SRI MARKANDEYA MAHARSHI PADMASHALI GURUPEETA MAHA SAMSTHANA ,BANGALORE vs. THE INCOME TAX OFFICER (EXEMPTION) WARD-3, BANGALORE

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE

BEFORE SHRI N. V. VASUDEVAN, VICE PRESIDENT AND SHRI JASON P BOAZ, ACCOUNTANT MEMBER

ITA Nos.274 and 277/Bang/2017 Assessment years : 2011-12 and 2012-13 M/s. Sri Markandeya Vs. The Income-tax Officer MaharshiPadmashali Gurupeeta (Exemptions), Maha Samsthana, Ward – 3, The Embassey, Bangalore. Plot No.l21, 15, Ali Asker Road, Bangalore – 560 052. PAN: AAKTS 3136 K APPELLANT RESPONDENT

Appellant by : Shri. V. K. Gurunathan, Advocate Respondent by : Shri. R. N. Siddappaji, Addl. CIT

Date of hearing : 02.01.2019 Date of Pronouncement : 06.02.2019

O R D E R Per Jason P Boaz, Accountant Member These two appeals by the assessee are directed against the orders of the CIT(A)-14, LTU, Bangalore, dated 25.11.2016, for Assessment Year 2011-12 and 2012-13. Since common issues are involved, these appeals were heard together and we therefore deem it appropriate to dispose off the same by way of this consolidated order.

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2.1 The assessee-trust, established on 22.11.2011, filed its return of income for Assessment Year 2011-12 on 18.01.2012 declaring income of Rs.3,180/- and for Assessment Year 2012-13 on 31.07.2012 declaring NIL income, after claiming that receipts from voluntary corpus donations are exempt from taxation; by claiming application towards charitable towards purposes for furtherance of its objects by purchase of lands. On the basis of information received, that the assessee trust has received corpus donations amounting to Rs.1,00,005/- and Rs.53,68,855/- from various donors for purchase of lands in the period relevant to Assessment Years 2011-12 and 2012-13 respectively, and since the assessee trust, being granted registration under section 12A of the Income Tax Act, 1961 (in short ‘the Act’), only on 8.11.2013, was not eligible for exemption in these two Assessment Years under consideration, the Assessing Officer (‘AO’) initiated proceedings u/s 147 of the Act and after recording that he had reason to believe that income of the assessee exigible to tax had escaped assessment, issued notices under section 148 of the Act. In response thereto, the assessee submitted that the returns of income filed for Assessment Year 2011-12 and 2012-18 be treated as returns filed in response to notices issued under section 148 of the Act. The AO did not accept the assessee’s contentions that the corpus donations are in the nature of capital receipts and are not exigible to tax, irrespective of whether registration under section 12A of the Act is available or not. Relying on

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section 12A(2) of the Act, the AO held that since the assessee was granted registration under section 12A of the Act only on 8.11.2013, exemption under section 11 of the Act could be granted only from Assessment Year 2014-15 and not for Assessment Years 2011-12 and 2012-13; i.e., the Assessment Years under consideration. The assessments were accordingly completed under section 143(3) r.w.s. 147 of the Act vide separate orders dated 27.03.2015, wherein the assessee’s income was determined at Rs.1,03,185/- for Assessment Year 2011-12 and Rs.53,68,855/- for Assessment Year 2012-13; by including therein the corpus donations received in each of those years.

2.2 Aggrieved by the orders of assessment dated 27.03.2015 for Assessment Years 2011-12 and 2012-13, the assessee preferred appeals before the CIT(A)-14, LTU, Bangalore, which were dismissed vide the impugned orders dated 25.11.2016.

3.1 Aggrieved by the orders of CIT(A)-14, LTU, Bangalore, dated 25.11.2016 for Assessment Years 2011-12 and 2012-13, the assessee has filed these appeals before the Tribunal wherein it has raised identical grounds. We, therefore, extract hereunder only the grounds raised by the assessee in Assessment Year 2011-12:

The order of the learned Commissioner of Income-tax (A) which 1. was passed on mere suspicious and surmises is opposed to law and accordingly liable to be set aside and the claim of the appellant ought to have been allowed.

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The learned Commissioner (A) in the interest of natural justice 2. ought to have given an opportunity to the appellant to prove the identity of the donors to whom the receipts have been issued before concluding that the donations were unproved by ignoring the receipts to deny the benefit to the appellant as claimed u/s.11 of the Act. The learned Commissioner (A) ought to have appreciated that the 3. claim of the appellant for the exclusion of the income u/s.11 of the Act in respect of corpus donations was in accordance with law and the appellant was entitled to the exclusion as claimed irrespective of the facts that the registration u/s.12A was granted with effect from A.Y 2014-15.

The learned Commissioner (A) ought to have appreciated that the 4. case law cited squarely support the claim of the appellant and consequently the denial of benefit of exemption u/s.11 and including the corpus donation as part of the income of the appellant for the relevant year was opposed to law and the impugned addition as made is liable to be deleted in toto.

Without prejudice, the addition is excessive, arbitrary and 5. unreasonable and liable to be deleted in toto.

For these and other grounds that may be urged at the time of 6. hearing of the appeal the appellant prays that the appeal may be allowed.

3.2 The learned AR for the assessee was heard in support of the grounds raised. The learned AR also field paper books containing copy of Registration Certificate under section 12A r.w.s. 12AA(1)(b)(ii) of the Act dated 8.11.2013, copy of Trust Deed dated 22.01.2011 and other details;

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including copies of certain judicial pronouncements. It was submitted that the genuineness of the voluntary corpus donations received by the assessee during the period relevant to Assessment Years 2011-12 and 2012-13 (i.e., the period under consideration), for the specific purpose of purchase of land for the purpose of furtherance of its objects, were never doubted by the authorities below. According to the learned AR, the AO disallowed the same only on the ground that since the assessee was granted registration under section 12A of the Act w.e.f. 08.11.2013, it would be entitled to exemption under section 11 of the Act only for and from Assessment Year 2014-15. The learned AR further contended that voluntary corpus donations received by the assessee for a specific purpose, as in the case on hand, cannot be regarded as income, as they do not fall within the ambit of the provisions of Section 2(24)(iia) of the Act. It is submitted that the principles relating to capital versus revenue have to be borne in mind and capital receipts cannot be treated as income. The learned AR contends that the voluntary corpus donations received for specific purposes are capital receipts and therefore entitled for exemption under section 11 of the Act. In this regard, the assessee, inter alia, placed reliance on the decision of a Co-ordinate Bench in the case of ITO Vs. Vokkaligara Sangha in ITA Nos.281 to 285/Bang/2014 dated 14.08.2015, which it submits being on similar facts as the case on hand, would cover the issue squarely in favour of the assessee.

3.3 Per contra, the learned DR for Revenue supported the orders of the authorities below. According to the learned DR, the assessee trust has

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secured registration under section 12AA of the Act only on 18.11.2013 and therefore was entitled for exemption in respect of voluntary corpus donation/contributions only w.e.f. Assessment Year 2014-15. Therefore the voluntary corpus donations/contributions received by it for purchase of lands in furtherance of its objects in the period relevant to Assessment Years 2011-12 and 2012-13, are not eligible for exemption under section 11 of the Act. It was prayed that the impugned orders of the authorities below be upheld.

3.4.1 We have heard the rival contentions and perused and carefully considered the material on record; including the judicial pronouncements cited and placed reliance upon. Firstly, we would like to consider the legal position with regard to the voluntary contributions urged by the parties. The case of the assessee before the authorities below was that the voluntary corpus donations/ contributions received by it was for the specific purpose of purchase of land for furtherance of its objectives. In short, the assessee has pleaded that the amount received by the assessee was a tied up grant or an amount received for a specific purpose as being capital in nature. In support of this proposition, the assessee has cited / placed reliance on several decisions of various benches of the ITAT and specifically in the case of ITO Vs. Vokkaligara Sangha of the Bangalore Bench of ITAT (supra), wherein it

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has been held that voluntary contributions / corpus donations received for specific purposes cannot be considered as income.

3.4.2 We find that in similar factual circumstances as the case on hand, a Co-ordinate Bench of this Tribunal in the case of ITO Vs. Vokkaligara Sangha in its order in ITA No.281 to 285/Bang/2014 dated 14.08.2015 has held that voluntary contributions received for a specific purpose cannot be regarded as income under section 2(24)(iia) of the Act since they are capital receipts to be utilised for specific purpose; and in this context at paras 5.3.1 to 5.3.5 of the aforesaid order, the Co-ordinate Bench has held as under:

“5.3.1 We have heard the rival contentions and perused and carefully considered the material on record; including the judicial pronouncements cited and placed reliance upon. Firstly, we would like to consider the legal position with regard to the voluntary contributions urged by the parties. The case of the assessee before the authorities below was that the voluntary contributions received by it was for the specific purpose of construction of a 'Kalyan Mantap'. In short, the assessee has pleaded that the amount received by the assessee was a tied up grant or an amount received for a specific purpose as being capital in nature. In support of this proposition, the assessee has cited / placed reliance on several decisions of various benches of the ITAT, wherein it has been held that voluntary contributions received for specific purposes cannot be considered as income. 5.3.2 In the case of J.B. Educational Society V ACIT reported in 159 TTJ 234 (Hyd), the Hyderabad Bench of the Tribunal followed an earlier decision of the Hyderabad Bench in the case of Society for Integrated Development in Urban and Rural Areas reported in 90 ITD 493 (Hyd) wherein the Tribunal followed the order of another co- ordinate bench in the case of Nirmal Agricultural Society (2000) 67 TTJ (Hyd) and recorded the observations therein which were as under :-

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"24. Coming to the second limb of the argument of the learned counsel for the assessee that the entire receipts cannot be taxed, we find that the issue is covered by the judgment of this Bench in Nirmal Agricultural Society v. ITO, 71 ITD 152. In that case, it has been held (as per head note) as under:- ITA Nos.281 to 285/Bang/2014 M/s. Vokkaligara Sangha. "The assessee had not been granted registration under Section 12A, as the Commissioner thought it fit to refuse to condone the long delay caused by the assessee in applying for the registration. Therefore, the Assessing Officer had no other option but to complete the assessments in the status of AOP also closing his eyes towards Section 11 and Section 13. To that extent, the Assessing Officer was right as he had acted only according to will of law. But as far as the contents of the assessments were concerned, even when the assessee had been assessed as AOP and deprived of Section 11 benefits, the Assessing Officer could assess only net income of the assessee and not gross receipts. As far as the assessee was concerned, construction of houses, reclamation of land, etc., were part of its regular activities. Houses were built on the land of poor agriculturists. The assessee-society had no legal title or right over the land or houses of those villagers/ agriculturists who were the beneficiaries. The purpose and activity of the assessee-society was to engage in such charitable activities. Whatever amount had been spent on those programmes/projects, it was spent in the usual course of carrying on its acclaimed objects. Therefore, there was no basis whatsoever, factual or legal, to hold that the amounts spent by the assessee in constructing houses or reclaiming land were capital expenditure. As far as the assessee was concerned, those expenses were revenue expenses. The assessee had no right or title over those properties. Those expenses were incurred as part of its normal activities for which the society was formed. Therefore, the money spent by the assessee- society in constructing houses, reclaiming the land, for non-formal education, etc., had to be allowed as deduction in the computation of income. The grants received from foreign donor were for specific purposes. The grants which were for specific purposes did not belong to the assessee-society; such grants did not form corpus of the assessee or its income. Those grants were not donations to the assessee so as to bring them under the purview of Section 12. Voluntary contributions covered by Section 12 are those contributions freely available to the assessee without any stipulation, which the assessee can utilise towards its objectives according to its own discretion and judgment. Tied-up grants for a specified purpose would only mean that the

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assessee which was a voluntary organisation, had agreed to act as a trustee of a special fund granted by donor with the result that it need not be pooled or integrated with the assessee's normal income or corpus. In the instant case, the assessee was acting as an independent trustee for that grant, just as same trustee could act as a trustee of more than one trust. Tied- up amount need not, therefore, be treated as amounts which were required to be considered for assessment for ascertaining the amount expended or the amount to be accumulated. The assessee should have actually credited the grant in the personal account of the donor and any amount spent against that grant should have been debited to that separate account of the donor. That incoming and outgoing need not be reflected in the income and expenditure account of the assessee. At the end of the project, the balance, if any, available to the credit of the donor, could be treated as income of the assessee, if the donor did not insist for the repayment of the balance amount. Therefore, the Assessing Officer was to be directed to redo the assessment on the following lines. (1) The tied-up grants received from the donor, Bread for the World, will be taken out of the computation of income from the income-side. (2) All the money spent under the tied-up programmes directed by the donor also will be taken out of the computation of income from the expenses-side. (3) Any non-refundable credit balance in the personal account of Bread for the World will be treated as income in the year in which such non- refundable balance was ascertained. (4) The expenses incurred by the assessee for house construction, reclamation of land, non-formal education programme (other than covered by the tied-up grants) will be deducted as revenue expenses." 25. Honourable Rajasthan High Court in the case of Sukhdeo Charity Estate (supra) held as follows (as per head note):- "It was for the specific purpose of implementation of the water supply scheme that the request for contribution had been made by the assessee-trust and it was in response to that request that the amount had been given by the Calcutta trust. It was clear that the intention of the donor and the donee was to treat the money as capital to be spent for the water supply scheme. The fact that the amount had not been paid over to the State Government and was kept

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unutilised in the account of the assessee-trust was not relevant. The amount could not be said to be "income" and could not be included as part of the assessable income of the trust under the provisions of Section 12(2)." In Yet another judgment in the case of Sukhdeo Charity Estate (supra), the Honourable Rajasthan High Court held as follows (as per head note):- "The intention of the donor-trust as well as the donee-trust was to treat the money as capital to be spent for the Ladnu Water Supply Scheme. It was of no significance whether the amount had since been paid to the State Government or kept in the account of the said scheme by the assessee-trust. The amount of Rs. 70,000/- did not constitute income of the petitioner. The reassessment proceedings were not valid and were liable to be quashed." This Bench of the Tribunal in the case of Arya Vysya Abhyudaya Sangham (supra) for asst. year 1998-99, in its order dated 25-6-2002 to which one of us was a party, was inclined to uphold the view of the Commissioner (Appeals) in that case by holding in para 15 of that order as follows: "Though we find considerable force in the other argument of the assessee's counsel i.e. the income should be computed on commercial principles, as we have held that the assessee-society is eligible for exemption Under Section 11 of the Act and as we have also held that the objects of the society were of charitable nature within the meaning of Section 2(15) of the Act, and as we have further held that there is no violation, whatsoever of the provisions of Section 13(1)(c) and (d) of the I.T. Act, 1961, the other grounds of the assessee need not be gone into, as it would be of academic interest only." The Revenue has not brought to our notice any judgment from any High Court which has dealt at length on this issue and which is in its favour. It is also not clear whether the Revenue has accepted or gone on appeal against the judgment of this Bench in the case of Nirmal Agricultural Society (supra). 26. Honourable Andhra Pradesh High Court in the case of Chairman, Andhra Pradesh Welfare Fund v. CIT, as per head note, held as follows:- "(i) That the finding of the Tribunal, that the assessee could not be regarded as a branch or as a part of the parent body, was a finding of fact and no question of law arose for reference. (ii) That the mere fact that the rice millers paid contributions with an oblique motive would not affect the character of the contributions, as voluntary contributions.

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(iii) That the finding of the Tribunal, that the assessee was not entitled to exemption as a trust under Section 12 because some of the funds were being utilised for purposes other than charitable and religious was a finding of fact and no question of law arose for reference." This judgment was relied upon by the Reference. A careful reading of this judgment does not indicate that the question raised by the assessee before us was posed to the court. We do not feel that this is a precedent for laying down a proposition of allowability of expenditure for computation of income of a charitable institution which is denied benefit Under Section 11. Honourable Supreme Court in the case of Goodyear India Ltd. v. State of Haryana (1991) 188 ITR 402 (SC), as per head note, held as follows: "Precedent -- Authority only for what it decides - Not for what may remotely or even logically follows - Decision on question not argued cannot be treated as precedent." Thus, the judgment of Honourable Andhra Pradesh High Court (supra) does not help the case of the Revenue. 27. On other hand, learned authors Chaturvedi and Pithisaria in their book Income Tax Law, Fifth edition, Vol.1, at page 424, under the heading "Income, when falls into the tax net", observed as follows:- "Although Section 14 of the 1961 Act classifies income under six heads, the main charging provision is Section 4(1) which levies income-tax, as only one tax, on the "total income" of the assessee as defined in Section 2(45) of that Act. AO income in order to come within the purview of that definition must satisfy two conditions. Firstly, it must comprise the "total amount of income referred to in Section 5". Secondly, it must be "computed in the manner laid down in this Act". If either of these conditions fails, the income will not be a part of the total income that can be brought to charge [CIT v. Harprasad & Co. P. Ltd., (1975) 99 ITR 118, 125 (SC)]". 28. As argued by the Revenue, though by virtue of Section 2(24)(iia) voluntary contributions are income, to our mind this by itself does not entitle the tax gatherer to ignore all other well settled principles of taxation and general law and levy tax on gross receipts without considering the claim for deductions. Principles such as capital versus revenue, doctrines of overriding title, form versus substance, interpretation of "deeming" provisions etc., have to be applied wherever necessary. Only the surplus or profit can be brought to tax and the same has to be computed in the manner laid down in the Act applying the normal principles of accountancy and taxation laws.

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simultaneously with the present section 12, both of which were introduced from the said date by Finance Act, 1972. Section 12 makes it clear by the words appearing in parenthesis that contributions made with a specific direction that they shall form part of the corpus of the trust or institution shall not be considered as income of the trust. The Board circular No. 108 dated 20.3.1973 is extracted at page 1754 of Volume I of Sampath Iyengar Law of Income-tax (10th Edition), in which the interrelation between sections 12 and 2(24) has been brought out. Gifts made with clear direction that they shall form part of the corpus of the religious endowment can never be considered as income. In the case of R.B. Shreeram Religious and Charitable Trust v. CIT (172 ITR 373) (Bom) the Hon'ble High Court held that even ignoring the amendment to section 12, which means that even before the words appearing in parenthesis in the present section 12, it cannot be held that voluntary contributions specifically received towards corpus of the trust may be brought to tax. The aforesaid decision was followed by the Bombay High Court in the case of CIT vs. Trustees of Kasturbai Scindia Commission Trust (189 ITR 5) (Bom). In the present case donations being received for specific purpose, towards corpus of the trust, cannot be assessed as income of the assessee. 61. Same view was taken in the case of Shri Dwarakadeesh Charitable Trust vs. ITO (98 ITR 557), DCIT vs. Nasik Gymkhana (77 ITD 500), ITO vs. M/s. Gaudiya Granth Anuved Trust in ITA No. 386/Agra/2012 order dated 2.8.2013, Penta Software Employees Welfare Foundation vs. ACIT in ITA Nos. 751-752/Mds/2007 and DIT (Exemptions) & Anr. vs. Sri Belimath Mahasamsthana Socio, Cultural and Educational Trust (336 ITR 694) (Kar). 62. Further, we have also carefully gone through the order of the Tribunal in the case of Nirmal Agricultural Society vs. ITO (71 ITD 152) relied on by the DR. Specifically paragraphs 9 to 12 of that order support the case of the assessee rather than the Revenue. For clarity, we reproduce the said paragraphs as under: "9. But as far as the contents of the assessments are concerned, we find much force in he contentions advanced by the assessee. Even when the assessee has been assessed as AOP deprived of s. 11 benefits, the AO could assess only net income of the assessee and not gross receipts. As far as the assessee is concerned, construction of houses, reclamation of land, etc., are part of its regular activities. Houses are built on the land of poor agriculturists. The assessee-society has no legal title or right over the land or houses of those villagers/ agriculturists who are the beneficiaries.

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The purpose and activity of the assessee-society is to engage in such charitable activities. Whatever amount has been spent on those programmes/ projects, they were spent in the usual course of carrying on its acclaimed objects. Therefore, there is no basis whatsoever, factual or legal, to hold that the amounts spent by the assessee in constructing houses or reclaiming land are capital expenditure. As far as the assessee is concerned, those expenses are revenue expenses. The assessee has no rig ht or title over those properties. Those expenses were incurred as part of its normal activities for which the society was formed. Therefore, the money spent by the assessee-society in constructing houses, reclaiming the land, for non-formal education, etc., has to be allowed as deduction in the computation of income. 10. The grants received from Bread for the World were for specific purposes. The grants which are for specific purposes do not belong to the assessee- society. Such grants do not form corpus of the assessee or its income. Those grants are not donations to the assessee so as to bring them under the purview of s. 12 of the Act. Voluntary contributions covered by s. 12 are those contributions freely available to the assessee without any stipulation which the assessee could utilise towards its objectives according to its own discretion and judgment. Tied-up grants for a specified purpose would only mean that the assessee, which is a voluntary organisation, has agreed to act as a trustee of a special fund granted by Bread for the World with the result that it need not be pooled or integrated with the assessee's normal income or corpus. In this case, the assessee is acting as an independent trustee for that grant, just as same trustee can act as a trustee of more than one trust. Tied- up amounts need not, therefore, be treated as amounts which are required to be considered for assessment, for ascertaining the amount expended or the amount to be accumulated. 11. The assessee should have actually credited that grant in the personal account of the donor, Bread for the World and any amount spent against that grant should have been debited to that separate account of the donor. That incoming and outgoing need not be reflected in the income and expenditure account of the assessee. At the end of the project, the balance, if any, available to the credit of Bread for the World, the donor, could be treated as income of the assessee, if the donor did not insist for the repayment of the balance amount. 12. Therefore, in the light of the examination of the facts of the case, we direct the AO to redo the assessments in the following lines: (1) The tied-up grants. received from the donor, Bread for the World, will be taken out of the computation of income from the income side.

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(2) All the money spent under the tied-up programmes directed by the donor also will be taken out of the computation of income from the expense side. (3) Any non-refundable credit balance in the personal account of Bread for the World will be treated as income in the year in which such non- refundable balance was ascertained. (4) The expenses incurred by the assessee for house construction, reclamation of land, non-formal education programme (other than covered by the tied-up grants) will be deducted as revenue expenses. " 63. Being so, as seen from the above order of the Tribunal the amount received by the assessee for specific purpose would only mean that the assessee agreed to act as a trustee of a special fund granted by assessee's trustees/members or associated persons. As a result it need not be pooled or integrated with the assessee's normal income or corpus. The assessee is acting as an independent trustee for that amount received from the assessee's trustees/members just as some trustee can act as a trust for more than one trust. Tied up or specific grant need not, therefore, be treated as amounts which are required to be considered for assessment. In other words, tied up grant received from donors for a specific purpose cannot form part of assessee's income. 64. In view of the above discussion, we are of the opinion that voluntary contributions in the nature of tied up grant received by the assessee cannot be brought to tax even the trust is not registered u/s. 12AA of the Act. The tied up donations received by the assessee should not be taxable as income of the assessee, if it is used for specific purpose for which it has been given and it cannot be considered as revenue receipts so as to tax the same......." 5.3.4 In coming to the aforesaid conclusion the Hyderabad Bench of the ITAT has also relied upon the decisions of the ITAT, Delhi Bench in the case of Smt. Basanthi Devi (supra) and Sri Chakhan Lal Garg Education Trust (supra) and in the case of Gaudiya Granth Anved Trust (supra) wherein similar issue raised has been considered by both the Delhi and Agra Benches of the ITAT. We also find that the Hon'ble Delhi High Court in the case of Basanti Devi & Sri Chakhan Lal Garg Education Trust vide its order in ITA No.927/09 dt.23.9.2009 has also affirmed the view taken by the Hon'ble ITAT in holding that corpus donations cannot be regarded as income under Section 2(24)(iia) of the Act. 5.3.5 Following the above decisions of the Tribunal (supra), relied upon by the assessee, we hold that voluntary contributions received for a specific

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purpose cannot be regarded as income under Section 2(24)(iia) of the Act since they are capital receipts and tied up grants for specific purpose.”

3.4.3 Respectfully following the decision of the Co-ordinate Bench of this Tribunal in the case of ITO Vs. Vokkaligara Sangha in ITA Nos.281 to 285/Bang/2014 dated 14.08.2015; where we find the factual matrix therein to be similar to that of the case on hand and the decision therein squarely applicable to the instant case, we hold that the voluntary corpus donations / contributions received by the assessee in the periods under consideration (i.e., Assessment Years 2011-12 and 2012-13) for the specific purpose of purchase of lands for furtherance of the assessee’s objects cannot be regarded as income under section 2(24)(iia) of the Act since they are capital receipts for specific purpose.

Pronounced in the open court on 06.02.2019.

Sd/- Sd/- Sd/- (N. V. VASUDEVAN) (JASON P BOAZ) Vice President Accountant Member Bangalore. Dated: 06.02.2019. /NS/

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Copy to:

By order

Assistant Registrar ITAT, Bangalore.