SIVANANTHAM ANBUSELVAN,TIRUVARUR vs. ITO, WARD-1,, TIRUVARUR

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ITA 1799/CHNY/2026Status: DisposedITAT Chennai14 October 2026AY 2018-1913 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer failed to provide the mandatory minimum period of seven days to the assessee to respond to the notice issued under Section 148A(b) of the Act. The notice was issued on 21.03.2022, requiring a reply by 28.03.2022, which is less than seven days. The Tribunal relied on the decision of the Hon'ble High Court in the case of Bevinakuppe Ningegowda vs ITO and ITO v. Venkatal Ayyappa Ranjanna, which held that if the AO does not provide the minimum period of seven days to respond to a notice under Section 148A(b), the notice is contrary to law, and the consequential proceedings are liable to be quashed. Therefore, the notice issued by the AO under Section 148A(b) was held to be contrary to law, and the consequential reassessment proceedings were liable to be quashed. As the legal contention was considered and the appeal was allowed on this ground, other grounds were rendered academic and left undecided. The appeal of the assessee was allowed.

What were the facts?

The assessee, Sivanantham Anbuselvan, an individual running a provisional store, was identified as a non-filer for Assessment Year 2018-19 due to substantial cash deposits of Rs. 1,97,42,205/- in his bank account. Proceedings under Section 148A(b) were initiated, followed by an order under Section 148A(d) and a notice under Section 148 of the Income Tax Act, 1961, dated 01.04.2022. The assessee filed a return declaring a turnover of Rs. 1,38,31,602/-. However, the Assessing Officer (AO) found total bank credits of Rs. 2,27,40,311/-, a discrepancy of Rs. 89,08,709/-. The AO treated this discrepancy as unexplained money under Section 69A and taxed it under Section 115BBE, assessing total income at Rs. 94,09,793/-. The assessee's appeal to the NFAC, Delhi, confirming the AO's order, is under challenge before the ITAT.

What were the issues?

1. Whether the assumption of jurisdiction under Section 147 of the Act and the consequential reassessment order are valid, considering the alleged lack of proper reasons and justification? (Mixed law and fact) 2. Whether the reassessment order is invalid, passed without jurisdiction, and not sustainable in law, particularly concerning the alleged lack of proper sanction under Section 151 of the Act and non-adherence to the prescribed procedure for reassessment? 3. Whether the order passed under Section 148A(d) by the Joint Assessing Officer (JAO) instead of the Faceless Assessing Officer (FAO) renders the proceedings a nullity? 4. Whether the reassessment proceedings are vitiated due to the AO failing to provide the assessee with at least seven clear days to respond to the notice issued under Section 148A(b) of the Act? 5. Whether the addition made on account of cash deposits, restricted by the NFAC to Rs. 58,47,739/- from the AO's addition of Rs. 89,08,709/-, is sustainable under Section 69A read with Section 115BBE of the Act? Assessee's contentions: The AO failed to grant 7 clear days to respond to the notice u/s. 148A(b), making the notice and subsequent order non-est, citing the Supreme Court and Karnataka High Court in Bevinakuppe Ningegowda vs ITO. The NFAC erred in confirming the assumption of jurisdiction and the reassessment order without proper reasons. The reassessment order was passed out of time, without jurisdiction, and not sustainable. The assumption of jurisdiction lacked proper sanction under Section 151. The procedure for reassessment was not followed, making the order a nullity. The order under Section 148A(d) by the JAO instead of FAO is a procedural defect. The provisions of Section 69A r.w.s 115BBE are not applicable. The NFAC failed to independently examine the cash deposits. The entire reassessment is wrong and not sustainable. The faceless regime was not adhered to. No proper opportunity was given, violating principles of natural justice. Revenue's contentions: Not recorded in the judgment.

Which sections of the Income-tax Act were involved?

Section 147,Section 148A,Section 148,Section 151,Section 69A,Section 115BBE,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRI S.R.RAGHUNATHA

Hearing: 13.08.2026

आयकरअपील�यअ�धकरण ’बी’ �यायपीठ,चे�नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI �ी मनुकुमारिग�र, �ाियक सद� एवं �ी एस. आर. रघुनाथा लेखासद� BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S.R.RAGHUNATHA, ACCOUNTANT MEMBER

आयकर अपील सं./ITA No. 1799/Chny/2026 �नधा�रण वष�/Assessment Year: 2018-19 Sivanantham Anbuselvan v. The Income Tax Officer, 4, Senbaga Rice Mill Road, Ward-1, Mannargudi,, Thiruvarur, Tiruvarur-610001 Tamil Nadu, 614001 [PAN: AQSPA 6150 H] (अपीलाथ�\Appellant) (��यथ�\Respondent)

अपीलाथ� क ओर से/ Appellant by : Mr. N. Arjun Raj, Advocate ��यथ� क ओर से /Respondent by : Mr. E. Elango, JCIT सुनवाई क तार�ख/Date of Hearing : 13.08.2026 घोषणा क तार�ख /Date of : 14.10.2026 Pronouncement आदेश / O R D E R PER MANU KUMAR GIRI, JM:

The captioned appeal filed by the assessee is directed against the order passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as "the Ld. CIT(A)"], dated 10.02.2026, confirming the assessment order passed u/s. 147 of the Income Tax Act, 1961 ("the Act"), for the Assessment Year ("AY") 2018-19.

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 2 ::

2.

The Registry has noted a delay of 149 days in filing the present appeal. We have considered the condonation petition and affidavit filed by the assessee and find the reasons stated therein to constitute sufficient cause. Accordingly, the delay is condoned and the appeal is admitted for adjudication. 3. The assessee has raised the following grounds of appeal as under: - 1. The order of the NFAC, Delhi dated 10.02.2026 vide DIN & Order No. ITBA/NFAC/S/250/2025-26/1085813424(1) for the above- mentioned Assessment Year is contrary to law, fact and in circumstances of the case. 2. The NFAC, Delhi erred in confirming the assumption of jurisdiction u/s. 147 of the Act and consequently erred in confirming the passing of the re-assessment order u/s. 147 of the Act without assigning proper reasons and justification. 3. The NFAC, Delhi failed to appreciate that the re-assessment order was passed out of time, invalid, passed without jurisdiction and not sustainable both on facts and in law. 4. The NFAC, Delhi failed to appreciate that the assumption of jurisdiction u/s. 147 of the Act was without proper sanction in terms of Section 151 of the Act and ought to have appreciated that the consequential re-assessment order accordingly should be reckoned as bad in law. 5. The NFAC, Delhi failed to appreciate that having not followed the prescription of law/procedure for framing the re-assessment, the consequential re-assessment order passed should be reckoned as nullity in law for want of jurisdiction. 6. The NFAC, Delhi failed to appreciate that the passing of the order u/s. 148A(d) of the Act by the JAO as against the passing of the such order by the FAO would completely defy the prescription of law /

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 3 :: procedure in relation there to and hence ought to have appreciated that in the absence of valid foundation for issuance of notice u/s. 148 of the Act in view of issuance of such notice by JAO instead of FAO, the consequential re-assessment should be considered as nullity in law. 7. The NFAC, Delhi failed to appreciate that the proposal made in the Finance Bill, 2026 forming part of the Budget documents by inserting a new Section 147A of the Income Tax Act, 1961 by creating two stages in the process of commencing and completing re-assessments, even if it is approved by both the houses as well getting the Presidential assent, the action taken earlier by the JAO in initiating the re- assessment could not be cured, while on the contrary to be reckoned as fatal to the proceedings of re-assessment. 8. The NFAC, Delhi erred in restricting the addition made on cash deposits to the extent of Rs. 58,47,739/- as against the addition made by the Assessing Officer to the tune of Rs. 89,08,709/- being alleged difference between the total turnover reported at Rs. 1,38,31,602/- and the total credits in the bank account aggregating to Rs. 2,27,40,311/- made during the assessment year under consideration as unexplained money in terms of Section 69A of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The NFAC, Delhi failed to appreciate that the provisions of Section 69A r.w.s 115BBE of the Act had no application to the present facts and in circumstances of the case and ought to have appreciated that the pre-requisite conditions required for making an addition in terms of Section 69A r.w.s 115BBE of the Act were absent in the present case and in circumstances, there by negating the findings in relation there to. 10. The NFAC, Delhi failed to appreciate that having accepted the explanation offered for one component of the disputed cash deposits/credits in the bank account made during the ordinary course of business, the sustenance of the addition made on the disputed cash

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 4 :: deposits received from customers towards monthly milk cards in running a provisional store in the name and style of M/s Vasunithi Agencies should be reckoned as bad in law. 11. The NFAC, Delhi failed to appreciate that in any event, having not independently examined the nature and source of the cash deposits/credits in the bank account maintained during the assessment year under consideration including the income component embedded there on, the assessment of the entire value of cash deposits / credits as unexplained money of the appellant was wrong, erroneous, incorrect, invalid, unjustified and not sustainable both on facts and in law. 12. The NFAC, Delhi failed to appreciate that the entire re- computation of taxable total income was wrong, erroneous, incorrect, invalid, unjustified and not sustainable both on facts and in law. 13. The NFAC, Delhi failed to appreciate that having not adhered to the prescription of faceless regime, the consequential re-assessment and appellate order passed should be reckoned as bad in law. 14. The NFAC, Delhi failed to appreciate that there was no proper opportunity given before passing of the impugned order and any order passed in violation of the principles natural justice would be nullity in law. 15. The Appellant craves leave to file additional grounds/arguments at the time of hearing.

4.

Brief facts of the case are that the appellant, Sivanantham Anbuselvan, is an individual engaged in the business of running a provisional store under the name and style of M/s Vasunithi Agencies. For Assessment Year (A.Y.) 2018–19, the appellant was identified as a non-filer based on information flagged on the Insight Portal under the CBDT’s risk management strategy, indicating substantial cash deposits of Rs. 1,97,42,205/- in his

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 5 :: current account maintained with The Lakshmi Vilas Bank Ltd. during the Financial Year (F.Y.) 2017–18. Accordingly, proceedings were initiated u/s. 148A(b), followed by an order u/s. 148A(d) and notice u/s. 148 of the Income Tax Act, 1961, dated 01.04.2022. In response, the appellant filed a return of income on 12.04.2022, declaring turnover of Rs.1,38,31,602/-, net profit of Rs. 5,01,084/-, and tax liability of Rs. 23,503/-. However, on verification of the bank statement, the Assessing Officer (AO) noticed total credits of Rs.2,27,40,311/-, resulting in a discrepancy of Rs.89,08,709/- between the declared turnover and the bank credits. Despite repeated statutory notices and show-cause communications, the appellant failed to explain the discrepancy or furnish supporting evidence regarding the source of the credits. Consequently, the AO completed the assessment u/s. 147 read with Section 144B of the Act, treating the unexplained credits of Rs. 89,08,709/- as unexplained money u/s. 69A and taxing the same u/s. 115BBE. The total income was accordingly assessed at Rs. 94,09,793/-.

5.

At the outset, ld.AR for the assessee submitted that the assessing officer failed to grant 7 clear days to file response to notice u/s. 148A(b) of the Act and therefore, considering the rationale of the Hon’ble Supreme Court and laid down by the Hon'ble Karnataka High Court in the case of Bevinakuppe Ningegowda vs ITO in WP No.16325 of 2025, notice u/s. 148 of

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 6 :: the Act and assessment order passed pursuant to the said notice are liable to be treated as non-est.

6.

The Ld. Authorised Representative (A.R) with regard to the legal contention raised in the above ground submitted that the A.O failed to provide the mandatory minimum time limit of seven days to the assessee while issuing notice u/s. 148A(b) of the Act. The Ld. AR further submitted that the A.O issued notice u/s. 148A(b) of the Act on 21.03.2022 calling on the assessee to raise objections and furnish details on or before 28.03.2022. Accordingly, the Ld. AR submitted that the initiation of reassessment proceedings without giving minimum time limit for responding as per section 148A(b) is not valid and the consequential proceedings are liable to be quashed. The ld. AR in this regard placed reliance on the decision of Hon'ble Karnataka High Court in the case of Shri Bevinakuppe Ningegowda Ramalingegowda vs. ITO [WP No.16325 of 2025 dated 04.09.2025]. 7. The ld.AR also filed paper book as under:

INDEX TO PAPERBOOK – I Sl. Page Date Particulars No. No. PROCEEDINGS U/S. 148A OF THE ACT 1. 21.03.2022 Show Cause Notice u/s. 148A(b) of the Act 1 2. 28.03.2022 Reply to the Show Cause Notice u/s. 148A(b) of the Act 3 3. 31.03.2022 Order passed u/s. 148A(d) of the Act 6 4. 01.04.2022 Notice u/s. 148 of the Act 9

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 7 :: CITATIONS Pioneer Motors (Private) Ltd v. Municipal Council, 5. 27.01.1961 10 Nagercoil – Supreme Court of India - 1961 SCC OnLine SC 265 Sri Bevinakuppe Ningegowda Ramalingegowda v. Income 6. 04.09.2025 tax officer ward 1 and TPS – Karnataka High Court – W.P. 17 No. 16325 OF 2025 (T-IT) Selvaraj Arokia Sagaya Raj v. DCIT Non-Corporate 7. 12.12.2025 25 Circle-22(1), Tambaram, Chennai – Income Tax Appellate Tribunal, Chennai - ITA No. 3597/CHNY/2025 Jayaraman Rukmani v. The ITO, Non-Corporate Ward 8. 01.07.2026 34 19(6) Chennai – Income Tax Appellate Tribunal, Chennai - ITA No 3859/CHNY/2025 Rema Divakara Panicker Gopakumar v. ITO Non- 9. 27.04.2026 40 Corporate Ward-8(2), Chennai. – Income Tax Appellate Tribunal, Chennai - ITA No.583/CHNY/2026

It is hereby certified under instructions that all the above mentioned documents are TRUE COPIES and are available in the records of the department

8.

The Ld. Departmental Representative (DR), on the other hand, submitted that the time provided for response u/s. 148A(b) of the Act is directory in nature and the same to be considered based on the prejudice caused to the assessee. Accordingly, the Ld. DR relied on the orders of the lower authorities.

9.

We have heard the parties and perused the material available on record. The contention of the assessee is that the A.O has not provided the minimum timeline as prescribed to respond to the notice u/s. 148A(b) of the Act and therefore, the reassessment proceedings are invalid. In this regard, we notice that the Hon'ble Karnataka High Court in the case of Shri

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 8 :: Bevinakuppe Ningegowda Ramalingegowda (supra), has considered an identical issue, where it has been held that:

“The petitioner is before this Court seeking the following prayers: i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice u/s. 148A(b) of the Act, dated 20/03/2022 bearing DIN No.ITBA/AST/F/148A(SCN)/2021- 22/1041110019(1), issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A.

ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice u/s. 148 of the Act dated 27/04/2022 bearing DIN No. ITBA/AST/S/148_1/2022- 23/1042880981(1) issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A1.

iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order u/s. 148A(d) of the Act, dated 27/04/2022, bearing DIN No. ITBA/AST/F/148A/2022- 23/1042880971(1) passed by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A2.

iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed u/s. 147 r.w.s. 144B dated 06/12/2023 bearing DIN No.ITBA/AST/S/147/2023- 24/1058525769(1) passed by the Respondent No.2 for the assessment year 2018-19 herein marked as Annexure - A3.

v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order u/s. 271AAC(1) of the Act dated 20/06/2024 bearing DIN No. ITBA / PNL / F /271AAC(1) / 2024-25/1065858089(1) passed by the Respondent No.2 for the assessment year 2018-19 herein marked as Annexure - A4.

vi) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.”

2.

Heard Sri Ravi Shankar S V, learned counsel appearing for petitioner and Sri Thirumalesh, learned counsel appearing for respondents 1 to 3.

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 9 :: 3. The issue revolves around the minimum period to the assessee to respond to the notice issued by the Income Tax Authorities, which the statute mandates to be, not less than 7 days. The issue was before the Division Bench of this Court in W.A.No.612 of 2025. The Division Bench, in terms of its order dated 05-08-2025 while rejecting the appeal filed against the order of the learned Single Judge had favoured the assessee. The Division Bench holds as follows: “…. …. ….

2.

The respondent [Assessee] had filed the said petition, inter alia, impugning a notice dated 20.03.2022 issued u/s. 148A (b) of the Income Tax Act, 1961 [Act] for the assessment year [AY] 2015-16 on the ground that the said notice did not provide sufficient time for the Assessee to file a response to show cause calling upon him to show cause why it was not a fit case for issuance of a notice u/s. 148 of the Act.

3.

The learned Single Judge has found merit in the aforesaid contention and accordingly, set aside the impugned notice as well as the notice dated 31.03.2022 issued u/s. 148A (d) of the Act and further reassessment proceedings that were initiated pursuant to the said notice.

4.

Before proceeding further, it would be relevant to refer to Section 148A of the Act, as was in force at the material time. The same is set out as below:

"148A. Conducting inquiry, providing opportunity before issue of notice u/s. 148.

The Assessing Officer shall, before issuing any notice u/s. 148,-

(a) conduct any enquiry, if required, with the prior approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment;

(b) provide an opportunity of being heard to the assessee, by serving upon him a notice to show cause within such time, as may be specified in the notice, being not less than seven days and but not exceeding thirty days from the date on which such notice is issued, or such time, as may be extended by him on the basis of an application in this behalf, as to why a notice u/s. 148 should not be issued on the basis of information which suggests that income chargeable to tax has escaped assessment in his case for the relevant assessment year and results of enquiry conducted, if any, as per clause (a);

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 10 :: (c)consider the reply of assessee furnished, if any, in response to the show-cause notice referred to in clause (b);

(d)decide, on the basis of material available on record including reply of the assessee, whether or not it is a fit case to issue a notice u/s. 148, by passing an order, with the prior approval of specified authority, within one month from the end of the month in which the reply referred to in clause (c) is received by him, or where no such reply is furnished, within one month from the end of the month in which time or extended time allowed to furnish a reply as per clause (b) expires:

Provided that the provisions of this section shall not apply in a case where,-

(a) a search is initiated u/s. 132 or books of account, other documents or any assets are requisitioned u/s. 132A in the case of the assessee on or after the 1st day of April, 2021; or

(b) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner that any money, bullion, jewellery or other valuable article or thing, seized in a search u/s. 132 or requisitioned u/s. 132A, in the case of any other person on or after the 1st day of April, 2021, belongs to the assessee; or

(c) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner that any books of account or documents, seized in a search u/s. 132 or requisitioned u/s. 132A, in case of any other person on or after the 1st day of April, 2021, pertains or pertain to, or any information contained therein, 2[relate to, the assessee;

Or

(d) the Assessing Officer has received any information under the scheme notified u/s. 135A pertaining to income chargeable to tax escaping assessment for any assessment year in the case of the assessee.]

5.

It is clear from the plain reading of Clause (b) of Section 148A of the Act, that a notice u/s. 148A(b) of the Act is required to provide an opportunity to the assessee to respond to the information which may suggests that the assessee’s income has escaped assessment. The minimum period of such notice is stipulated as “not less than seven days”. In the present case, the impugned notice was issued on 20.03.2022 and the Assessee was called upon to furnish a reply on or before 25.03.2022. Indisputably, the impugned notice did not comply

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 11 :: with the requirement of providing a minimum period of seven days to respond to the said notice. 6. The impugned notice is contrary to law as rightly pointed out by the learned Single Judge.” 4. Learned counsel Sri Thirumalesh M appearing for the respondents would not dispute the position of law being affirmed by the Division Bench, as the notice was set aside by the learned single Judge.

5.

In the light of the issue being covered on all its fours to the order in the writ appeal as afore-quoted, the petition deserves to succeed on the same lines.”

10.

In the above decision, the Hon’ble High Court has relied on the decision of the Division Bench in the case of ITO v. Venkatal Ayyappa Ranjanna [2025] 178 taxmaqnn.com 410 (Kar.), where the identical issue has been considered by the Hon'ble High Court. From the combined perusal of the above judicial precedence, it is clear that where the A.O does not provide the minimum period of seven days to respond to the notice u/s. 148A(b) of the Act as provided in the said section then the impugned notice is contrary to law and the consequential proceedings are liable to be quashed. In the present case, the A.O has issued a notice u/s. 148A(b) of the Act on 21.03.2022 calling on the assessee to furnish the details by 28.03.2022. The copy of the relevant notice is extracted below:

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 12 ::

11.

From the above, it is clear that the A.O has given only less than 7 days to the assessee to respond, which is clearly contrary to the provisions u/s. 148A(b) of the Act, which provides that the minimum period of seven days should be given to the assessee to respond. Accordingly, respectfully following the above judicial precedence, we hold that the notice

ITA No. 1799/Chny/2026 (A Y 2018-19) Sivanantham Anbuselvan Vs ITO W-(1) :: 13 :: issued by the A.O u/s. 148A(b) of the Act is contrary to the law and the consequential reassessment proceedings therefore is liable to be quashed.

12.

Since, we have considered the legal contention of the assessee and allowed the appeal, the other grounds have become academic and left open accordingly.

13.

In the result, the appeal of the assessee is allowed. Order pronounced in the open court on the 14th day of October, 2026 in Chennai.

Sd/- Sd/- (एस. आर. रघुनाथा) (मनु कुमार िग�र) (S.R.RAGHUNATHA) (MANU KUMAR GIRI) लेखा सद*य/ACCOUNTANT MEMBER �या�यक सद*य/JUDICIAL MEMBER चे�नई/Chennai, SANDE Digitally signed +दनांक/Dated: 14th October 2026 by SANDEEP SNDP, Sr. PS EP KUMAR Date: KUMAR 2026.10.16 आदेश क ��त,ल-प अ.े-षत/Copy to: 17:42:36 +05'30' 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

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