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Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD
Before: SHRI WASEEM AHMED & SHRI SIDDHARTHA NAUTIYAL
आदेश/O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER:
The captioned cross appeals have been filed at the instance of the Assessee and the Revenue against the order of the Learned Commissioner of Income Tax, Ahmedabad-7, dated 21/12/2016 arising in the matter of assessment order passed under s. 143 of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Year 2012-2013.
The assessee has raised following grounds of appeal: 1. That on facts, and in law, the learned CIT(A) ought to have decided the ground regarding the addition of Rs. 3,44,07,768/- on account of cash credits on merits, instead of directing the AO to verify the documentary evidences, and decide the same. 2. That on facts, and in law, the learned CIT(A) has grievously erred in confirming the addition of Rs.50,040/- made in respect of Employee’s contribution to PF made u/s.2(24)(x) rws 36(1)(va) of the Act. 3. That on facts, and in law, the learned CIT(A) has grievously erred in confirming the addition of Rs.14,342/- made in respect of payment of commission. 4. That on facts, and in law, the learned CIT(A) has grievously erred in confirming the addition of Rs.76,819/- made in respect of payment of interest on TDS. 5. The appellant craves leave to add, alter, amend any ground of appeal.
The first issue raised by the assessee is that the learned CIT (A) erred in sustaining the addition of Rs. 3,44,07,768/- made by the AO under section 68 of the Act.
Brief facts of the case are that the assessee is a private company and engaged in the business of trading in pure ghee and food products. During the year
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under consideration, the assessee company received unsecured loan aggregating to Rs. 3,44,07,768/- from 18 persons detailed as under:
Sr.No. Name of Investor/Depositor Type of Investment Amount Received received (Rs.) 1. Anand G Keswani Un-Secured loan 2238250 2 Anand G Keswani HUF Un-Secured loan 953750 3. Hardev Das Tejpal Un-Secured loan 5344812 4. Jyoti R Punjabi Un-Secured loan 631560 5. Kalpanaben R Desai Un-Secured loan 250000 6. Karaan A. Keswani Un-Secured loan 2951250 7. Kirandevi Rula Un-Secured loan 612300 8. Kishangopal Rajpurioa Un-Secured loan 10568750 9. Kishangopal Rajpuria HUF Un-Secured loan 3337500 10 Krishnadevi Rajpuria Un-Secured loan 556250 11 Lata Gurnani Un-Secured loan 464250 12 Manish R Punjabi Un-Secured loan 383660 13 Purshottam Ruia Un-Secured loan 1284038 14. Pushpa Keswani Un-Secured loan 3633500 15. Ramesh C Punjabi Un-Secured loan 425472 16 Ramesh C. Punjabu HUF Un-Secured loan 132960 17 Vijay R Punjabi Un-Secured loan 289216 18. Vipinchand M. jain HUF Un-Secured loan 320250 Total fresh funds received including interest calculated Rs.3,44,07,768/-
4.1 The assessee, in support of genuineness of the loan, furnished the ledger copy confirmation along PAN and screen shot from IT portal of income declared by the loan parties. The assessee further submitted that the loan parties were not supporting, therefore the notice under section 133(6) of the Act should be issued to the parties if any other detail is required.
However, the AO was dissatisfied with the submission of the assessee. The AO was of the view that the documentary evidences filed by the assesse are not sufficient to hold the genuineness of loan and creditworthiness of the creditors. Thus, the AO in view of the above and after placing reliance on various case laws treated the entire amount of credit of Rs. 3,44,07,768/- from the above mentioned parties as unexplained cash credit under section 68 of the Act, and added to the total income of the assessee by holding that own unaccounted money has been received by the assesse in the guise of loan.
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Aggrieved assessee preferred an appeal before the learned CIT (A) who partly allowed the appeal of the assessee by observing as under: 4.2 1 have considered the assessment order, facts of the case and the submissions made by the appellant. A perusal of the assessment order shows that in view of limited compliance by the assessee during the assessment proceedings, the AO was not able to verify the genuineness of the transactions and identity and the creditworthiness of the depositors, in respect of the unsecured loans taken during the year. It is also seen that the appellant did not produce the required documentary evidences before the AO all through the assessment proceedings, but as late as March 2015, requested the AO to call for the required information himself u/s. 133(6) of the Act. In view of the fact that the case was getting time-barred in March and the fact that the assessee had not furnished the required evidences and explanations in respect of the deposits, the AO was left with no option but to add*the said amount to the total income of the assessee. It is however seen that during the appellate proceedings, my learned predecessor i.e. ClT(A)-8, Ahmedabad (who had the jurisdiction over this case before it was assigned to the undersigned) issued letters to the depositors calling for information u/s. 133(6) of the Act in respect of their transactions with the appellant. In response to this, some parties Tave submitted their replies along with copies of income-tax returns filed, confirmations and ledger account of the appellant. 4.2.1 In view of the above discussion, the AO is directed to verify the details submitted by the parties and allow the same, since the evidences filed now establishes the genuineness of the transactions and the creditworthy ness and the Identity of the depositors. This ground of appeal is partly allowed, subject to verification of the said documentary evidences and details by the AO.
Being aggrieved by the order of the learned CIT(A), both the Assessee and Revenue are in appeal before us. The assessee is in appeal against the direction of the ld. CIT-A wherein the claim of assessee was allowed after necessary verification instead of allowing the same whereas the revenue is in appeal against the deletion of the addition made by the AO in ITA No. 620/Ahd/2017 on the ground which reads as under: Whether the Ld.CIT(Appeal) is right in law and on facts in deleting the addition of Rs,3,44,07,768/- made account of un-explained cash credits.
The learned AR before us filed a paper book and case law compilation running from pages 1 to 315 which are available on record. According to the learned AR, all the details of the loan parties such as name and address along with PAN, Copy of ledger confirmation, Screen Shot from IT portal showing taxable income declared by them, ledger copies containing the details of the interest credited and paid to loan parties were furnished. Similarly, the assessee also requested the AO to issue notices under section 133(6) of the Act for any other detail, if required from the
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loan parties. But the AO has not issued notices to the loan parties. However, during the appellate proceedings notices under section 133(6) of the Act were issued to some of the loan parties which were duly complied with by furnishing required details. As per the learned AR, the onus cast under section 68 of the Act was duly discharged by the assessee by furnishing the details as discussed above. Accordingly, no addition of whatsoever is warranted in the hands of the assessee in the given facts and circumstances.
The learned DR before us vehemently supported the stand of the AO by reiterating the findings contained in the assessment order which we have already adverted to in the preceding paragraph. Therefore, we are not repeating the same for the sake of brevity.
We have heard the rival contentions of both the parties and perused the materials available on record. The provision of section 68 of the Act fastens the liability on the assessee to provide the identity of the lenders, establish the genuineness of the transactions and creditworthiness of the parties. These liabilities on the assessee were imposed to justify the cash credit entries under section 68 of the Act by the Hon’ble Calcutta High Court in the case of CIT Vs. Precision finance (p) Ltd reported in 208 ITR 465 wherein it was held as under: “It was for the assessee to prove the identity of the creditors, their creditworthiness and the genuineness of the transactions. On the facts of this case, the Tribunal did not take into account all these ingredients which had to be satisfied by the assessee. Mere furnishing of the particulars was not enough. The enquiry of the ITO revealed that either the assessee was not traceable or there was no such file and, accordingly, the first ingredient as to the identity of the creditors had not been established. If the identity of the creditors had not been established, consequently, the question of establishment of the genuineness of the transactions or the creditworthiness of the creditors did not and could not arise. The Tribunal did not apply its mind to the facts of this particular case and proceeded on the footing that since the transactions were through the bank account, it was to be presumed that the transactions were genuine. It was not for the ITO to find out by making investigation from the bank accounts unless the assessee proved the identity of the creditors and their creditworthiness. Mere payment by account payee cheque was not sacrosanct nor could it make a non-genuine transaction genuine.”
10.1 Now, 1st we proceed to understand the identity of the party. The identity of the party refers to the existence of such party which can be proven based on the
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evidences. As such the identity of a party can be established by furnishing the name, address and PAN detail, bank details, passport and other details of the Government agencies.
10.2 The next stage comes to verify the genuineness of the transaction. Genuineness of transaction refers what has been asserted is true and authentic. A genuine transaction must be proved to be genuine from all prospective and not merely on paper. The documentary evidences should not provide a mask to cover the actual transaction or designed in way to present the transaction as true but the same is not. Genuineness of transaction can be proved by submitting confirmation of the party along details of mode transaction but merely showing transaction carried out through banking channel is not sufficient enough. As such, the same (genuineness) should also be proved by circumstantial/ surrounding evidences as held by the Hon’ble supreme court in case of Durga Prasad More reported in 82 ITR 540 and in case of Smt. Sumati Dayal reported in 214 ITR 801.
10.3 The last stage comes to verify the creditworthiness of the parties. The term creditworthiness as per Black Law Dictionary refers as: "creditworthy, adj. (1924) (Of a borrower) financially sound enough that a lender will extend credit in the belief default is unlikely; fiscally healthy-creditworthiness.
10.4 Similarly in The New Lexicon Webster's Dictionary, the word "creditworthy" has been defined as under:- "creditworthy, adj. of one who is a good risk as a borrower."
10.5 It the duty of the assessee to establish that creditor party has capacity to advance such loan and having requisite fund in its books of account. The capacity to advance loan can be established by the showing sufficient income, capital and reserve or other fund in the hand of creditor. It is required by the AO to find out the financial strength of the creditor to advance loan with judicious approach and in accordance with materials available on record but not in arbitrary and mechanical manner.
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10.6 In the light of the above discussion, we proceed to adjudicate the issue in hand. With respect to the identity of the party, we find that the AO in his order has given categorical finding that the assessee has furnished the details such as copy of ledger confirmation along with the copy of PAN except one party namely Smt. Kalpanaben Desai from whom the assessee has taken the loan of Rs. 2,50,000.00 only. The ledger copies contain the name and address of the loan parties. From the above, there remains no doubt that the identity of the loan parties has been established by the assessee beyond doubt.
10.7 With respect to the genuineness of transaction, we note that the assessee has submitted that all the transactions were carried out through banking channel and in support, it has furnished the copy of confirmation except one party namely Smt. Kalpanaben Desai from whom the assessee has taken the loan of Rs. 2,50,000.00 only. From the ledger copies it can also be found that the assessee duly credited interest against such loan and paid to the parties except one party namely Smt. Kalpanaben Desai from whom the assessee has taken the loan of Rs. 2,50,000.00 only. Similarly, with regard to credit worthiness, the assessee submitted screen shot from the IT portal showing taxable income declared by the loan parties. The assessee submitted that the loan parties were not willing to provide other details such as bank statement and ITR. Therefore, the assessee requested the AO to issue notices under section 133(6) of the Act. But the AO without making independent inquiry or bringing any other material on record concluded that the assessee failed to discharge its onus cast under section 68 of the Act. We also note that during the appellate proceedings, the learned CIT(A) Ahmedabad has issued notices under section 133(6) and some of the parties have submitted required detail. In the given facts and circumstances, the assessee duly discharged the primary onus cast under section 68 of the Act. It was the duty of the AO to make independent enquiries based on primary document to bring contrary materials. But the AO failed to make enquiries and bring any adverse material on record.
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10.8 Be that as it may be, the undisputed fact that the assessee paid interest on loan after deducting TDS which was not doubted except one party namely Smt. Kalpanaben Desai from whom the assessee has taken the loan of Rs. 2,50,000.00 only. Thus, the Revenue accepted the amount of interest on the loan but doubted the genuineness of the impugned amount of loan. As such the stand of the Revenue is contrary to the facts on record. Thus, we can assume that the impugned transaction was the business transactions between the assessee and the loan parties. We also feel pertinent to refer the judgment of the Hon’ble Gujarat high court in case of the CIT Vs. Rohini builders reported in 256 ITR 360 wherein it was held as under: “The genuineness of the transaction is proved by the fact that the payment to the assessee as well as repayment of the loan by the assessee to the depositors is made by account payee cheques and the interest is also paid by the assessee to the creditors by account payee cheques.”
10.9 In view of the above and after considering the facts in totality, we are of the view that the assessee has discharged its onus cast under section 68 of the Act, therefore, we direct the AO to delete the addition made by him except one party namely Smt. Kalpanaben Desai from whom the assessee has taken the loan of Rs. 2,50,000.00 only. Hence, the ground of appeal of the assessee is hereby allowed whereas the ground of appeal of the Revenue is hereby partly allowed.
The next issued raised by the assessee is that the learned CIT(A) erred in confirming the addition of Rs. 50,040/- made under section 2(24)(x) of the Act on account of late payment of PF.
At the outset, we note that the issue on hand is squarely covered against the assessee by the order of the Hon’ble Jurisdictional High Court of Gujarat in the case of CIT vs. Gujarat State Road Transport Corporation India Limited reported in 366 ITR 170. However, we also note that the above referred order of the Hon’ble Gujarat High Court has been challenged before the Hon’ble Supreme Court and outcome of the same is pending. In our considered view, the issue is covered against the
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assessee at this stage and deserve to be dismissed. Thus the ground of appeal of the assessee is hereby dismissed.
The next issued raised by the assessee is that the learned CIT(A) erred in confirming the addition of Rs. 14,342/- made by the AO on account of commission expense relating to prior period.
The AO found that the assessee debited profit & loss account by Rs. 14,342/- on account of commission expense but the same was pertaining to the earlier year. The assessee failed to establish that the commission expense was crystalized during the year under consideration. Thus, the AO disallowed the same and added to the total income of the assessee.
On appeal by the assessee, the learned CIT(A) also confirmed the action of the AO by observing that the assessee has not furnished any detail of such expenses.
Being aggrieved by the order of the learned CIT(A), the assessee is in appeal before us.
The learned AR before us contended that the genuineness of the expenses was not doubted by the authorities below. Thus, it can be inferred that the expenses were incurred wholly and exclusively for the purpose of the business and therefore the same cannot be disallowed merely on the reasoning that the expense was incurred in the earlier year.
On the other hand, the learned DR vehemently supported the order of the authorities below.
We have heard the rival contentions of both the parties and perused the materials available on record. From the preceding discussion, we note that the
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genuineness of the expenses and proximity of such expenses with the business of the assessee has not been doubted by the authorities below. Thus, it can be inferred that the impugned expenses were incurred wholly and exclusively by the assessee for the purpose of its business. But the only drawback is that the same was not claimed in the year to which it pertains. However, we also note that there was no change in the rate of tax under the Act. Thus, there cannot be any loss to the revenue even if the assessee claimed such expenses in the year under consideration. In this regard we find support and guidance from the judgment of Hon’ble Bombay High Court in the case of CIT v. Nagri Mills Co. Ltd.[1958] 33 ITR 681 has held as under: "3. We have often wondered why the Income-tax authorities, in a matter such as this where the deduction is obviously a permissible deduction under the Income-tax Act, raise disputes as to the year in which the deduction should be allowed. The question as to the year in which a deduction is allowable may be material when the rate of tax chargeable on the assessee in two different years is different; but in the case of income of a company, tax is attracted at a uniform rate, and whether the deduction in respect of bonus was granted in the assessment year 1952-53 or in the assessment year corresponding to the accounting year 1952, that is in the assessment year 1953- 54, should be a matter of no consequence to the Department; and one should have thought that the Department would not fritter away its energies in fighting matters of this kind. But, obviously, judging from the references that come up to us every now and then, the Department appears to delight in raising points of this character which do not affect the taxability of the assessee or the tax that the Department is likely to collect from him whether in one year or the other.” 19.1 In view of the above and after considering the facts in totality, we are of the view that the assessee is entitled to claim the deduction of the impugned expenses. Accordingly, we set aside the order of the Ld. CIT (A) and direct the AO to delete the addition made by him. Hence the ground of Appeal of the assessee is allowed.
The next issued raised by the assessee is that the learned CIT(A) erred in confirming the addition of Rs. 76,819/- made on account of disallowance of interest paid on late payment of TDS.
During the assessment proceeding, the AO found that the assessee under the head finance cost debited an amount of Rs. 76,819/- on account of interest paid
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on TDS. The questioned was raised to explain the allowability of the same but the assesse failed to make any submission. Thus the AO disallowed the same and added to the total income of the assessee.
On appeal by the assessee, the learned CIT-A confirmed the action of the AO by observing that the assessee has conceded for the disallowance of the impugned expense.
Being aggrieved by the order of the learned CIT (A), the assessee is in appeal before us.
We have heard the rival contentions of both the parties and perused the materials available on record. In the present case, we note that the assessee itself conceded before the ld. CIT-A for the disallowance of the impugned expense. Therefore, we dismiss the ground of appeal of the assessee.
24.1 In the result, the appeal of the assessee is partly allowed.
Coming to ITA NO. 620/Ahd/2017, an appeal by the Revenue for the AY 2012-13
The Revenue has raised the following grounds of appeal: 1. Whether the Ld.CIT(Appeal) is right in law and on facts in deleting the addition of Rs,3,44,07,768/- made account of un-explained cash credits. 2. Wether the Ld.CIT(Appeal) is right in law and on facts in deleting the addition of Rs.3,00,821/- made account of un-explained advance from customers. 3. Whether the Ld.CIT(Appeals) is right in law and on facts in deleting the addition of Rs.8,46,289/- made account of on account of unexplained liabilities.
The first issue raised by the Revenue is that the learned CIT (A) erred in deleting the addition of Rs. 3,44,07,768/- made under section 68 of the Act.
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At the outset we note the issue raised by the Revenue has been adjudicated with the assessee’s ground of appeal in ITA No. 478/Ahd/2017. The issue on hand has been decided by us vide paragraph no. 11 of this order in favour of the assessee and partly in favour of the Revenue. Thus, the ground of appeal raised by the Revenue is hereby partly allowed.
The next issue raised by the Revenue is that the learned CIT (A) erred in deleting the addition of Rs. 3,00,821/- and Rs. 8,46,289/- made by the AO on account of unexplained advances from customers and unexplained liabilities.
The AO during the assessment proceedings found that the assessee in the financial statement has shown advances from customers as detailed below:
Sr.No. Name of the party Credit Balance/Advance 1. Consumer Super Market Rs.19,150/- 2. Ganesh Sales Agency Rs.17,063/- 3. Shree Shrinath Trading Rs.44,560/- company 4. Thakkar lalji pdamsinh Rs.22,239/- 5. Deep General Stores Rs.1,61,585/- 6. Shiv Enterprises Rs.36,224/- TOTAL Rs.3,00,821/-
Similarly, the assessee has shown creditors for expenses amounting to Rs. 8,46,289/- only. The AO vide SCN required the assessee to explain the amount of advance from the customers and creditors for the expenses. The assessee in response thereto submitted only ledger copies of the customers from whom the advance was claimed to have been received whereas no explanation or submission was made with regard to creditor for the expenses. Thus, the AO in absence of documentary evidence and necessary explanation, treated the amount of advances as unexplained cash credit under section 68 of the Act and also held that the liability for the expenses has ceased to exist as provided under section 41(1) of the Act. Thus, the AO added the same to the total income of the assessee.
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On appeal by the assessee, the learned CIT (A) deleted the addition made by the AO. The learned CIT(A) found that the advances from customers shown by the assessee were against the sales made to them. As the advances were not from deposit or loans liability therefore, the question of making addition of the same under section 68 does not arise.
Similarly, the assessee has not written off the liabilities against the expenses in its books of accounts. The AO has also not brought any material suggesting that the creditors for expenses have ceased to exist.
Being aggrieved by the order of the learned CIT(A), the Revenue is in appeal before us.
The learned DR and the learned AR before us vehemently supported the order of the authorities below as favourable to them by reiterating the findings contained in the respective orders.
We have heard the rival contentions of both the parties and perused the materials available on record. From the preceding discussion, we note that the AO has treated the advances from 6 parties, shown by the assessee, as unexplained cash credit under section 68 of the Act. The details of such advances from 6 parties have been detailed somewhere in the preceding paragraph. Out of the submissions made by the assessee before the learned CIT-A, we note that the assessee with respect to three parties has also shown opening credit balance in its financial statement. Likewise, there were 4 parties (including three parties as discussed above) with whom the assessee has shown regular transactions. As such, the assessee has also debited the ledgers accounts of these 4 parties on account of sales made to them but the same was not doubted by the AO. Thus, it is implied that the AO has doubted only the closing balance shown by the assessee in its financial statement as on 31st of March 2012 and believed all other transactions as genuine. Accordingly, we are of the view that the stand taken by the AO is
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unsustainable by treating the closing credit balance as unexplained and treating the transaction carried out by the assessee during the year as genuine. It is not expected from the AO to give different treatment to the various transaction carried out by the assessee. If any credit from any party is to be treated as an unexplained cash credit, then it has to be treated in the entirety and not in the piecemeal.
35.1 With respect to the party namely M/s Shiv Enterprise, we note that the credit balance shown by the assessee was relating to the earlier year. As such, the assessee has shown opening credit balance of ₹ 36,224.00 which was also shown closing balance as on 31st of March 2012. In our considered view, the opening balance carried forward from the earlier year cannot be disturbed in the year under consideration. If any doubt is there with respect to such transaction, the same can be disturbed in the year in which it was credited in the books of accounts of the assessee. In other words, the amount of ₹ 36,224.00 was not credited in the year under consideration.
35.2 With respect to the party Consume Supermarket, we find that the assessee has shown advance of ₹ 19,150.00, we find that the amount shown as an advance by the assessee was received by it through the banking channel which is evident from the copy of the ledger enclosed on page 44 of the paper book. The address of the party was also appearing in the ledger copy. But the AO before concluding the issue against the assessee, has not made any verification from the party. Admittedly, it is the primary onus upon the assessee to justify the entries shown in the financial statements based on the documentary evidence. The assessee has given the summary of the advances shown from various parties which are in dispute which is placed on page 43 of the paper book. On perusal of the same, we find that the assessee has not furnished the PAN of the party. Admittedly, the assessee has classified such advance from the party as advance against the sales but has not furnished any other detail suggesting that sale has been made by it in the later period. Accordingly, in the absence of the necessary document, we find difficult to convince ourselves that such amount represents the advance against the sales. But
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at the same time, considering the minuscule amount involved in the dispute and the fact that the amount was received through banking channel, the same cannot be assumed as unexplained cash credit under section 68 of the Act. It is for the reason that the assessee has furnished the name and address of the party, therefore the identity cannot be doubted without necessary verification which has not been done by the AO in the instant case. Likewise, the transaction was carried out through the banking channel and therefore genuineness of the transaction cannot be doubted in the instant case. Similarly, the amount of advance is of negligible value and therefore the question of creditworthiness of the party does not arise. Thus, in the given facts and circumstances, considering the minuscule amount involved in the dispute, we do not find any reason to disturb the finding of the learned CIT-A. Hence the ground of appeal of the revenue is hereby dismissed.
35.3 Coming to the next issue for the remission and cessation of liability for expenses, admittedly the assessee has not written back the impugned liabilities in the books of accounts. To attract the provisions of section 41(1) of the Act, the features of section 41(1) are given below: (i) It is applicable in respect of an allowance or deduction which has been allowed in any earlier assessment year. (ii) In any subsequent year, if the assessee obtains some benefit, whether in cash or in any other manner in respect of such loss, expenditure referred to above, it is chargeable to tax. (iii) The benefit is in respect of a trading liability by way of remission or cessation or unilateral transfer to profit and loss account by the assessee. (iv) The amount received or benefit derived shall be deemed to be the profits and gains of business or profession and is chargeable to tax as income of the previous year in which it is received. (v) This is regardless of whether the business or profession in respect of which the allowance or deduction was made originally is continued in the year of receipt of such benefit subsequently. In other words, even if the business or profession is discontinued, the benefit so received is chargeable to tax. (vi) Even successor to the business deriving such benefit has to pay tax. For example, a bad debt written off by father when it is recovered by son who succeeds to the business of the father, is liable to offer such recovery as income under section41(1).
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35.4 From the above, it is transpired that it is necessary to write back the liabilities in the books of accounts by crediting the profit and loss account. But, in the present case, the assessee has not done so, rather the assessee in the later years has discharged part of the liabilities by making payments which is evident from the submission of the assessee before the learned CIT-A on page 9 of the appellant order. Accordingly, we are of the view that the liabilities shown by the assessee against the expenses cannot be treated as income under the provisions of section 41(1) of the Act. Hence, we decline to interfere in the finding of the learned CIT-A. Thus the ground of appeal of the revenue is hereby dismissed.
35.5 In the result, the appeal filed by the Revenue is partly allowed.
In the result the appeal filed by the assessee is partly allowed whereas the appeal filed by the revenue is also partly allowed.
Order pronounced in the Court on 11/11/2022 at Ahmedabad.
Sd/- Sd/- (SIDDHARTHA NAUTIYAL) (WASEEM AHMED) JUDICIAL MEMBER ACCOUNTANT MEMBER (True Copy) Ahmedabad; Dated 11/11/2022 Manish