M/S. SHUBH ENTERPRISE,SURAT vs. PR. CIT-1, , SURAT

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRIPAWAN SINGH, JM &DR. A.L.SAINI, AM आयकरअपीलसं./ITA No.317/SRT/2018 (िनधा�रणवष� / Assessment Year: (2013-14) (Virtual Court Hearing) M/s Shubh Enterprise Principal Commissioner of Income V TP Scheme No.14, Plot No.42, Opp. Tax-1, Aayakar Bhawan, Majura s. Recent Residency, Pal Village, Surat Gate, Surat-395002 �थायीलेखासं./जीआइआरसं./PAN/GIR No.: ABZFS 6271 K (Appellant ) (Respondent)

Assessee by : Shri Sapnesh R Sheth, C.A Respondent by :Shri Sreenivas T Bidari, CIT-DR

सुनवाईकीतारीख/ Date of Hearing : 27/09/2021 घोषणाकीतारीख/Date of Pronouncement : 09/11/2021 आदेश / O R D E R PER DR. A. L. SAINI, ACCOUNTANT MEMBER:

By way of this appeal, the assessee has called into question correctness of impugned order passed by the Learned Principal Commissioner of Income Tax under section 263 of the Income tax Act, 1961( in short ‘the Act’), in the matter of assessment under section 143(3) of the Act, 1961, for the assessment year 2013- 14, on the following grounds:

“1.On the facts and circumstances of the case as well as law on the subject, the learned Pr. Commissioner of Income-Tax has erred in passing revisionary order u/s 263 of the I.T. Act setting aside the order of ld. assessing officer passed u/s 143(3) of the Act dated 29.02.2016 for the year under consideration although said order is neither erroneous nor prejudicial to the interest of revenue. 2. On the facts and circumstances of the case as well as law on the subject, the learned Pr. Commissioner of income-tax has erred in observing that order passed by assessing officer u/s 143(3) of the Act is erroneous on the ground that interest & remuneration to partners u/s 40(b) has been allowed without verifying that income disclosed in survey by assessee is business income. 3. It is therefore prayed that order passed by Pr. Commissioner of income-tax u/s 263 of the I.T.Act setting aside the order of Assessing Officer and directing Assessing Officer to

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make fresh investigations on issue of deduction of interest & remuneration u/s 40(b) of the I.T. Act may please be quashed.” 2.The facts necessary for disposal of the appeals are stated in brief.The assessee before us is a firm. The assessee-firm is engaged in the business of real estate development and construction of properties and has filed its return of income on 22.09.2013, declaring total income of Rs.8,26,38,930/-for AY 2013-14. The scrutiny assessment for the assessment year 2013-14 was framed by assessing officer on 29.02.2016, under section 143 (3) of the Act, by accepting the income returned by the assessee-firm.

3.Later, Learned Principal Commissioner of Income Tax (Ld.PCIT) has exercised his jurisdiction under section 263 of the Income tax Act, 1961. On verification of the Return of Income, details available on record and assessment order u/s 143(3) of the I.T.Act dated 29/02/2016 for the AY.2013-14, the ld PCIT has observed the following facts : (i). There is incorrect computation of the business income of the firm for the year in view of violation of provisions of section 40(b) read with section 184 and provisions of section 115BBE of the Income Tax Act.

(ii). Deductibility of interest paid to partners by a firm depends upon the fulfillment of conditions of section 184 and 40(b) of the I.T. Act. As per section 40(b) of the I.T.Act, payment of interest should be authorized by the partnership deed, the payment of interest should pertain to period commencing after execution of the partnership deed and the rate of interest should not exceed 12 per cent.

(iii). A survey u/s 133 A of the I.T.Act was conducted at the business premises of "the firm on 16.02.2013, whereby certain incriminating document was found and impounded.

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(iv). During the course of survey proceedings on 16/02/2013, statement of Mr. Sanjaybhai Naranbhai Patel, partner of the firm was recorded on oath. Subsequently, notice u/s 131 of the Act was issued and his statement was recorded again on 19.03.2013. In his statement, Shri Sanjaybhai Naranbhai Patel admitted to undisclosed income of the assesses firm to the extent of Rs. 9,00,00,000/- for AY. 2013-14.

(v).Theassessee firm has disclosed the admitted income in its Profit and Loss account for the year and has also offered net profit to the extent of Rs.8,26,47,743/-after adjustment of payment of interest of Rs.23,30,367/- and remuneration of Rs. 46,86,000/- to partners.

(vi). The amended partnership deed of the firm has been executed on 26/05/2012,and as per this amended partnership deed, no interest shall be paid to the partners on the amount of capital brought in by them into the firm till then or on any further introduction of capital by the partners in the partnership firm.

(vii). However, in violation of the said clauses of the partnership deed, the assessee firm has paid interest to its partners from the income admitted as undisclosed income and the same is not in accordance with the provisions of section 40 (b) r.w.s184 of the Act.

(viii) In view of the above facts, the claim of interest payment of Rs.23,30,367/- to partners was required to be disallowed. However, the same has not been disallowed by the Assessing Officer in the assessment order u/s 143(3) of the I.T.Act dated 29/12/2015 for the AY.2013-14 in the case of the assessee firm. The assessment order is therefore erroneous and prejudicial to the interest of Revenue.

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(ix). It is further observed that as per the provision of section 115BBE(2) of the I. T. Act, no deduction in respect of any expenditure or allowance shall be allowed to the assessee under any provision of the Income Tax Act while computing the income referred to in sections 68, 69, 69A, 69B, 69C and 69D. In view of these provisions of law, the claim of payment of remuneration of Rs.46,86,000/- to partners of the firm was required to be disallowed. However, the same has not been disallowed by the Assessing Officer in the assessment order u/s 143(3) of the I.T. Act, dated 29/12/2015, for the AY.2013-14 in the case of the assessee-firm. The assessment order is therefore erroneous and prejudicial to the interest of Revenue. Thus, after considering the return of income and other details and documents available on record, it is observed by the ld PCIT that assessment order u/s 143(3) dated 29.02.2016 passed by the Assessing Officer for the AY.2013-14 in the case of assessee is erroneous and prejudicial to interest to Revenue. As the above irregularities to the extent of points discussed above, is erroneous and prejudicial to the interest of Revenue, therefore, ld PCIT initiated action under section 263 of the I. T. Act and issued a show cause notice to the assessee.

4.In response to the show cause notice, assessee had submitted its reply, vide letter dated 14.02.2018, which is reproduced below:

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(vi) of above referred notice, it is submitted that vide amended partnership deed executed on 26.05.2012only remuneration clause was amended whereas, interest clause was also amended by executing partnership deed on 01.06.2012. As per the same, it is provided that interest at the rate of 12% shall be payable to the partners of the firm. Copy of amended partnership deed dated 01.06.2012 is produced herewith for your reference. Thus, there is neither violation of interest clause of partnership deed nor provisions of section 40(b) r.w.s. 184 of the Act. Hence, the same has not been disallowed by assessing officer in the assessment order u/s 143(3) of the Act dated 29.12.2015. Further partner's interest & remuneration is separately offered to tax by all the partners in their respective cases. As such there is no evasion of tax & there isno loss to revenue. Hence, the assessment order passed u/s 143(3) of the Act is not prejudicial to the interest of revenue. 3. As regards provision of section 115BBE(2) of the Act, it is pertinent to mention here at the outset that the income disclosed during the course of survey represents business income and against the same the expenditure relating to business of assessee are eligible for deduction. It is evident on perusal of statement dated 19.03.2013 recorded at the time of survey of Shri Sanjay N. Patel - partner of assessee firm that disclosure relates to cash received on sale of flats & entire disclosure pertains to the project of "Prestige Manor" developed by the firm & the same represents business income of the firm. Thus, this is not the case where addition is made on the basis of presumptive provisions of section 68 / 69 etc. & therefore, provisions of section 115BBE are not attracted. Consequently, partners salary and interest expenditure being directly related to earning of above income, the same is legitimately allowable as business expenditure. In support of above contention reliance can be placed on the following judicial pronouncements: …………………………………………………………………………………………….. 4. It is also pertinent to mention that during assessment proceedings, the Id. A.O has raised specific query regarding allowability of partners salary & interest against the income disclosed during survey & in response, assesses submitted detailed explanation along with relevant judicial pronouncements. As such the issue has been examined by Id. A. O at the time of assessment proceedings & after duly applying his mind, the Id. A. O has allowed the claim of expenditure. As such the assessment order passed by Id. A.O cannot be termed as erroneous. 5. In light of above submissions, it may kindly be appreciated that assessment order passed u/s 143(3) of the Act is neither erroneous nor prejudicial to the interest of revenue & hence, proceedings initiated u/s 263 of the Act is requested to be dropped.”

5.Having gone through the reply of the assessee, Learned Principal Commissioner of Income Tax, has rejected the contention of the assessee and observed that assessee in his submission has mentioned that income disclosed is related to business but has not substantiated his submission with supporting evidence like

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names of the persons from whom the assessee has received the un-accounted money and also the Assessing Officer during the course of assessment proceedings has only relied on the replies given by the assessee without making independent verifications. Therefore, in absence of any documentary evidences to justify that Income declared is business income or not, the claim of the assessee that the unaccounted Income disclosed, is its business income, is not acceptable .The fact that the partner of the assessee Shri Sanjaybhai N Patel stated during the course of Survey Proceedings that they did not maintain any detail of cash received, when he was specifically asked in question No.9 to quantify the amount of cash received on account of booking of flats, clearly proves that the assessee does not have any detail to correlate these receipts with the actual persons to hold that these receipts pertain to the business of the assessee. In absence of these details, the Assessing Officer should have assessed the Income disclosed as "income from other sources" or income taxable under the provisions of section 68/69/69A of the Act, and the assessee was not entitled for deduction of interest and remuneration against such income.

7.Aggrieved by the order of Ld. PCIT, assessee is in appeal before us.

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8.Shri Sapnesh R Sheth, Learned Counsel for the assessee submits before us that undisclosed receipts of Rs.9,00,00,000/- which were not recorded in the regular books of account pertain to assessee`s business and the same has been disclosed during survey proceedings. This money pertains to cash received on account of booking of flats, hence it is business income of the assessee. The ld Counsel submits that as per amended partnership deed the assessee is entitled to claim deduction of interest and remuneration of Rs.23,30,367/- and Rs.46,86,000/- respectively. The ld Counsel further submits that Assessing Officer has examined these issues during the assessment stage, that is, disclosure to the extent of Rs.9 crores and secondly partner’s remuneration and the interest paid to the partners, have been verified and examined by the assessing officer. Therefore order passed by the Assessing Officer under section 143(3) of the Act, is neither erroneous nor prejudicial to the interest of revenue, hence order passed by the ld PCIT under section 263 of the Act may be quashed.

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10.We have heard both the parties and carefully gone through the submissions put forth on behalf of the assessee alongwith the documents furnished and the case laws relied upon and perused the facts of the case including the finding of Ld. PCIT. We note that Ld. PCIT has mainly raised two issues in his order u/s 263 of the Act, viz: (i). The undisclosed money of Rs.9 crores, which were disclosed during the course of survey, has not been examined by the Assessing Officer i.e. its nature, whether it relates to ‘business income’ or it relates to ‘income from other sources’, has not been examined by the assessing officer, and (ii)The deduction of interest and remuneration of Rs.23,30,367/- and Rs.46,86,000/- respectively, have been allowed in violation of the provisions of the Income Tax Act.

We note that said two issues raised by the ld PCIT in his order u/s 263 of the Act, have been examined by the assessing officer while framing assessment order under section 143(3) of the Act, dated 29.02.2016. The relevant part of the assessment order is reproduced below:

“3. The assessee is engaged in real estate development and construction of properties. The firm has commenced its business during the current year. A survey u/s 133 A of the I T Act was conducted in the business premises of the assessee on 16.02.2013, whereby incriminating document marked as “B-1-1” was found and impounded. During the course of survey proceedings, statement on oath of Mr. Sanjaybhai Naranbhai Patel was recorded. Subsequently, notice u/s 131 of the Act was issued and his statement was recorded on 19.03.2013, whereby the entries contained in the document were confronted. Mr. Sanjaybhai Naranbhai Patel taking into consideration the facts of the case and entries contained in the impounded documents, admitted undisclosed income of Rs. 9 crores (Rupees Nine crores). The assessee has disclosed the admitted income in its profit and loss account and has also offered net profit to the extent of Rs. 8,26,47,743/- after adjustment of partner's interest of Rs. 23,30,367/- and partner's remuneration of Rs.46,86,000/-. 3.1 During the year under consideration, the project of the assessee was just started and the entire construction expenses have been capitalized. As per "Method of Accounting” the firm is adopting accrued concept in the preparation of the account following historical cost convention. The firm is engaged in the business of building construction, and revenue is to be recognized when effective control of the real estate is handed over to the buyers. During the course of assessment proceedings, the details of construction expenses and source of capital and introduction by the partners have been called for and examined. The

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entire loan confirmations, as well as details of current liabilities and provisions have also been called for, examined, and placed on record. 3.2 The partners have been paid remuneration and interest. The provision of remuneration and interest is found to be provided under the Clause 7 & 8 of the Partnership Deed. 4. After examination and discussion, the total income declared in the returned income of the assessee is accepted.”

11.From the above assessment order passed by Assessing Officer under section 143(3) of the Act, it is vivid that Assessing Officer has examined and discussed the undisclosed income of Rs.9 crores in para-3 of his assessment order, as noted by us above. The Assessing Officer has also discussed and adjudicated the issue relating to remuneration to partners and interest paid to partners, vide para-3.2 of assessment order, as noted by us above. Therefore, it is abundantly clear from the above assessment order that during the assessment stage, the assessing officer has examined and verified both the issues which were raised by the ld PCIT in his order under section 263 of the Act. Hence, order passed by the assessing officer under section 143(3) of the Act is neither erroneous nor prejudicial to the interest of Revenue.

12.During the assessment proceedings, assessee has submitted reply to the Assessing Officer in response to question raised by the Assessing Officer which is placed at paper book page no.5, and page no.11 of the paper book. Therefore, we note that Assessing Officer has raised the question during the assessment stage and assessee has replied to the assessing officer along with relevant documents.Thereafter, assessing officer has applied his mind and examined both the issues, viz: undisclosed income of Rs.9 crores and interest and remuneration paid to the partners. Therefore, it cannot be said that the issue has not been examined by the Assessing Officer. Considering this factual position, we note that order passed by the Assessing Officer is neither erroneous nor prejudicial to the interest of Revenue and for that reliance can be placed on the judgment of Hon'ble

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jurisdictional High Court in the case of CIT vs. Suman Paper & Boards Ltd. 221 CTR 0781 (Guj), wherein it was held as follows:-

“Respondent assessee is a partnership firm engaged in the business of running a hospital. For the assessment year -2004-05, the assessee filed its return of income. The Assessing Officer, accepted the return substantially except for making disallowance of 10% of the expenses of Rs.5,54,324/- claimed by the assessee and framed the assessment on 21st September 2005. The said order of the Assessing office dated 21.09.2005 was taken in revision by the Commissioner of Income Tax in exercise of powers under section 263 of the Income Tax Act. The Commissioner noted that during the survey operations under section 133A of the Act at the premises of the assessee firm, the assessee disclosed an additional income of Rs.19,91,000/- which was invested in assets not recorded in the books of accounts. After adding such amount of Rs.19,91,000/- in the income of the assessee for the year in question, the assessee had shown a profit of Rs.7,67,000/-as against the previously arrived at loss of Rs.12,24,000/-. From the said income of Rs.7,67,000/-, the assessee had claimed deduction of a sum of Rs.3,77,000/- towards remuneration of the partners. The Commissioner was of the opinion that such income of Rs.19,91,000/- has to be assessed under section 69 of the Act. The Commissioner also noted that the assessee had utilized the borrowed funds not for setting up of business, but for expansion of the business inasmuch as the fixed assets of the assessee firm increased and investment in the building also increased substantially. Commissioner, therefore, was of the opinion that though the interest on borrowed funds utilize for expansion of running business deserves to be allowed, the Assessing Officer should examine the utilization of the borrowed funds for renovation of the building for capitalization. On these two grounds, the Commissioner was of the opinion that the powers under section 263 of the Act are required to be exercised. He accordingly, restored the proceedings to the Assessing Officer for re-framing the assessment after hearing the assessee. To do so, he came to the following conclusions: “The assessee has adduced evidence that the interest bearing borrowing funds were not utilized for setting up of the business but the same were utilized for expansion of the business inasmuch as that fixed assets of the assessee increased from Rs.57,49,512/- to Rs.1,32,36,268/-.The investment in building increased from Rs.37,65,831/- to Rs.65,13,410/- and investment in the plant and machinery incurred by Rs.25,49,930/.The assessee has not constructed a new hospital and has only added extra facilities in the existing hospital. Therefore, the interest on borrowed funds utilized for expansion of running business deserves to be allowed. However, the A.O. may examine the utilization of borrowed funds for renovation of building for capitalization in the light of the decision of the Hon'ble Supreme Court in the case of Ballimal Naval Kishore 224 ITR 414. The income of Rs.19,91,701/- was declared by the assessee during survey u/s.133A of I.T.Act as investment in assets not recorded in the books of A/c. Once the assessed has admitted the income to represent the investment in assets not recorded in the books of accounts, the income has to be assessed u/s.69 of the I.T.Act. The Department is not to seek or establish any other source of income which could have resulted in such investment." The assessee aggrieved by the said order of the Commissioner approached the Tribunal. The Tribunal by the impugned judgment dated 23.2.09 allowed the appeal and set aside the order by the said order of the Commissioner.

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With respect to question of interest bearing borrowed funds not being utilized for setting up of business, the Tribunal observed that though the Commissioner was convinced that such interest was allowable, he required the Assessing Office to examine the issue in light of the decision of the decision of the Apex Court in the case of Ballimal Naval Kishor v. CIT, (1997) 224ITR 414. With respect to treatment to undisclosed income of Rs.19,91,000/- the Tribunal was of the opinion that from the remainder of the profit, the assessee could have claimed deduction for the remuneration paid to the partners. In any case, the Tribunal was of the opinion that when two views are possible, powers under section 263 of the Act could not have been exercised. The Tribunal in this regard relied on the decision of the Apex Court in the case of Malabar Industrial Co. Ltd. v. CIT, 243 ITR 83. The Tribunal also relied on the decision of the Karnataka High Court in the case of CIT v.S.K.Srigiri and Bros.(2008) 298 ITR 13 (Karn). The decision of this Court in the case of Fakir Mohmmed Haji Hasan v. CIT 247 ITR 290 (Guj) was distinguished on facts. On behalf of the Revenue, counsel submitted that the Tribunal committed grave error. The Commissioner exercised powers under section 263 of the Act giving cogent reasons and remanded the proceedings before the Assessing Officer for fresh consideration. Such order ought not to have been disturbed. Counsel further submitted that undisclosed income of Rs.19, 91,000/- cannot be treated as the business income of the assessee and must be treated to be an income from other source. No deduction from this income can be made for incurring business expenditure. Counsel drew our attention to the decision of this Court in the case of Deputy CIT v Radhe Developers India Ltd. (Guj) 329 ITR 1. On the other hand, counsel for the assessee submitted that the Assessing Officer committed no error in the assessment order. The Commissioner could not have revised such order even without holding that the order passed by the Assessing Officer is erroneous and is prejudicial to the interest of the Revenue. He submitted that deduction towards interest on borrowed funds would be allowable deduction irrespective .of whether the borrowed funds have been utilized for revenue or capital expenditure. Counsel further submitted that the amount of Rs.19,91,000/- was business income of the assessee. It may have been diverted towards construction of building. It nevertheless arose from the sole activity of the assessee, namely, that of business of running hospital. Remuneration to the partners within the limit prescribed under the law was therefore an allowable deduction. He submitted that in any case, even if it is held that two views are possible, powers under section 263 of the Act should not be exercised. Having thus,- heard the, learned counsel for the parties in so far as the first question on which the Commissioner sought to reopen the assessment by exercising powers under section 263 of the Act is concerned, same permits no debate. It is by now well settled that interest on borrowed funds would be allowable deduction irrespective of whether such funds are utilized for incurring revenue or capital expenditure. Reference in this regard can be made right from the decision of this Court in the case of CIT v. Khedut Sahakari Khand Udyog Mandli, 104 ITR 206.This view was reiterated by this Court in the case of Gujarat State Fertilizer &Chemicals Ltd. v. Asst. CIT, (2009) as also by the Apex Court in the case of Deputy CIT v. Core Health Care Ltd., (2008) 298 ITR 194 (SC). Therefore, the said ground does not hold valid. With respect to second question, we may notice that the assessee's stand is that its sole business was that of running a hospital. It had no other source of income and that undisclosed income justified. Page | 11

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In the case of Deputy CIT v. Radhe Developers India Ltd., (2010) 329 ITR l (Guj.), this Court while distinguishing the decision in the case of Fakir Mohmed Haji Hasan (supra),, observed as under: "The decisions of this Court in the case of Fakir Mohmed Haji Hasan (supra) and Krishna Textiles (supra) are neither relevant nor germane to the issue considering the fact that in none of the decisions the Legislative Scheme emanating from conjoint reading of provisions of sections 14 & 56 of the Act have been considered. The Apex Court, in the case of D.P.Sandu Bros. Chembur P. Ltd.(supra) has dealt with this very issue while deciding the treatment to be given to a transaction of surrender of tenancy right. The earlier decisions of the Apex Court commencing from case of United Commercial Bank Ltd., Vs. CIT (1957) 32 ITR 688 (SC) have been considered by the Apex Court and, hence, it is not necessary to repeat the same. Suffice it to state that the Act does not envisage taxing any income under any head not specified in section 14 of the Act. In the circumstances, there is no question of trying treat any conflict in the two judgments of this Court as submitted by the learned Counsel for the Revenue.” In any case, we are convinced that the Tribunal was correct in holding that even if two views are possible, powers under section 263 of the .Act could not and ought not to have been exercised. The Apex Court in the case of Malabar Industrial Co. Ltd. observed as under: "The phrase 'prejudicial to the interests of the revenue' has to be read in conjunction with an erroneous order passed by the Assessing Officer. Every loss of revenue as a consequence of an order of Assessing Officer cannot be treated as prejudicial to the interests of the revenue, for example, when an Income-tax Officer adopted one of the courses permissible in law and it has resulted in loss of revenue, or where two views are possible and the Income-tax Officer has taken one view, with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interests of the revenue unless the view taken by the Income-tax Officer is unsustainable in law. It has been held by this Court that where a sum not earned by a person is assessed as income in his hands on his so offering, the order passed by the Assessing Officer accepting the same as such will be erroneous and prejudicial to the interests of the revenue. Rampyari Devi Saraogi v. Commissioner of Income-tax,(1968) 67 ITR 84 (SC) and in Smt. Tara Devi Aggarwal v. Commissioner of Income-tax, West Bengal, 88 ITR 323." In the case of S.K.Srigiri and Bros. (supra), the Karnataka High Court held as under: “We have perused the orders of the Tribunal has carefully considered the questions put by the authority and the-, answer of the partners of the assessee’s firm and based on the same, the Tribunal has come to the conclusion that the additional income received by the assessee in the instant case is from business and not from other sources. If the Tribunal has come to the conclusion that the additional income is from business, the remuneration paid to the partners has to be deducted while considering the profit and loss. In the circumstances, we are of the opinion that on facts the Revenue has no case on the merits. So far as the question of law is concerned, we have to answer the same in favour of the Revenue. " In view of the above discussion, we do not find any question of law arises. Tax Appeal is therefore, dismissed.” Page | 12

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13.Hence, by placing reliance on the decisions rendered by Hon’ble jurisdictional High Court in the case of CIT vs. Suman Paper & Boards Ltd (supra), we are of the view that revisionary jurisdiction exercised by the Ld. Pr. C.I.T. u/s. 263 of the Act was not in tune with the facts and evidences on record duly explained to the Assessing Officer and verified by him and that being so the order passed u/s 263 of the Act on such erroneous stand is liable to be quashed. Therefore, we quash the order of the ld. PCIT u/s 263 of the Act.

14.In the result, the appeal of the assessee is allowed.

Order pronounced on 09/11/2021by placing the result on the Notice Board as per Rule 34(5) of the income Tax (Appellate Tribunal) Rule 1963.

Sd/- Sd/- (PAWAN SINGH) (Dr. A.L. SAINI) JUDICIAL MEMBER ACCOUNTANT MEMBER Surat/िदनांक/ Date: 09/11/2021 Dkp Outsourcing Sr.P.S. Copy of the Order forwarded to 1. The Assessee 2. The Respondent 3. The CIT(A) 4. Pr.CIT 5. DR/AR, ITAT, Surat 6. Guard File By Order // True Copy // Assistant Registrar/Sr. PS/PS ITAT, Surat