INCOME TAX OFFICER WARD-1 EXEMPTIONS , BANGALORE vs. M/S CENTRE FPR CELLULAR AND MOLECULAR PLATFORMS , BANGALORE

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI ARUN KUMAR GARODIA, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER

ITA No. 271/Bang/2018 Assessment Year : 2013-14 M/s. Centre for Cellular and Molecular Platforms, The Income Tax Officer (E), Post bag no. 6505, Ward -1 , Vs. G.K.V.K. P.O. Bangalore. Bellary Road, Bangalore – 560 065. PAN: AADCC8572D APPELLANT RESPONDENT Assessee by : Shri V. Srinivasan, Advocate Revenue by : Shri Ujjwal Kumar, JCIT (DR) Date of hearing : 14.08.2019 Date of Pronouncement : 28.08.2019

O R D E R Per Shri A.K. Garodia, Accountant Member This appeal is filed by the revenue and the same is directed against the order of ld. CIT(A)-2, Bangalore dated 14.09.2017 for Assessment Year 2013-14. 2. The ld. DR of revenue supported the assessment order whereas the ld. AR of assessee supported the order of ld. CIT(A). He also placed reliance on the judgement of Hon'ble Rajasthan High Court rendered in the case of CIT(E) Vs. Shree Shyam Mandir Committee as reported in [2018] 400 ITR 466 (Raj), copy available on pages 1 to 16 of the paper book. 3. We have considered the rival submissions. We find that in the present case, the issue in dispute is this whether the assessee is eligible for exemption u/s. 11 and 12 of the IT Act or not. It is noted by ld. CIT(A) on page no. 8 of his order that during the course of appellate proceedings, the assessee has raised this ground regarding benefit u/s. 11 and 12 of the IT Act and this ground was raised on 11.04.2017 for the first time. It is noted by ld. CIT(A) that report was called for from the AO and he reproduced the relevant portion of the remand report from the AO dated 07.08.2017. As per the relevant

ITA No. 271/Bang/2018 Page 2 of 11 portion of the remand report reproduced by him, it is noted that assessee has made an application for registration u/s. 12AA of the IT Act on 30.03.2016 and was granted 12AA registration by CIT(E) on 21.09.2016. It is further reported by the AO in the remand report that the provisions of sub-section 2 of section 12A clearly states that the provisions of section 11 and 12 shall apply in relation to the income of such trust or institution from the Assessment Year immediately following the financial year in which such application is made and since in the present case, the assessee has made the application for registration u/s. 12AA on 30.03.2016, the assessee can claim benefit of section 11 and 12 from A. Y. 2017-18. Before the ld. CIT(A), this was the claim of the assessee that since the registration of the assessee concern has been granted w.e.f. 21.09.2016, it comes into effect during the course of pendency of first appeal proceedings and the proviso to sub-section 2 of section 12A should be construed liberally and the assessee should be granted exemption u/s. 12A of the IT Act. The ld. CIT(A) has referred to various judicial pronouncements and held that the assessee is eligible for exemption u/s. 11 and 12 of the IT Act for the present year. Before us, reliance has been placed by the learned AR of the assessee on the judgement of Hon'ble Rajasthan High Court rendered in the case of CIT(E) Vs. Shree Shyam Mandir Committee (supra). Para nos. 7.2 to 8.5 of this judgment of Hon’ble Rajasthan High Court are relevant and hence, the same are reproduced hereinbelow for ready reference. “7.2 When section 12A of the Act was amended by introducing new provisos to sub-section (2) of s. 12A by Finance Act, 2014 with effect from 01.10.2014, the assessment orders passed by the assessing officer in respect of the present assessee were pending in appeal before the first appellate authority. During such pendency, the assessee was granted registration u/s. 12AA of the Act on 29.07.2013 w.e.f. the assessment year 2013-14. Those appeals were the continuation of the original proceedings and that the power of the Commissioner of Income-tax was co-terminus with that of the assessing officer [ADIT (Exemption) in the present case] were two well established principles of law. In view of the above and going by the principle of purposive interpretation of statues, an assessment proceeding which is pending in appeal before the appellate authority should be deemed to be 'assessment proceedings pending before the assessing officer' within the meaning of that term as envisaged under the proviso. It follows there-from that the assessee which obtained registration u/s. 12AA of the Act during the pendency of appeal was entitled for exemption

ITA No. 271/Bang/2018 Page 3 of 11 claimed u/s. 11 of the Act. 7.3. The explanatory Memorandum to Finance (No. 2) Bill, 2014 which sought to amend section 12A explains the objects and reasons for making such amendments. The explanation makes it clear that it was in order to provide relief to such trusts in respect of which, due to absence of registration u/s. 12AA tax liability got attached though otherwise they were eligible for exemption by fulfilling other substantive conditions that the amendment was brought in. That being so, denying such benefit to a trust like the assessee who had obtained registration u/s. 12AA during the pendency of the appeals filed against the orders of the assessing authority, by narrowly interpreting the term, 'pending before the assessing officer' so as to exclude its pendency before the appellate authority, will be doing violence to the provisions of the Statute and, as such, liable to be interfered with. Moreover, under the Scheme of the Act, sections 11 and 12 are substantive provisions which provide for exemptions to a religious or charitable trust. Sections 12A and 12AA detail the procedural requirements for making an application to claim exemptions under sections 11 and 12 by the assessee and the grant or rejection of such application by the commissioner. Thus, in our view, sections 12A and 12AA are only procedural in nature. Hence, it is not the registration u/s. 12AA by itself that offers immunity from taxation. A receipt whether it is revenue or capital in nature is to be decided at the assessment stage. Being procedural in nature, in our view, liberal interpretation will give effect to the intention of the amendment, thereby removing the hardship in genuine cases like the present assessee under consideration. 7.4. Taking into account the above facts and circumstances of the issue, we are of the view that the AO was not justified in taking a stand that registration u/s. 12A was not applicable to the assessee for the AYs under dispute and the condonation petition for delay in filing the application for registration u/s. 12A [for the AYs under dispute] has not yet been decided by the CBDT and, therefore, the total incomes of the assessee were to be assessed as per commercial principles. The CIT(A) was also not justified in taking a similar stand that of the AO, without taking cognizance and intention of the amendment to s. 12A of the Act. If no judicious or a liberal view is not taken either by the assessing authority or the appellate authority as in the case under consideration, the very purpose for which such an amendment to s. 12A of the Act enacted, in our view, would be defeated. We are also supported by the order of Kolkata Bench of ITAT in case of Sree Sree Ramkrishna Samity v. DCIT (ITA No. 1680/2012, order dated 09.10.2015) where it was held that amendment to Section 12A w.e.f. 01.10.2014 is retrospective. The relevant finding of the Hon'ble Kolkata Bench in case of Sree Sree Ramkrishna Samity v. DCIT (supra) read as follows: "6.10. We hold that it is an established position in law that a proviso which is inserted to remedy unintended consequences and to make the

ITA No. 271/Bang/2018 Page 4 of 11 provision workable, a proviso which supplies an obvious omission in the section and is required to be read into the section to give the section a reasonable interpretation, requires to be treated as retrospective in operation, so that a reasonable interpretation can be given to the section as a whole and accordingly the said insertion of first proviso to section 12A(2) of the Act with effect from 1.10.2014 should be read as retrospective in operation with effect from the date when the condition of eligibility for exemption under section 11 & 12 as mentioned in section 12A provided for registration u/s. 12AA as a pre-condition for applicability of section 12A." Further, the Kolkata Tribunal observed as under: "6.11. We also hold that though equity and taxation are often strangers, attempts should be made that these do not remain always so and if a construction results in equity rather than in injustice, then such construction should be preferred to the literal construction. It is only elementary that a statutory provision is to be interpreted ut res magis valeat quam pereat, i.e. to make it workable rather than redundant. Applying this legal maxim, it would be just and fair to hold that the amendment in section 12A is brought in the statute to confer benefit of exemption u/s. 11 of the Act on the genuine trusts which had not changed its objectives and had carried on the same charitable objects in the past as well as in the current year based on which the registration u/s. 12AA is granted by the DIT (Exemptions)." 7.5 In light of the aforesaid reasoning and order of the Tribunal in case of Sree Sree Ramkrishna Samity (supra), we direct the Director of Income-tax (Exemption) to grant registration to the assessee trust for all the assessment years under dispute, subject to the following conditions, namely: "i) The registration U/s. 12AA (1)(b)(i) of the Income Tax Act, 1961 does not automatically exempt the income of the Trust/Institution. The question of taxability of the income of the Trust/Institution shall be examined and decided upon by the Assessing Officer at the time of assessment based on the conduct of the activities, compliance with various statutory and other requirements, etc., as referred to in Sections 2(15), 11, 12 & 13 of the Income Tax Act, 1961, without prejudice to the fact of granting merely in principle registration by DIT(E). (ii) With effect from the Assessment Year 2009-10, the advancement of any object of general public utility other than relief of the poor, education and medical relief as defined in section 2(15) of the Income Tax Act shall not be a charitable purpose, if it involves the carrying on of any activity in the nature of trade, commerce or business, or any activity of rendering any service in relation to any trade, commerce or business, for a cess or fee or any other consideration, irrespective of the nature of use or application, or retention, of the income from such activity. (iii) Amendments to the Deed/Memorandum, Rules and Regulations, if any, of the Trust/Institution shall be made only with the prior approval of the Commissioner of Income Tax (Exemptions) or any other prescribed

ITA No. 271/Bang/2018 Page 5 of 11 authority under the Income Tax Act, 1961. (iv) The registration may be withdrawn on violation of any of the stipulations laid down in the Income Tax Act, 1961, (v) The SOCIETY/TRUST shall regularly file its Income Tax Return." 3. Allied Motors (P) Ltd. ETC. vs. Commissioner of Income Tax, (1997) 224 ITR 0677, wherein it has been observed as under:- "In the case of Goodyear India Ltd. v. State of Haryana and Anr. [1991] 188 ITR 402 (SC) this Court said that the rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge Learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have some purpose and object to accomplish whose sympathetic and imaginative discovery is the surest guide to their meaning. In the case of R.B Jodha Mai Kuthiala v. Commissioner of Income-Tax, [1971] 82 ITR 570 (SC) , TC 40R.279, this Court said that one should apply the rule of reasonable interpretation. A proviso which is inserted to remedy unintended consequences and to make the provision workable, a proviso which supplies an obvious omission in the section and is required to be read into the section to give the section a reasonable interpretation, requires to be treated as retrospective in operation so that a reasonable interpretation can be given to the section as a whole. 9. This view has been accepted by a number of High Courts. In the case of Commissioner of Income-Tax v. Chandulal Venichand [1994] 118 CTR (Guj) 257: (1994) 209 ITR 7(Guj): TC 19R.748, the Gujarat High Court has held that the first proviso to Section 43B is retrospective and sales-tax for the last quarter paid before the filing of the return for the assessment year is deductible. This decision deals with assessment year 1984-85. The Calcutta High Court in the case of Commissioner of Income-Tax v. Sri Jagannath Steel Corporation [1991]191ITR676(Cal), has taken a similar view holding that the statutory liability for sales-tax actually discharged after the expiry of the accounting year in compliance with the relevant statute is entitled to deduction under Section 43B. The High Court has held the amendment to be clarificatory and, therefore, retrospective. The Gujarat High Court in the above case held the amendment to be curative and explanatory and hence retrospective. The Patna High Court has also held the amendment inserting the First proviso to be explanatory in the case of Jamshedpur Motor Accessories Stores v. Union of India and Ors. [1991]189ITR70(Patna). It has held the amendment inserting first proviso to be retrospective. The special leave petition from this decision of the Patna High Court was dismissed. The view of the Delhi High Court, therefore that the first proviso to Section 43B will be available only prospectively does not appear to be correct. As observed by G.P. Singh in his Principles of Statutory Interpretation, 4th Edn. Page 291, "It is well settled that if a statute is curative or

ITA No. 271/Bang/2018 Page 6 of 11 merely declaratory of the previous law retrospective operation is generally intended." In fact, the amendment would not serve its object in such a situation unless it is construed as retrospective. The view, therefore, taken by the Delhi High Court cannot be sustained." 10. In the premises the appeals are allowed and the Income-tax references are answered in favour of the assessees and against the revenue. In the circumstances, however, there will be no order as to costs. 4. St. Jude's Convent School vs. Assistent Commissioner of Incoem-tax, [2017] 77 taxmann.com 173 (Amritsar -Trib.), wherein it has been observed as under:- “12. In response to this, the Id. Counsel for the assessee has contended that the assessment proceedings pending in appeal are deemed to be assessment proceedings pending before the Assessing Officer. For this proposition, the Id. Counsel has placed reliance on the decisions in the cases of SNDP Yogam v. Asstt. DIT (Exemption) [2016] 161 ITD 1/68 taxmarm.com 152 (Coch. - Trib.) and Shree Bhanushali Mitra Mandal Trust v. ITO [2016] 68 taxmann.com 250 (Ahd. Trib.). 13. The ld. DR has further submitted that in any case, the said first proviso has been inserted by Finance (No. 2) Act, 2014 w.e.f. 01-4-2014 and as such, it is not applicable retrospectively. 14. For this, the Id. Counsel for the assessee has, again, cited the decision in the case of SNDP Yogam (supra). 15. We have heard the rival contentions of both the parties with reference to the merits of the additional ground. The relevant portion of Section 12A of the Act is as follows:- "Section 12A - (1) Conditions as to registration of trusts, etc.- The provisions of section 11 and section 12 shall not apply in relation to the income of any trust or institution unless the following conditions are fulfilled, namely :- (aa) the person in receipt of the income has made an application for registration of the trust or institution on or after the 1st day of June, 2007 in the prescribed form and manner to the Principal Commissioner or Commissioner and such trust or institution is registered under section 12AA;… (2) Where an application has been made on or after the 1st day of June, 2007, the provisions of sections 11 and 12 shall apply in relation to the income of such trust or institution from the assessment year immediately following the financial year in which such application is made:

ITA No. 271/Bang/2018 Page 7 of 11 Provided that where registration has been granted to the trust or institution under section 12AA, then, the provisions of sections 11 and 12 shall apply in respect of any income derived from property held under trust of any assessment year preceding the aforesaid assessment year, for which assessment proceedings are pending before the Assessing Officer as on the date of such registration and the objects and activities of such trust or institution remain the same for such preceding Assessment year. Provided further that no action under section 147 shall be taken by the Assessing Officer in case of such trust or institution for any assessment year preceding the aforesaid assessment year only for non-registration of such trust or institution for the said assessment year". 16. Thus, as per the provisions of Section 12A, if a Trust or Institution has applied for registration on or after 016-2007 and such registration has been granted to it the provisions of Sections 11 and 12 shall not apply to its income. If the application for registration has been made on or after 01-6-2007, the provisions of Sections 11 and 12 shall apply for any assessment year preceding the assessment year immediately following the financial year in which the application for registration was made, for which year, the assessment proceedings are pending before the Assessing Officer as on the date of the registration and the objects and activities of the Trust or Institution remained the same as those on the basis of which the registration was granted, According to the second proviso to Section 12A(2), where for the assessment year immediately following the financial year. In which the application for registration was made, the Trust or Institution is not registered, no action u/s. 147 shall be taken for any assessment year preceding the said assessment year. 17. The first issue before us is as to whether the two provisos to Section 12A(2) are applicable to all the appeals before us, respectively, as contended by the Id. Counsel for the assessee, or whether, since the provisos have been brought in w.e.f. 01-10-2014 and they have not been made applicable, retrospectively, the same are not applicable for earlier periods, as submitted by the department. 18. Now, a bare reading of the first proviso to Section 12A(2) shows that it has not been made applicable retrospectively. It has been inserted in the Act w.e.f. 0110-2014, by virtue of the Finance (No. 2) Act, 2014. Thus, ordinarily, it ought to be taken as applicable only prospectively, and not retrospectively. However, the law is well settled to the effect that if the proviso brought in as a procedural or beneficial one, intending to remove hardship, it is applicable retrospectively. 19. In C.B. Richards Ellis Mauritius Ltd. v. Asstt. DIT [2012] 208 Taxman 322/21 taxmann.com 535 (Delhi) (copy on record), it has been

ITA No. 271/Bang/2018 Page 8 of 11 held that "procedural law, when amended" or substituted, is generally retrospective and applies from the date of its enforcement and to this extent, it can be retrospective". 20. In Allied Motors (P.) Ltd. v. CIT [1997] 224 ITR 677/91 Taxman 205 (SC), it has been held that a proviso, which is intended to intended to remedy unintended consequences and to make the provision workable, a proviso which supplies an obvious omission in the section and is required to be read into the section to give the section a reasonable interpretation, is required to be treated as retrospective in operation, so that a reasonable interpretation can be given to the section as a whole. It is, thus, trite that if a provision is curative or merely declaratory of the previous law, retrospective operation thereof is generally intended. 21. In CIT (Central) v. Vatika Township (P.) Ltd. [2014] 367 ITR 466/227 Taxman 121/49 taxmann.com 249 (SC), the Constitutional Bench of the Hon'ble Supreme Court held that "if a legislation confers a benefit on some persons but without inflicting a corresponding detriment on some other person or on the public generally, and where to confer such benefit appears to have been the legislators' object, then the presumption would be that such a legislation, giving it a purposive construction, would warrant it to be given a retrospective effect." 22. In Government of India v. Indian Tobacco Association [2005] 7 SCC 396, the doctrine of fairness was held to be a relevant factor to construe a statute conferring a benefit, in the context of it to be given a retrospective operation. 23. In Vijay v. State of Maharashtra [2006] 6 SCC 286, the Hon'ble Supreme Court went to the extent of holding that "where a law is enacted for the benefit of the community as a whole, even in the absence of a provision, the statute may be held to be retrospective in nature." 24. Now, undeniably, the assessment of Income is a matter of procedure. Even the heading of Chapter (xiv) of the Act, which deals with assessment itself is "PROCEDURE FOR ASSESSMENT". Likewise, grant of registration is also a procedural aspect since registration is but a step-in- aid for exemption u/s. 11. As such, the provisos to Section 12A (2) are also procedural. 25. So far as regards the bringing in of the first proviso to Section 12A (2), the Memorandum explaining the provisions of the Finance (No. 2) Bill, 365 ITR (Statute) 175 itself elaborates the intention of the Legislature behind insertion thereof in the statute book. It states, inter alia, that non-application of registration for the period prior to the year of registration causes genuine hardship to charitable organizations. Due to absence of registration, tax liability gets attached even though they may otherwise be eligible for exemption and fulfil the other

ITA No. 271/Bang/2018 Page 9 of 11 substantive conditions. The power of condonation of delay is not available under the section. In order to provide relief to such Trusts and remove hardship in genuine cases, it is proposed to amend Section 12A of the Act to provide that in a case where a Trust or Institution has been granted registration u/s. 12AA of the Act, the benefit of Sections 11 and 12 shall be available in respect of any income derived from property held under Trust in any assessment proceedings for any earlier assessment year, which is pending before the Assessing Officer as on the date of such registration, if the objects and activities of such Trust or Institution in the relevant earlier assessment year are the same as those on the basis of which such registration has been granted. 26. Thus, clearly, the provisions of Section 12A of the Act entailed unintended consequences of non-application of registration for the period prior to the year of registration and, thereby, non-grant of exemption u/ss. 11 and 12 up to grant of registration. This position was also recognized by the CBDT while issuing the Explanatory Notes to the provisions of the Finance (No. 2) Act, 2014, vide CBDT circular No. 1 of 2015 : dated 21/1/2015. It was this anomaly, which was cured by bringing in the first proviso to Section 12A (2), This proviso, even as avowed by the above quoted Memorandum explaining the provisions of the Finance (No. 2) Bill, has sought to remedy the said unintended hardship visiting Trusts and Institutions. It has supplied the aforesaid omission in the section and has thereby made the provision of the section workable, providing a reasonable interpretation to it by providing the benefit mandated by it. It is, thus, a curative proviso, which is but merely declaratory of the previous law. It has, by removal of the hardship, rendered the procedure more relief-oriented. It adequately complies with the natural justice principle of fairness to all. Hence, it has to be presumed and construed as retrospective in nature, in order to give the section a purposive interpretation. 27. In Sree Sree Ramkrishna Samity v. Dy. CIT 120161 156 ITD 646 : [2015] 64 taxmann.com 330 (Kol.), the above position has elaborately been considered to hold the first proviso to Section 12A(2) to be retrospectively applicable. The said decision has been followed in SNDP Yogam (supra). 28. In view of the above discussion and respectfully following these decisions, in the absence of any decision to the contrary having been cited before us by the department, we hold that the first proviso to section 12A (2) of the Act is applicable retrospectively. 29. Likewise, for the same reasoning, it is also held, regarding the second batch of appeals, that even the second proviso to Section 12A (2) is retrospective in nature and the completed assessments in these cases ought not to have been reopened only for non-registration for the relevant assessment years. 30. This brings us to the next question, i.e., whether the assessment

ITA No. 271/Bang/2018 Page 10 of 11 proceeding "pending before the Assessing Officer", as stated in the first proviso to Section 12A(2) can be taken as "pending in appeal", or, in other words, whether proceedings pending in appeal can be taken to be proceedings pending before the Assessing Officer. This issue also stands answered in favour of the assessee by Shree Bhanushali Mitra Mandal Trust (supra), wherein, it was held that appeal is a continuation of the original proceedings and assessment proceedings pending before an appellate authority should be deemed to be "assessment proceedings pending before the Assessing Officer" within the meaning of Section 12A. SNDP Yogam {supra), is to the same effect. Again, no contrary decision has been brought to our notice. Accordingly, it is held that the appellate proceedings before the appellate authorities are deemed to be assessment proceedings pending before the Assessing Officer. 31. In all these cases, the impugned orders were passed after the respective dates of grant of registration. Thus, we hold that subsequent grant of registration in all these cases operates retrospectively for all the relevant years under consideration." 5. CBDT Circular No. 1/2015, dated 21.1.2015, reads as under:- "8.1 The provisions of section 12A of the Income-tax Act, before amendment by the Act, provided that a trust or an institution can claim exemption under sections 11 and 12 only after registration under section 12AA of the said Act has been granted. In case of trusts or institutions which apply for registration after 1st June, 2007, the registration shall be effective only prospectively. 8.2 Non-application of registration for the period prior to the year of registration caused genuine hardship to charitable organisations. Due to absence of registration, tax liability is fastened even though they may otherwise be eligible for exemption and fulfil other substantive conditions. However, the power of condonation of delay in seeking registration was not available. 8.3 In order to provide relief to such trusts and remove hardship in genuine cases, section 12A of the Income-tax Act has been amended to provide that in a case where a trust or institution has been granted registration under section 12AA of the Income-tax Act, the benefit of sections 11 and 12 of the said Act shall be available in respect of any income derived from property held under trust in any assessment proceeding for an earlier assessment year which is pending before the Assessing Officer as on the date of such registration, if the objects and activities of such trust or institution in the relevant earlier assessment year are the same as those on the basis of which such registration has been granted. 8.4 Further, it has been provided that no action for reopening of an assessment under section 147 of the Income-tax Act shall be taken by the Assessing Officer in the case of such trust or institution for any assessment year preceding the first assessment year for which the

ITA No. 271/Bang/2018 Page 11 of 11 registration applies, merely for the reason that such trust or institution has not obtained the registration under section 12AA for the said assessment year. 8.5 However, the above benefits would not be available in the case of any trust or institution which at any time had applied for registration and the same was refused under section 12AA of the Income-tax Act or a registration once granted was cancelled." 4. We find that in this case also, it is noted by Hon’ble Rajasthan High Court that registration was granted to the assessee u/s. 12AA of the IT Act on 29.07.2013. Under these facts, it was held by Hon’ble Rajasthan High Court that appeal is continuation of original assessment proceedings and proceedings before appellate authorities is covered by the proviso to sub- section 2 of section 12A of the IT Act. In the present case also, the facts are similar and hence, respectfully following this judgment of Hon’ble Rajasthan High Court, we decline to interfere in the order of ld. CIT(A). 5. In the result, the appeal filed by the revenue is dismissed. Order pronounced in the open court on the date mentioned on the caption page.

Sd/- Sd/- (PAVAN KUMAR GADALE) (ARUN KUMAR GARODIA) Judicial Member Accountant Member Bangalore, Dated, the 28th August, 2019. /MS/ Copy to: 1. Appellant 4. CIT(A) 2. Respondent 5. DR, ITAT, Bangalore 3. CIT 6. Guard file By order

Assistant Registrar, Income Tax Appellate Tribunal, Bangalore.