INDIAN SULPHACID INDUSTRIES LIMITED,NEW DELHI vs. PR.CIT, KARNAL

आदेश/Order

PerAnnapurna Gupta, AM:

The present appeal has been filed by the assessee against the order dated 12.3.2020 passed by the Ld. Principal Commissioner of Income Tax, Karnal (in short ‘the PCIT) in exercise of his revisionary powers u/s 263 of the Income Tax Act, 1961 (in short 'the Act').

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 2 of Long Term Capital Gains and huge business losses, there were

several errors and discrepancies which showed that the Assessing

Officer had accepted the claim of the assessee without making any

proper enquiries and without application of mind at all. Accordingly,

the Ld. PCIT assumed powers u/s 263 for revising the order of the

Assessing Officer and issued notice to the assessee specifically

pointing the errors noted by him vis-a-vis the above claims of the

assessee of Long Term Capital Gains and brought forward business

losses.The notice is reproduced at pages 2 to 5 of the order of the

PCIT.

In response to the same, the assessee contended that the

Assessing Officer had examined the issues during the assessment

proceedings and the assessee had filed the details and evidences with

regard to the same and that the Assessing Officer having been

satisfied with the same, had therefore accepted the claim of the

assessee. The assessee further replied to each and every specific

discrepancy/error pointed out by the Ld. PCIT and

contended,therefore, that there was no error in the order of the

Assessing Officer. The Ld. PCIT rejected the contention of the

assessee and held that the Assessing Officer had accepted the

assesseee’s claim without making any verification with respect to the

various expenses claimed against the capital gains and against its

business income and since the same needed verification, the order

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 3 passed by the Assessing Officer was, therefore, erroneous.

Accordingly he set aside the order passed by the AO with the

direction to make assessment afresh after considering the issues

raised .

before us.

the findings of the Ld. PCIT of lack of enquiry by the Assessing

Officer, for holding the assessment order erroneous. Ld.Counsel for

the assessee reiterated the contention made before the Ld. PCIT that

due enquires were made during the assessment proceedings and that

all the details and evidences were filed by the assessee to the

satisfaction of the Assessing Officer. In this regard, our attention

was drawn to the submissions dated 17.8.2017 filed before the

Assessing Officer during the assessment proceedings, placed before

us at paper book pages 38 to 40 alongwith all evidences filed which

were placed at pages 41 to 266.

to the specific anomaly and discrepancy noted by the Ld. PCIT which

were confronted to the assessee vide show cause notice issued u/s

263 dated 4.2.2020 as under:-

“Accordingly, a show cause notice u/s 263 of the Act was issued to the assessee on 04-2.2020 as follows:-

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 4

"2. A perusal of the assessment record reveals that the assessee had shown capital gain of Rs.2,22,47,840/- in its computation of income. In the computation statement of Capital Gain, the assessee had claimed deduction on account of 'Other Expenses' of Rs.27 80,000/-, in respect of sale of property located at Shahdara, Delhi. In support of the given "other expenses", the assessee submitted to the AO, the copy of commission expenses and brokerage expenses as per the following details :-

ii) Further, there are 2 bills of commission, one from Rajeev Insulation Products of Rs.8 Lacs and another of Rs.5.90 Lacs. The latter one is an unsigned bill. The name of the so-called commission agent has been smudged at the top of the bill. Despite the effort to smudge the name, if is evident that the said bill has also been procured from the same "Mayank Gupta", from whom the bill of repair expenses mentioned above was procured. The A.O. did not care to conduct any enquiry about the genuineness of the assessee's claim of the given expenses.

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 5

The A.O. just didn't try to find out as to how Mayank Gupta had issued bill for Commission Expenses, as well as for repair of Building, and that too for a vacant land. The smudging of the name at the top of the bill seems intentional with the clear purpose to avoid detection of bogus claim. Further, the bill is also unsigned which escalates the suspicion regarding the given expenses. In spite of such glaring discrepancies, the A.O. had passively accepted the version of the assessee despite the fact that one of the reasons for selection of case for scrutiny was 'Verification of Capital

iii) Similarly, no enquiries were conducted by the A.O. to ascertain the genuineness of the third bill, i.e. bill of commission of Rs.8 lacs from Rajeev insulation Products. It was incumbent upon the A.O. to ascertain the identity of the party concerned, and the genuineness of the transaction. The services rendered by Rajeev Insulation Products so as to make it eligible for receipt of commission in connection with the given property transaction also needed to be looked into by the A.O. Also, the A.O. did not raise any query for paying commission to two different parties for the same property.

3.1 From the P&L account of the assessee, it is seen that the assessee had returned revenue from certain Service Charges at Rs. 18,47,557/-, and also some other income of Rs.29,66,854/-. Against a total revenue earned of Rs.48,14,391/-, the assessee had claimed loss of Rs.2,23,94,470/-. The sheer volume of expenses claimed at Rs.3.28 Cr. against a revenue generation of Rs.48.14 Lacs should have prompted the AO to make enquiries about the reasonableness or genuineness of the expenses claimed. As far as the expenses are concerned, some glaring facts are noticed which have been ignored by the A.O.:-

a) There are expenses of Repair & Maintenance of Rs.10,35,079/- for which certain bills have been submitted. Out

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 6 of these, there are 2 bills of MRU, Builders & Contractors of Rs.54,000/- and Rs.l,59,000/- dated 04.02.2013 and 20.04.2013 respectively. These bills clearly pertain to preceding year. The A.O. did not bother to check the justification for claiming the said expenses of preceding year.

b) There is another bill related to Repair & Maintenance Head, shown as "Repair to Shahbad building" and debited as Advance to Sagar Steel Traders at Rs.67,930/-. It is noted that the factory at Shahbad is lying closed. Therefore, the reason behind undertaking repair of a closed factory needed to be enquired. Even for arguments' sake, it is accepted that repair was undertaken, if is not understandable as to how only one bill of steel could complete the repair process.

c) Survey Expenses have been claimed at Rs.60,000/-. No query was raised by the A.O. to examine the nature and business relevance of the said expenses. Only internal vouchers of the company are available on record, it is not at all clear as to how the said expenses are incidental to the business and how the A.O. satisfied himself regarding the genuineness of the claim.

d) Heavy Professional & Legal charges have been debited in the P&L account to the tune of Rs.56,02,852/-. If is noted that the said expenses are disproportionately higher than the preceding year. If is noted that only general submissions were made in this regard by the assessee. The A.O. did not care to ask the assessee to co-relate the expenses to the exact legal and professional services procured case-wise, and to ascertain the genuineness of the same.

e) As per P&L account, there is a payment of Rs.50,000/- for the purchase of some "book". The said expenses have been booked under the "Miscellaneous Expenses". The A.O. has not cared to go through the details of Misc. expenses and to ascertain whether the expenses claimed were genuine and incidental to the business of the assessee.

f) Further, there are huge Travelling Expenses "Staff", and foreign travelling expenses of directors claimed by the

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 7 assessee. Given the fact that there was hardly any worthwhile business transacted by the assessee company, the business relevance and the genuineness of the given expenses has not been probed into by the A.O.

g) Salary has been paid to one "Heritage Security & Intelligence Services". It has not been examined by the A.O. whether the expenses were genuine and incidental to the business of the assessee.”

hadspecifically replied to each and every query before the Ld. PCIT.

He drew our attention to page Nos. 11 to 15 of the order, which is

reproduced as under;-

III. Without prejudice to the objections raised by the assessee in para II above, the assessee herein below stated the facts and justification of expenses claimed by the assessee as below:-

J. Commission /Brokerage and other expenses : Rs. 27,80,000/- During FY 2014-15, the assesse company has sold land situated at Gali no. 8, 458- 466,friends Colony Industrial Area, Shahdara Delhi for Rs. 2,32,00,000/-(Copy submitted before learned AO). The assessee claimed following deductions from such sales consideration:-

i. Cost of acquisition ; : Rs. 6,14,400/- ii. Commission /Brokerage and other expenses : Rs. 27,80,0001-

The assesse, vide its reply dated 17.08.2017 submitted details and bills of such expenses. The details of expenses are as below:- SN Name of Party Amount Remarks Justification (Rs.) Rajeev 8,00,000 Commission Commission for sale of property. 1. insulation expenses. Bill Debited to profit and Loss products attached as per account. Added Dock and page reduced from capital Gains. no.......to.....

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 8 2. Mayank Gupta 5,90,000 Commission Commission for sale of property. expenses. Bill Debited to profit and Loss attached as per account. Added back and page no....to , reduced from capital Gains.

In the show cause notice, there appears some typing error in mentioning Rs, 8,00,000/- as Rs.8,80,000/- and accordingly total wrongly mentioned as 28,60,000/- where as correct amount is Rs, 27,80,000/- 2. Repair and maintenance expenses amounting to Rs10,33,079/-. : !n the show cause notice, there appears some typing error in mentioning Rs.10,35,079/-instead of correct figure Rs.10,33,079/-. Details of repair and maintenance expenses were submitted before Learned AO (refer Page no.....to.....) . Details re produced herein below:-

Financial Grouping Tally Grouping Debit Repair & Maintenance MISC REPAIRS (DEL) 7,500 Repair & Maintenance REPAIRS TO OTHER 67,930 BUILDING (SBD Repair & Maintenance Office Upkeep 22,504 Repair & Maintenance Repair & Maintenance - 14,055 Computer Repair & Maintenance Repairs & 921,090 Maintenance (Delhi) TOTAL 10,33,079

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 9

Copies of ledger account enclosed page no. .....to......(Submitted vide submission dated 17.08.2017 before Id. AO)

The two bills of MPN Builders & Contractors of Rs. 54,000/- and 1,59,000/- dated 04.02.2013 and 20.04.2013 respectively were though debited to profit and Loss account but since the work done was in dispute and thus assessee never recorded such invoice earlier. Intact, in current year also, on perusal of mere ledger account your goodself will observe that assessee company has once debited Rs.54,000/- and Rs.1,59,000/- and on same date has reversed 2,08,180/- from the expenses. Thus only accepted claim of MPN builders to the tune of Rs.4820/-.

From the above it is evident that in total repair & maintenance expenses assessee amounting to Rs. 10,33,079/- the assessee has claimed only Rs. 4820/- which pertains to prior period bills of MPN builders which got settled In current year. The same was well explained to learned AO as well and only after being satisfied, learned AO accepted the assessee's claim. Hence change of opinion is undesirable under ambit of section 263.

Repair to "Sahabad Building” Rs. 67.930/- : There are guards who stays and look after sahabad land of the assessee. The building is very old and requires some maintenance. The assessee company has put fencing around the main entrance to avoid unauthorized entry. Copy of bill and voucher is enclosed.

3.Survey expenses Rs 60,000/-.-Survey expenses paid to a consultant @10,000/- for conducting market survey for the assessee. As matter of fact the assessee during the previous year 2014-15, carried out the business activity of earning commission. A short note in respects to business activity of earning commission is appended herein below:-

a. The business activity of earning commission was started with initial market survey in 1995-96 and commercial activity of commission earning was started in the beginning of 1997-98 the items are:-

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 10 i. Import of Specialized polymers resins - used by' Indian Railway, Automotive Industry'- like MaruiiUdyog, Cooling towers manufacturers and Chemical equipments made of Fibers Glass Reinforcement manufactures and

ii. Import of Hard PVC foam. Balsa wood for Indian Railways, Aerospace Wind energy sector and ship buildings. b. Above items are specialized products and not easily available in Indian markets-even though some are available but are of inferior quality and not acceptable to the manufactures of equipment's in government sector I organized sector. Some of the import customers are Indian Railways Coach building factory RCF -Kapurthala, National Aerospace, NSTL Vishakhapatnam, Hindustan Aeronautics Ltd. Etc. and in corporate sector iikeSuzlon, Sterling group Enercon India, Paharpur Cooling Tower etc. .

c. These customers float Global tender enquiry for the specialized items required and we on behalf of our principal company in Switzerland I USA and China submit the price and technical bid. All work connected to the technical approval, price negotiation and fill the finalization of the order is looked after by our team of sales, marketing and technical person who have been trained in USA Factory of our foreign principals.

d. After the order finalization, all work connected to the opening of letter of credit, and thereafter the work connected to the receipt of goods in India, inspection, customs clearance and handling forwarding etc. till receipts of goods to customers is under the supervision of our officers. The Job requires extensive travelling and close coordination at all levels in Government and corporate sectors.

The assessee hired a consultant on contract basis ©10,000/- per month and has paid the said amount to her Since the expenses is related to business of the assessee the same should be allowed.

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 11 company has on going number of court cases and contesting demand and penalties for which proceedings have been initiated under different laws . The assesse company has ongoing litigations as under:

n. Before sales tax authorities-contesting demands. o. Writ petition before High Courts against attachment proceedings, p. Before B1FR q. Before AAIFR r. Before Central Excise departments contesting demands, s. Settlement proceedings with Uttar Haryana Bijli Vitran Nigam. t. Settlement proceedings with HSIDC. u.Settlement proceedings Before Labour cour/Labour laws for settlement of gratuity, v. Settlement proceedings Before Labour court / Labour laws for payments of provident funds, w. Before Civil courts torrent recover/suits, x. Before Civil courts and High courts for vacant possession of lands. y. Routine Audit works z. Routine ROC and other statutory compliances. Copies of ledger account with narration of legal and professional expenses along-with copies of invoices is attached at page no.....to......., the same were submitted before learned AO as well and learned AO on test basis has verified and satisfied himself on the claim of the assessee.

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 12

The assessee is line of business requires extensive travelling. The principal of assessee is a swiss based company. Assessee is working under trade name ''Composite Polymers & Specialties Company, a Unit of Indian Sulphacid Industries Limited. The assessee travels frequently to attend workshops, launches of the products. The assesse has submitted complete details of travelling expenses alongwith bills and vouchers. Intact for foreign travelling copy of Invitation / email trails were also asked by learned AO and produced by the assessee. ( Copies attached.......................) From the above it can be slated that assessee has incurred travel conveyances expenses and thus correctly allowed by learned AO.

Under the above circumstances, your good self will appreciate that learned AO has carried out complete enquiry, including independent inquiry and after being satisfied with the details submitted before him from time to time has allowed the claim of cost of Improvement from long term capital gains. Accordingly, it is requested that the proceedings u/s 263( I) may kindly be dropped.” 7. The Ld. Counsel for the assessee contended that despite the

specific issue wise response filed by the assessee, the Ld. PCIT

without dealing with the same held the order erroneous for lack of

enquiry and further for the reason that the submissions/explanations

and documents filed by the assessee needed further verification. The

Ld. Counsel for the assessee contended that powers u/s 263 of the

Act cannot be exercised for mere purpose of further enquires and

there has to be specific findings in the order of the Assessing Officer

for exercising the revisionary powers u/s 263. He, therefore, pleaded

that the orders passed u/s 263 be quashed since it was not in

accordance with law.

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 13

the Ld. PCIT contending that in view of the glaring discrepancies

pointed out by the Ld. PCIT in the evidence submitted by the Ld.

counsel for the assessee vis-a-vis its claim of expenses against

capital gains income and against business income, the fact of

Assessing Officer accepting the same showed clear non application

of mind by the Assessing Officer and no proper enquiries being

conducted and, therefore, the order of the Assessing Officer had been

rightly held to be erroneous by the Ld. PCIT.

the order of the PCIT and also documents submitted before us. The

basis for holding the assessment order erroneous by the Ld. PCIT,

we find is that the details ,evidences and explanation filed by the

assessee in support of its claim of capital gains and business loss

returned were accepted as such by the AO without conducting any

inquiry and or verification. The entire thrust of the Ld.Pr.CIT is on

this aspect of non-verification of the evidences, details and

explanations filed by the assessee as is evident from the findings of

the Ld.Pr.CIT at para 4-10 of her order as under:

“4. The submissions made by the assessee have been carefully perused and duly considered. The same are discussed herewith along with the facts of the case on merits:-

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 14 The assessee has challenged the invoking of the provisions of Section 263 on the grounds that the Assessing Officer had made proper and adequate enquiries and examination as required in the facts of the case and thereafter allowed the claims of the assessee. The assessment order is stated to be not erroneous on this ground. It is further stated mat merely a different view from that of the Assessing Officer by itself could not have been a ground for exercising jurisdiction u/s 263. If was also submitted that an order can be interfered with under the revisionary provisions not only when the order is held erroneous but it also has to be prejudicial to the interest of Revenue. Several case laws have been relied upon. In the present case, the Assessing Officer completed the assessment without any application of mind and without conducting any worthwhile enquiries as is evident from the reasons spent out in the show cause letter for initiating the revisionary proceedings u/s 263 of the Act. The AO blindly accepted assessee's claims without any independent verification as will be evident from the ensuing discussions. There were no subsequent events that were not available to the AO at the time of making the assessment.

It has been held by many courts that where there is lack of proper enquiry or application of mind the invoking of provisions of Section 263 is rightful and justified (Shiv Automobiles Vs ITO [2010]133 TTJ 505: 43 DTR 345 (ITAT Agra) where the claims of deductions were allowed without any application of mind, the order of revision was held to be justified. (CIT Vs Alloy Steel (2013) 359 ITR 355 : 217 Taxman 262 (Kar). The Courts have held that an order by the Assessing Officer without application of mind is definitely prejudicial to interest of revenue (Malabar Industrial Co.ltd. vs. CIT(2000) 243 ITR 53(SC), Bharat Overseas Bank Ltd. Vs CIT (2013) 152 TTJ 546 : 82 DTR 373 (ITAT Chennai), Also, inadequate inquiry by the Assessing Officer which led him to believe incorrect facts was prejudicial to the Revenue (CIT Vs Maithan International (2015) 375 ITR 123 : 277 CTR 65 :231 Taxman 381 : 117 DTR 401 (Cal). Considering the submissions of the assessee, the facts of the case and the judicial pronouncements

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 15 as discussed above, the claim of the assessee that recourse to Section 263 of the Act, in the present case, is not sustainable. 5. The assessee has submitted details of the deductions claimed on account of commission/brokerage and repairs etc. amounting to Rs.27,80,000/- in the calculation of Capital Gains. The justification of the expenses was not examined by the AO. These are required to be examined to verify their allowability. 6. With respect to the repair and maintenance expenses amounting to rs.10,33,079/-, the assessee has claimed that only a sum of rs.4820/- has been eventually claimed. This aspect was not verified by the AO and requires verification. Similarly, the repair to Shahabad building requires verification. 7. The assessee has explained the business requirement of the expenditure of Rs.60,000/- on account of survey expenses. The name, address of the recipient as well as nature of service rendered have not been spelt out. The AO had failed to verify this aspect which required verification. 8. The allowability of the professional and legal expenses amounting to Rs.56,02,852/- and travelling expenses of staff and foreign travelling expenses amounting to Rs.19,61,571/- has to be verified as there was no application f mind to the same by the AO. 9. The purchase of book and salary paid to heritage security and intelligence services have to be verified with respect to the claim of the assessee. 10. In view of the above, it is clear that the AO has passed the order dated 06.12.2017 in an extremely careless, casual and perfunctory manner without caring to go though the details of the case and conducting any worthwhile enquiries on critical issues. The AO failed to exercise due diligence in respect of each and every issue involved in the assessee’s case, and has passed a summary assessment order after simply obtaining a few documents from the assessee and placing them on record. The order passed by the A.O. is, therefore, held to be erroneous in so far as it is prejudicial to the interest of Revenue. The same is accordingly set-aside with the directions to the A.O. to make the assessment afresh after interalia considering all the facts/issues discussed above. The A.O. is also directed to allow

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 16 reasonable opportunity of being heard to the assessee before passing the assessment order in this case.”

Ld.Pr.CIT has dealt with each issue flagged in her show cause

notice, and admitted to the fact of details ,evidences and

explanations vis a vis the same being filed by the assessee, but has

held that they need further verification. Surprisingly though no

reason has been given for the need for further verification.

the assessee to the income returned for taxation. But the extent and

manner of verification is dependent on the subjective satisfaction of

the assessing officer. All claims are primarily substantiated by

supporting evidences/documents. It is not that every evidence so

filed needs to be necessarily verified. This neither appeals to logic

nor is it feasible logistically considering voluminous transactions

carried out by assessees in the course of their business. The AO can

be satisfied about the veracity and genuineness of the transaction

basis the supporting documentary evidences and explanations filed

with respect to the same. But at the same time if the evidences and

documents raise suspicion then a case for further verification is

compulsorily made out and the absence of the same surely makes the

order erroneous so as to cause prejudice to the Revenue. But in the

present case, sadly the Ld.Pr.CIT has failed to make out a case for

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 17 further verification of the details and explanations filed by the

assessee. Undisputedly the AO had examined the claim of capital

gains and business losses returned by the assessee, during assessment

proceedings. Even with regard to the issues flagged by the

Ld.Pr.CIT, the AO had examined the same with the evidences ,details

and explanations filed by the assessee. There is no dispute with

regard to the aforesaid. Even before the Ld.Pr.CIT the assessee had

referred to the said evidences and explained the queries raised by the

Ld.Pr.CIT. Without pointing out fallacy in the same so as to raise

doubt regarding the veracity of the claim ,thus calling for further

verification, we cannot agree with the findings of the Ld.Pr.CIT that

the issues required further verification and the absence of the same

resulted in the assessment order so passed being erroneous.

“should have been made”(emphasis provided by us) which makes the

order erroneous as per explanation 2(a) to section 263 which reads

as under:

“S.263. (1) The Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing] Officer is erroneous in so far as it is prejudicial to the interests of the revenue, he, may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 18 directing a fresh assessment. Explanation.- For the removal of doubts, it is hereby declared that, for the purposes of this sub- section,- Explanation-1 ………………………… …………………………………………….. …………………………………………….. Explanation-2 For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Commissioner or Commissioner,- (a) The order is passed without making inquiries or verification which should have been made;” 13. The order of the Ld.Pr.CIT, in the impugned case, falls

grievously short of this requirement of pointing out the absence of

enquiry “which should have been made” in the present case. And

therefore, we hold, that there is no finding by the Ld.Pr.CIT of the

assessment order being erroneous. The jurisdiction assumed by the

Ld.Pr.CIT, therefore u/s 263 of the Act for revising the assessment

order therefore, is, we hold, not as per law and the order so passed

by the Ld.Pr.CIT is accordingly set aside.

Order pronounced on 22.02.2021.

Sd/- Sd/- (R.L. NEGI) ( ANNAPURNA GUPTA) Accountant Member Judicial Member Dated : 22.02.2021

ITA No. 261-Chd-2020 - Indian Suphacid Industries Limited , New Delhi 19 “आर.के.”/Rati

आदेशक���त�ल�पअ�े�षत/ Copy of the order forwarded to : 1. अपीलाथ�/ The Appellant 2. ��यथ�/ The Respondent 3. आयकरआयु�त/ CIT 4. आयकरआयु�त (अपील)/ The CIT(A) 5. �वभागीय��त�न�ध, आयकरअपील�यआ�धकरण, च�डीगढ़/ DR, ITAT, CHANDIGARH 6. गाड�फाईल/ Guard File

आदेशानुसार/ By order, सहायकपंजीकार/ Assistant Registrar