and various grounds raised by both the parties. Hence, bench feels that the decision taken by us in ITA No. 64/JP/2024 for the Assessment Year 2005-06 sell apply mutatis mutandis in the case of Ravi Haldia in ITA No. 65-JP-2024 for the Assessment Year 2007-08. 3. That, from reading last but one sub-para of para no 10 above, para no 11 above and whole of the order it clearly comes out that the Hon’ble bench has upheld the application of average rate of gross profit against the 30% applied by the A.O. and sustained by CIT(A) for both the assessment years. 4. That the assessee craves leave to refer to part of the observation made by the Hon’ble bench in para 11 above, which reads as under:- “11. The fact of the case in ITA No. 65-JP-2024 is similar to the case in ITA No. 64-JP-2024 and we have heard both the parties and persuaded the materials available on record. The bench has noticed that the issues raised by the assessee in this appeal No. 65/JP/2024 is equally similar on set of facts and grounds.” Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 3 5. That in relation to observation made by the Hon’ble Bench that the facts in ITA No. 65/JP/2024 are quite similar to that of the case in ITA No. 64/JP/2024, the humble appellant craves leave to refer to and rely upon ground of appeal No. 1 mentioned in form No. 36 of appeal to the Hon’ble Tribunal bearing Appeal No. 65/JP/2024 which reads as under: “That the learned CIT (Appeal) erred in sustaining addition made by the A.O. of Rs. 36,41,232/- u/s. 69C of the IT Act to the total income of the assessee as unexplained expenditure by disallowing the expenditure in respect of alleged unverifiable/unexplained purchases of Rs. 36,41,232/- on the pretext that the Hon’ble Jurisdictional High Court has held so in the assesse’s case wide appellate order bearing ITA No. 208/2012 dated- 24/08/2017, which sustaining of addition of Rs. 36,41,232/- u/s. 69C of the IT Act, as unverifiable/unexplained purchases is most arbitrary, unjust and untenable in fact and in law and in the alternative excessive w.r.t. facts and circumstances of the case.” 6. Moreover in the written submissions filed by the appellant before the Hon’ble Bench, the appellant had made submissions in this regard under the head “Ground of Appeal No. 1” havingpara No. 1 to 32 running from page 1 to page 5 of written submissions and had also submitted various supporting documents forming part of paper book.The appellant craves leave to refer to and rely upon these written submissions and supporting documents submitted before the Hon’bleBench .Besides in the course of hearing before the Hon’ble Bench on the appointed day the assessee’s authorized representative had made oral submissions in support of above mentioned ground of appeal No. 1. 7. That, in view of above facts it is very humbly submitted that if the Honorable Bench pleases the above mentioned common order dated 15/04/2024 in regard to ITA no. 65/JPR/2024 for assessment years 2007-8 may kindly be amended/revised/rectified and relief prayed in the Ground of Appeal no.1 may be granted. The humble appellant will always remain grateful of the Hon’ble Bench for this act of kindness . 8. That, a treasury challan receipt of Rs. 50 towards fees for filing application u/s 254(2) of the IT Act is enclosed herewith. Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 4 2. The ld. AR of the assessee in furtherance to the contentions raised in miscellaneous application has also filed written submissions to support the contentions raised in this application which reads as under:- Sub: Filing of written submissions in regard to MA4/JPR/2025 arising out of ITA No. 65/JPR/2024 for A.Y. 2007-08 in relation to appellate order passed by the Hon'ble Income Tax Appellant Tribunal, Jaipur Benches, \"B\" Jaipur in ITA No. 65/JPR/2024 vide common order in ITA Nos. 64 & 65/JPR/2024 for A.Y. 2005-06 and 2007-08 respectively. With reference to above mentioned M.A. the humble appellant craves leave to furnish before the hon'ble bench following written submissions:- 1. That the Hon'ble bench was kind enough to pass a common order in the above case of Ravi Haldia v/s DCIT in regard to ITA No. 64/JP/2024 and ITA No. 65/JP/2024 for A.Y. 2005-06 and 2007-08 respectively after giving the reason of passing common order in para no. 2 of Tribunal's order, which para no. 2 read as under:, \"Since the issues involved in these appeals are almost identical on facts and are almost common, except the difference in figure disputed in each year, therefore, these appeals were heard together with the agreement of both the parties and are being disposed off by this common order. \" 2. That while concluding the above mentioned appellate order in ITA Nos. 64 & 65/JPR/2024 (copy enclosed), the hon'ble Bench observed in Para no. 11 as under \"the fact of the case in ITA No. 65-JP-2024 is similar to the case in ITA no. 64-JP-2024 and we have heard both the parties and persuaded the materials available on record. The Bench has noticed that the issues raised by the assessee in this appeal no. 65/JP/2024 is equally similar on set of facts and grounds. Therefore, it is not imperative to repeat the facts and various grounds raised by both the parties. Hence, the bench feels that the decision taken by us in ITA no. 64/JP/2024 for the assessment year 2005-06 shall apply mutatis-mutandis in the case of Ravi Haldia in ITA no. 65-JP-2024 for the assessment year 2007-08.\" Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 5 3. That though by reading the above mentioned order passed by the hon'ble bench it comes out that in both the appeals bearing ITA nos. 64 & 65/JPR/2024 for assessment years 2005-06 & 2007-08 respectively all the grounds of appeal taken by the assessee have been allowed by the hon'ble bench in favor of the assessee vide the above mentioned common order passed for both the years yet while giving effect to the above mentioned appellate order passed by the hon'ble Bench, the AO vide his order u/s 254 r.w.s 260 (Set Aside) r.w.s 153A of the IT Act dated 07/12/2024 (copy enclosed) allowed only a relief of Rs. 6,26,445/- by way of applying GP rate of 12.81% as against 30% applied by AO on sales declared of Rs. 36,44,240/- and did not allow relief to the assessee in regard to alleged unexplained investment in purchase of Rs. 36,41,232/-. In above circumstances it is humbly prayed that necessary directions for allowing relief in relation to ground of appeal no. 1 (copy of Form 36 enclosed) of AY 2007-08 in ITA 65/JPR/2024 may kindly be issued to the AO to give appeal effect in form of relief for all the grounds of appeal taken by the assessee for both the years. 3. On the other hand, ld. DR submitted that the assessee under grab of Miscellaneous Application trying to get review of the order already passed on the merits of the dispute. The ld. DR thereby supported the report of the AO placed on record vide submissions dated 28.02.2025 which reads as under:- Sub. Appellate proceedings in the case of Ravi Haldia, PAN:- AACPH3653A, MA4/JPR/2024 for the A.Y. 2007-08-reg- Please refer to your office letter no. 1234 dated 20.02.2025 on the subject cited above vide which comments was sought in the case of Ravi Haldia, PAN:- AACPH3653A, MA4/JPR/2024 for the A.Y. 2007- 08. 2. In this case, assessee filed income of Rs. 80,51,730/- for A.Y. 2007- 08. The AO passed order u/s 260A (set aside) r.w.s 153A of the I. T. Act, 1961 and assessed total income Rs. 1,24,37,840/-. Vide this order, Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 6 addition of Rs. 36,41,232/- was made on account of unexplained expenditure u/s 69C of the IT Act, 1961. 3. The assessee filed appeal before the Hon'ble ITAT Jaipur Bench on the following grounds:- \"1 That the learned CIT (Appeals) erred in sustaining the application of G.P. rate of 30 percent (as against declared G.P. rate of 11.36 percent) applied by the A.O. on the declared sales of Rs. 1,91,32,770/- on the pretext that the hon'ble Jurisdictional High Court has held so in assessee's own case vide appellate order bearing ITA number 214/2012 dated 24/8/2017 and thereby sustaining the trading addition of Rs. 35,66,906/- (G.P. determined Rs. 57,39,831/- minus G.P. declared Rs.21,72,925/-) made by the A.O., which sustaining of G.P. rate of 30 percent as against declared GP rate of 11.36 percent and consequential trading addition of Rs. 35,66,906/- are most arbitrary, unjust and untenable in fact and in law and in the alternative excessive w.r.t. facts and circumstance of the case. 2 That the appellant craves leave to add, alter, amend or substitute one or more grounds of appeal as and when necessary.\" 4. The Hon'ble ITAT, Jaipur passed order in ITA No 64 & 65/JPR on 15.04.2024 for A.Y. 2005-06 & 2007-08. Vide order dated 15.04.2025 The Hon'ble ITAT has directed to the AO estimate the profit @ 12.81% as against the 11.60% declared by the assessee. 5. The assessee has not filed appeal on the issue of addition of Rs. 36,41,232/- made on account of unexplained expenditure u/s 69C of the I T Act, 1961. Therefore, the Hon'ble ITAT has not given decision on the issue. The assessee has not taken ground of appeal before the Hon'ble ITAT regarding addition of Rs. 36,41,232/-. 4. The ld. DR also placed on record and another submission received by e-mail to the ld. DR which was forwarded vide covering letter dated 04.08.2025 which reads as under:- Kindly refer to your office letter no. 1494 dated 17.07.2025 on the subject cited above vide which comments was sought in the case of Ravi Haldia, PAN:- AACPH3653A, MA4/JPR/2024 for the Α.Υ. 2007- 08. Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 7 2. In this case, assessee filed ROI declaring income of Rs. 80,51,730/- for A.Y. 2007-08 in compliance to the notices u/s 153A r.ws. 153B of the IT Act. Assessment u/s 153A was passed on 24.12.2009 making addition of Rs. 36,41,232/. Being aggrieved with the assessment order, the assessee instituted an appeal before CIT(A). Vide order dated 18.11.2010, the CIT(A) partly allowed relief to assessee. 2.1 Being aggrieved with the order of CIT(A), the assessee as well as the department instituted an appeal before Hon'ble ITAT. The Hon'ble ITAT pronounced combined appellate order vide order dated 19.12.2011 allowing the appeal of the assessee. Being aggrieved with the appellate order, the department instituted appeal before Hon'ble High Court. In order dated 24.08.2017, the Hon'ble High Court set aside the case for fresh assessment. Accordingly, assessment u/s 260A (set aside) r.ws. 153A of the IT Act, 1961 was completed on 16.10.2018 making additions (1) Rs.36,41,232/- on account of unverifiable/unexplained purchase, (ii) Rs. 6,91,350/ on account of trading addition taking GP @ 30% in compare to 11.02% declared by the assessee, (iii) Rs. 38,029/- on account of unexplained investment and (iv) Rs. 15,500/- on account of disallowance of Expenses. 2.2 Being aggrieved with the said assessment order, the assessee instituted appeal before the id. CIT(A) challenging these additions. The CIT(A) vide order dated 30.11.2023 sustained the additions made by the AO. Being aggrieved with the order, the assessee instituted appeal before the Hon'ble ITAT, Jaipur. In the combined order for the A.Y. 2005-06 & 2007-08, the Hon'ble ITAT vide order dated 15.04.2024 pronounced that: - \"Since, in these the average rate of gross profit was directed to apply and the assessee has submitted the details of the gross profit of the last four year before the Id. CIT(A) by way of chart and said chart reads as under: The average of gross profit from the above chart comes to 12.81% and therefore, the same is directed to be applied as against the 30% applied by the lower authority which will end the justice on the issue. Based on these observations the appeal of the assessee is partly allowed. In terms of these observations, the appeal of the assessee in ITA no. 64/JP/2023 is partly allowed. 11. The fact of the case in ITA No. 65-JP-2024 is similar to the case in ITA No. 64-JP-2024 and we have heard both the parties and persuaded the Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 8 materials available on record. The bench has noticed that the issues raised by the assessee in this appeal No. 65/JP/2024 is equally similar on set of facts and grounds. Therefore, it is not imperative to repeat the facts and various grounds raised by both the parties. Hence, the bench feels that the decision taken by us in ITA No. 64/JP/2024 for the Assessment Year 2005-06 shall apply mutatis mutandis in the case of Ravi Haldia in ITA No. 65-JP-2024 for the Assessment Year 2007-08. In the result, both appeals of the assessee are partly allowed.\" 2.3 In compliance to the order dated 15.04.2024 of the Hon'ble ITAT, appeal effect was given allowing relief by applying G.P. rate of 12.81% as against 30% applied by AO on sales declared of Rs. 36,44,240/- 3. In connection to observation of the Hon'ble ITAT during the hearing on 16.07.2025 in respect of Para 5 of letter dated 28.02.2025 of this office, it is submitted that the letter was drafted on the basis of the order dated 15.04.2024 of the Hon'ble ITAT, wherein it is found that the assessee had filed appeal before the Hon'ble ITAT Jaipur Bench on the following grounds:- \"1 That the learned CIT (Appeals) erred in sustaining the application of G.P. rate of 30 percent (as against declared G.P. rate of 11.36 percent) applied by the A.O. on the declared sales of Rs. 1,91,32,770/- on the pretext that the hon'ble Jurisdictional High Court has held so in assessee's own case vide appellate order bearing ITA number 214/2012 dated 24/8/2017 and thereby sustaining the trading addition of Rs. 35,66,906/- (G.P. determined Rs. 57,39,831/- minus G.P. declared Rs.21,72,925/-) made by the A.0, which sustaining of G.P. rate of 30 percent as against declared GP rate of 11.36 percent and consequential trading addition of Rs. 35,66,906/- are most arbitrary, unjust and untenable in fact and in law and in the alternative excessive w.r.t. facts and circumstance of the case. 2 That the appellant craves leave to add, alter, amend or substitute one or more grounds of appeal as and when necessary.\" 4. Further, in regard to the observation of the Hon'ble ITAT for not giving appeal effect in respect of the amount of addition of Rs. 36,41,232/-, it is submitted that in compliance to the order dated 15.04.2024 of the Hon'ble ITAT, Jaipur in ITA No 64 & 65/JPR for A.Y. 2005-06 & 2007-08, it is understood that the Hon'ble ITAT has directed to the AO estimate the profit @ 12.81% as against the 11.60% declared by the assessee. No specific directions are available in the order of Hon'ble ITAT for considering addition u/s 69C of Rs. Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 9 36,41,232/- while calculating profit on sales. Accordingly, appeal effect was given vide order dated 07.12.2024. It is also submitted that the assessee has not filed any application u/s 154 for rectification of order u/s 254 r.ws. 153A dated 07.12.2024. As such, the assessee has not exhausted alternative remedy available with him. The Hon'ble bench may be apprised that the assessee has filed MA before Hon'ble bench without pointing out any defect/shortcoming in the order of Hon'ble bench. Therefore, it may be pleaded that MA may be rejected. The Hon'ble bench may also be apprised of provisions of section 253 of the IT Act, if deemed fit. 5. We have heard the rival contentions and perused the material placed on record. As is evident from the Miscellaneous Application that the assessee contended that while dealing with the appeal in ITA no. 65/JP/2025 the bench has not given any finding in respect of the ground no. 1 raised by the assessee regarding the addition of Rs. 36,41,232/- u/s. 69C of the Act. On this aspect of the matter the bench noted that the assessee’s book results were not considered and thereby the same was rejected by the ld. AO thereby observing as under ; Moreover, it is mentioned here that the books of accounts are incomplete and incorrect and trading results declared by the assessee are not relied upon. Neither the cash books of any concerns were complete on the date of search on 20.04.2007, as balance was not drawn at the end of the day nor purchases are fully vouched. During search, excess stock and cash have been found. Various entries in seized loose papers/documents/Diaries suggest that the assesses of this group are indulged in unaccounted purchases so much so that wages for processing of Gems stones claimed by the assesses are not supported by proper vouchers. As per seized Annexures AA-22, pages 16 to 22 are manual vouchers were prepared dully paid in cash without mentioning the month and year. It is also noticed that as held above the Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 10 purchases are unverifiable. It is also noticed that in AY 2005-06 the assessee had shown purchases from Registered Dealers, i.e. M/s Girish Diam Jaipur of Rs. 22,25,626/- and M/s Abhay International Jaipur of Rs. 22,95,357/- and in AY 2004-05 purchases of Rs. 25,07,258/- made from registered dealers namely M/s Jwels and Crafts, A. S. Exports, A. R. Exports, DJ Impex and Metro Gem House, but these dealers had been declared unverified/unexplained in the case of Shri Ravi Haldia and Dinesh Haldia in AY 2004-05 as per Hon'ble ITAT's Order dated 31.07.2008 in ITA No. 320-321/JP/2008. It is thus, held that the books of account are defective and the provisions of section 145(3) are clearly and admittedly applicable. In this regard following case laws are relied upon: - ➤ Kachwala Gems Vs. JCIT Tax World, Feb 2004 Pages 77 ITAT Jaipur and confirmed by Apex Court reported in 288 ITR 10 (SC) wherein it is held that: - A. Payment made by account payee cheques are not sufficient to establish genuineness of purchases. B. Registration under Sales tax Act does not give conclusion that purchases from such parties were genuine. ➤ CIT Vs. Golcha Properties P. Itd. 227 ITR 391 (Raj.) ➤ CIT Vs. La Medica 250 ITR 575 (Del.) ➤ CIT Vs. Vaibhav Gems Thus, once the books of accounts rejected no separate addition relying on the same set of books of accounts be made and thereby the addition so made for an amount of Rs. 36,41,232/- has no leg to sustained thereby the same is directed to be deleted as the income has already been estimated in this case. We get support of our view from the decision of our own High Court in the case of Malpani House of Stones Vs. CIT 395 ITR 386 (Raj) wherein Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 11 Hon’ble High Court held that ; 9. We have heard counsel for the appellant and the counsel for the respondent. 10. In view of the well settled principle of law that when income is estimated and while assessing the same and rejecting the books of accounts, it would not be appropriate to rely on the books of accounts for any addition other than estimate made by A.O. 11. In that view of the matter, the contention raised by the appellant deserves to be accepted. The income which has been added on the basis of books of accounts having been rejected and in that view of the matter, addition of Rs.13,740/-requires to be deleted. 12. The appeal is allowed. The question is answered in favour of the assessee and against the Department. Respectfully, following that finding of our High Court ground no. 1 in ITA No. 65/JP/2024 stands allowed as we have while ground no. 2 sustained the GP addition as per the detailed finding already given. In the result, Miscellaneous Application filed by the assessee is allowed as indicated hereinabove. Order pronounced in the open Court on 08/09/2025 Sd/- Sd/- ¼ Mk0 ,l- lhrky{eh ½ ¼ jkBksM deys'k t;UrHkkbZ ½ (Dr. S. Seethalakshmi) (Rathod Kamlesh Jayantbhai) U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member Tk;iqj@Jaipur fnukad@Dated:- 08/09/2025 *Ganesh Kumar, Sr. PS vkns'k dh izfrfyfi vxzsf’kr@Copy of the order forwarded to: 1. The Appellant- Shri Ravi Haldia, Jaipur 2. izR;FkhZ@ The Respondent- DCIT, Circle-01, Jaipur Printed from counselvise.com MA No. 04/JP/2025 Ravi Haldia vs. DCIT 12 3. vk;dj vk;qDr@ The ld CIT 4. vk;dj vk;qDr¼vihy½@The ld CIT(A) 5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur 6. xkMZ QkbZy@ Guard File (MA No. 04/JP/2025) vkns'kkuqlkj@ By order lgk;d iathdkj@Asst. Registrar Printed from counselvise.com "