SMT. JAMUNA DEVI,JAIPUR vs. ACIT, BHARATPUR

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR Jh dqy Hkkjr] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 926/JP/2013 fu/kZkj.k o"kZ@Assessment Year : 2008-09 cuke Smt. Jamuna Devi, The A.C.I.T., Vs. Prop. M/s Narang Stones, Circle, Bharatpur. Bharatpur Road, Murrki, Bayana District, Bharatpur. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AFQPD 3798 H vihykFkhZ@Appellant izR;FkhZ@Respondent

fu/kZkfjrh dh vksj ls@ Assessee by : Shri Manish Agarwal (CA) jktLo dh vksj ls@ Revenue by : Shri Rajendra Singh (ACIT)

lquokbZ dh rkjh[k@ Date of Hearing : 09/01/2017 mn?kks"k.kk dh rkjh[k@ Date of Pronouncement : 08/02/2017 vkns'k@ ORDER

PER: VIKRAM SINGH YADAV, A.M. This is an appeal filed by the assessee against the order of Ld. CIT(A) dated 02.09.2013 for A.Y. 2008-09. The grounds of appeal taken by the assessee are as under:- 1. On the facts and in the circumstances of the case the Ld. CIT(A) has grossly erred in sustaining the addition of Rs.2,92,706/- u/s 40A(3) of the Income Tax Act, 1961 for making the payment in cash exceeding Rs.20,000/- without appreciating the submission made and evidence adduced.

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1.1 That the Ld. CIT(A) has further erred in not appreciating the fact that the aforesaid amount was paid by the assessee on different dates under unavoidable circumstance, covered under rule 6DD of I.T. Rules, thus addition sustained by the Ld. CIT(A) of Rs.2,92,706/- deserves to be deleted. 2. On the facts and in the circumstances of the case the Ld. CIT(A) has grossly erred in making an addition of Rs.4,14,652/- by applying G.P. rate 31% being the gross profit on alleged unaccounted sale of Rs.13,37,586/- arbitrarily. 2.1 That the Ld. CIT(A) has further erred in ignoring the fact that entries noted in loose papers and slips impounded during the course of survey were rough working and measurements not related to the actual sale made by the assessee and all the sale pertaining to loose papers were duly recorded by the assessee in the books of accounts, thus addition of Rs.4,14,652/- sustained by the CIT(A) deserves to be deleted. 3. On the facts and in the circumstances of the case the Ld. CIT(A) has grossly erred in sustaining the addition of Rs.1,25,105/- [though telescoped from addition sustained on account of profit on unaccounted sales] on account of unexplained investment in unaccounted purchases, arbitrarily. 3.1 That the Ld. CIT(A) has further erred in ignoring the fact that entries noted in loose papers, slips impounded during the course of survey were only rough estimate and measurements and actual purchases noted on loose paper were duly recorded in the books of accounts, therefore, addition of Rs.1,25,105/- as sustained by the Ld. CIT(A) deserves to be deleted. 4. On the facts and in the circumstances of the case the Ld. CIT(A) has grossly erred in making the addition of Rs.61,873/- [though telescoped from addition sustained on account of profit on unaccounted sales] on account of stock alleged as found excess arbitrarily, thus the resultant addition deserves to be deleted.

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4.2 That the Ld. CIT(A) has further erred in ignoring the fact that valuation of stock done by the department during the course of survey was on higher side on estimate basis without considering the stock of Red blocks and Pink blocks separately, therefore, addition so sustained of Rs.61,873/- deserves to be deleted.

and proprietor of M/s Narang Stone which is engaged into the business

of manufacturing and trading of pillars & slabs of sand stones. For the

year under appeal, the assessee furnished her return of income

declaring total income at Rs.4,29,320/-. Thereafter, a survey u/s 133A of

the Income Tax Act, 1961 was conducted on 18.03.2008 at the business

premises of the assessee. Subsequently, assessment was completed u/s

143(3) of the Act at a total income of Rs.12,43,400/- by making

additions to the tune of Rs.8,14,080/- on various counts.

2.1. Against the said assessment order, the assessee preferred an

appeal before the Ld. CIT(A) who vide his appellate order dated

02.09.2013 passed in Appeal No.309/10-11, partly allowed the appeal of

assessee. The final outcome after the order of Ld. CIT(A) is as under:-

S. Particulars Addition made by Addition deleted Addition sustained No. AO by CIT(A) by CIT(A)

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2.2. Against the additions so sustained by the Ld. CIT(A), the assessee

has preferred this appeal before this Bench.

2.3 In respect of Grounds of Appeal Nos. 01 to 1.1, the assessee has

challenged the action of Ld. CIT(A) in sustaining the addition of

Rs.2,92,706/- made by way of disallowance u/s 40A(3) of the Income

Tax Act, 1961. The impugned order of Ld. CIT(A) has been challenged

on the ground that the Ld. CIT(A) as well as AO both failed to appreciate

the fact that the case of assessee falls within the exceptional

circumstances envisaged under Rule 6DD(g) & (j) of Income Tax Rules,

1962.

2.4 Brief facts pertaining to these grounds of appeal are that during the year under appeal, the assessee had paid an amount totalling to

5 ITA No.926/JP/2013 Smt. Jamuna Devi Vs. A.C.I.T., Bharatpur

Rs.2,92,706/- in cash in respect of the purchases made by assessee from M/s Mahalaxmi Stone, Sarmathura on four different dates. The details regarding such cash payments is as under:

Date Name of the Party Amount

14.12.2007 Mahalaxmi Stone, Sarmathura Rs. 61,342.00

14.12.2007 Mahalaxmi Stone, Sarmathura Rs. 65,452.00

25.12.2007 Mahalaxmi Stone, Sarmathura Rs. 79,392.00

29.01.2008 Mahalaxmi Stone, Sarmathura Rs. 86,250.00

Total Rs. 2,92,706.00

These cash payments totalling to Rs.2,92,706/- were disallowed by Ld. AO u/s 40A(3) of the Act. However, while doing so, the AO failed to consider the submission of assessee that, the case of assessee falls within the exceptional circumstances as provided for under rule 6DD of the Income Tax Rules, 1962.

2.5 In this regard, the ld AR submitted that it was explained before the Ld. AO that, out of these payments, the payment of Rs.79,392/- was made on 25.12.2007 which is a public holiday (Christmas), banks were closed on the said date and therefore, the payment through cheque was not possible. Accordingly, the case of assessee with respect to the payment of this amount of Rs.79,392/- is covered under Rule 6DD(j) of the Income Tax Rules, 1962. Upon being confronted with this submission, the Ld. CIT(A) remanded the matter back to the file of AO for making verification in this regard and in the remand report dated

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11.06.2013, the Ld. AO has clearly recommended that, this payment of Rs.79,392/- cannot be disallowed u/s 40A(3) in as much as the same is covered by Rule 6DD(j) of the Income Tax Rules, 1962, relevant portion of the remand report has been reproduced at pages 4-5 of the appellate order of Ld. CIT(A) from a perusal of which, it would be clear that there remained no dispute with regard to the payment of Rs.79,392/- as the Ld. AO himself has recommended in the remand report the relief to such extent may be allowed. Nevertheless, in spite of being so, the Ld. CIT(A) has not allowed any relief even on this account and has upheld the entire addition of Rs.2,92,706/- without any basis. Therefore, this action of Ld. CIT(A) deserves to be held bad in law and the respective addition to the extent of Rs.79392/- deserves to be deleted.

2.6 With regard to the remaining payments totalling to Rs.2,13,314/- (2,92,706 – 79,392), the ld AR submitted that, those payments are covered under clause (g) of Rule 6DD of the Income Tax Rules, 1962 according to which, if the cash payment exceeding Rs.20,000/- is made in a village or town, which on the date of such payment is not served by any bank, to any person who ordinarily resides or carries on any business in such village or town, then such payment shall be out of the purview of section 40A(3) and cannot be disallowed under the said section.

2.7 In this regard it was further submitted that the assessee had made these payments in cash to a dealer named M/s Mahalaxmi Stones in auction in open market. As per usual practice, the auction process is completed in the evenings, and particularly so on the dates mentioned above, the auctions were finalized in the evenings only and as per the

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terms of the contract, the amount had to be paid in the same day. It is submitted here that, at the relevant time. i.e. the date of making these payments, there was no evening branch of any Bank at Bayana so that no payment could be deposited directly in the bank account of the party and it has to be made in cash only. In support of this statement, the assessee had also furnished her affidavit during the course of appellate proceedings which remained uncontroverted. Therefore, it is submitted that the case of assessee is completely covered by Rule 6DD(g) of the Income Tax Rules, 1962.

2.8 It was further submitted that during the course of appellate proceedings, upon submission of affidavit of assessee, the matter was referred to the AO for his comments thereupon who submitted his report on 11.06.2013 and the sole objection raised by him therein was that, “the contention regarding no evening branch of bank at Bayana is not acceptable because it is story after thought to avoid tax liability”. Apart from this, the Ld. AO has not raised any other objection.

2.9 In this regard, it was further submitted that, at the relevant time in the year 2007 when these payments were made, there existed no evening bank branch and in view of the urgency to make payment at the spot right then, the assessee was genuinely precluded from making payment otherwise than in cash. It must be noted that, the Ld. AO has refrained from bothering to making the necessary inquiry regarding the fact of availability of evening bank branches in Bayana, but has straightaway proceeded to deny this fact. The Ld. AO has denied the submission of assessee and affidavit submitted by her, hence the onus was on the Ld. AO to make the necessary enquiry in order to find out

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whether there was any evening bank branch available in Bayana or not. Here, it may be mentioned that, the onus was not on the assessee because a negative fact cannot be proved by positive evidence and there exists no such thing as negative evidence. However, the assessee has made averments in the affidavits regarding non-availability of evening bank branch at Bayana. Now, it was the duty of the Ld. AO to conduct necessary enquiry so as to satisfy himself before reaching any conclusion, which the Ld. AO has refrained from undertaking.

Therefore, the action of Ld. AO in discarding the explanation / submission of assessee merely on the basis of assumptions and presumptions and without conducting the necessary inquiries deserves to be held bad in law and the addition of Rs.2,92,706/- deserves to be deleted.

2.10 The relevant finding of the CIT(A) is reproduced which is as under: “4.5 I have considered the submissions made by the AR and the report submitted by the AO and find that the appellant has made payments of Rs.2,92,706/- to M/S Maha Laxmi stone, Sarmathura on various dates during the year under consideration. The appellant has been making regular purchases from this party during the year as may be seen from the details given above.

This seller is engaged in a regular business and is assessed to tax in Ward-3, Bharatpur, therefore, the argument that cash payment was made to a villager or during an auction does not hold good in the case of a person with whom the appellant has regular business dealings. Further

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both are business units functional in an area where ample banking facilities are available. The AO in his remand report has stated that only one payment of Rs.79,392/- made on 25th December, 2007 may be allowed as a deduction on account of banks being closed due to Christmas holiday. I do not find force in the said argument, since it is not a case, where there had been no transactions with the seller in the past, nor it is a case of any compelling circumstance, which required cash payment. The appellant has failed to bring on record any evidence to justify such payments made in cash. To support this, I rely on the following judgments of the Hon’ble Allahabad High Court, in the case of Evershine Plateres Vs. CIT 295 ITR 349; and of the Hon’ble Kerla High Court in the case of Silk Feb Exports Vs. CIT 295 ITR 0123; and of Hon’ble Kalkatta High Court in the case of CIT Vs. Himachal Terepene Products Pvt. Ltd. 269 ITR 538; and of Hon’ble Himachal Pradesh High Court in case of CIT Vs. Dalip Chand and Sons 301 ITR 276 where it was held that payments in cash where banking facility are available, disallowance U/s 40A(3) is justified. Further, it has been held that the onus is on assessee to prove the existence of exceptional circumstances. “4.6 Thus, the payments made in cash by the appellant during the year are not justified and hence the addition of Rs.2,92,706/- made by the AO U/s 40A(3) is confirmed.”

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3.1. Brief facts pertaining to these grounds of appeal are that during the course of survey, certain loose papers were found and were impounded. The AO referred to these papers and stated that the jottings on these papers reflect the unaccounted sales made by the assessee. The details pertain to these papers have been mentioned at page 4 of the Assessment Order. Before the AO, it was explained by assessee that none of these papers recorded any actual transaction and that they contain mere rough workings and estimations. However, the contention of the assessee was rejected and basis such papers, the AO determined unaccounted sales and applied a GP rate of 25% and made the addition of Rs.3,34,397/-.

3.2 Before the Ld. CIT(A), it was submitted by the assessee that the loose papers so found during the course of survey did not record any actual transaction, but were mere rough working and calculations. The Ld. CIT(A) then referred the matter to the AO for examination of the contentions of assessee. Accordingly, the AO submitted his remand report dated 11.06.2013 (APB 15-20) which was taken into consideration by the Ld. CIT(A) and on the basis of findings made in the remand report, the Ld. CIT(A) decided this issue against the assessee.

3.3. In this regard, the ld AR submitted that with regard to the alleged unaccounted sale of Rs.67,200/- [Annexure 4, page no. 111] it was submitted before the Ld. AO as well as Ld. CIT(A) that the figure of Rs.89,475/- was only a rough estimate and the actual sale was made only of Rs.22,275/- out of the above rough estimation against which, bill no. 556 dated 15.03.2008 was issued, copy of which was already submitted before the Ld. AO during the course of assessment. This sale

11 ITA No.926/JP/2013 Smt. Jamuna Devi Vs. A.C.I.T., Bharatpur

of Rs.22,275/- was duly recorded by assessee in the books of account. No sale to the tune of Rs.89,475/- was executed by the assessee, however, the Ld. AO has treated the same as unaccounted sale without any basis and without establishing the execution of sale, the burden of proving which was on the Ld. AO.

3.4 With regard to the alleged unaccounted sale of Rs.2,85,114/-, the ld AR submitted that there was a rough estimate of Rs.10,62,420/- mentioned on a paper, out of which there was job work worth Rs.7,79,306/- which was duly recorded by assessee in the books of account as mentioned in Para 3 of page 8 of the assessment order. However, the Ld. AO treated this entire amount of Rs.10,64,420/- as the amount of actual sale / job work. With regard to the difference amount of Rs.2,85,114/- it was submitted before the Ld. AO as well as Ld. CIT(A) that the same is mere rough calculation and cannot be treated as actual sale.

3.5 With regard to the other alleged sales of Rs.6,54,802/-, Rs.38,876/-, Rs.1,03,669/-, it was further submitted that these were mere rough estimate, which has been treated by the Ld. AO as actual sale without establishing the same and merely on the basis of assumptions and presumptions.

3.6 It was further submitted that the burden of proving the fact of execution of unaccounted sales was on the Ld. AO which he has failed to discharge and without proving which, no addition on account of unaccounted sales can be made. In this regard reliance is placed on

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order of Hon’ble ITAT in the case of Mahavir Prasad Choudhary Vs. ITO (ITAT Jodhpur) (XLII TW 98).

Therefore, in view of the above it is humbly prayed that the addition of Rs.4,14,652/- being G.P. rate @ 31% on the alleged undisclosed sales of Rs.13,37,586/- sustained by the Ld. CIT(A) may please be directed to be deleted.

3.7 Further, without prejudice to above and in the alternative, it was further submitted that the Ld. CIT(A) has grossly erred in enhancing the application of the profit rate at 31% in place of 25% applied by the Ld. AO. In this regard, it is submitted that the Ld. CIT(A) has unilaterally and on his own applied this profit rate without appreciating the fact that assessee has disputed the application G.P. rate and requested for application of N.P. rate and never challenged the application of average GP rate applied by the ld. AO. It is submitted that the Ld. AO was quite justified in applying the profit rate of 25% by taking the average profit rate of the past three assessment years, however the Ld. CIT(A) has wrongly disturbed this rate by applying the profit rate @ 31%.

Thus, in the alternative it is prayed that the action of Ld. CIT(A) in applying the profit rate of 31% may please be declared bad in law and the profit rate as applied by the Ld. AO @ 25% be upheld.

3.8 The relevant finding of the CIT(A) is reproduced which is as under:

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“5.5 I have carefully considered the submissions made by the AR and

the remand report furnished by the AO. It is seen that AO had worked

out the total unaccounted sales at Rs.21,58,227/- and after verification

of impounded books of accounts, diary, loose papers etc. which were

marked as annexure A-4, A-13, A-19, A-24 & A-25, found that only sales

of Rs.41,335/- and job work receipts of Rs.7,79,306/- has been recorded

in the books of accounts. Paper-wise details of computation of

unrecorded sales have been given in the remand report of the AO and

also elaborately discussed on pages-4 to 10, in the assessment order.

The AO has worked out the unaccounted sales at Rs.13,37,586/- in the

remand report after giving a credit of Rs.41,335/- and Rs.7,79,306/- to

the appellant. The appellant has not been able to controvert the findings

of the AO and has merely stated that these papers reflect the estimate

made and do not show the actual sales. There is no substance in the

arguments given by the appellant as the impounded papers clearly show

the quantity of the materials, rate, date and name of the party. Further,

the AO had also given credit for the job work done by the appellant and

which was found recorded in the regular books of accounts. The

arguments given by the appellant are repetitive and have already been

considered by the AO at the assessment stage as well as at the appellate

stage, while furnishing the remand report.”

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“5.6 Thus, I confirm the unaccounted sales at Rs.13,37,586/- as

worked out by the AO in his remand report. However, while making the

trading addition the AO applied the average GP rate for the last 3 years

(for FY 2005-06 to FY 2007-08 of 25%). I do not agree with the average

rate adopted by the AO, while working out the profit earned on

unaccounted sales. The rate of GP declared by the appellant for the

period under consideration should be adopted, while working out the

profit on unaccounted sales and this fact has also been pointed out by

the AO in his remand report. The appellant in the counter comments on

remand report did not offer any explanation on this point. However, this

issue was discussed with the AR during the appellate proceedings and it

was fairly conceded by him. The GP rate declared by the appellant for FY

2007-08 is 31% and if applied on sales of Rs.13,37,586/-, it gives a

profit of Rs.4,14,652/-. Accordingly, I enhance the addition made on

account of profit earned on unaccounted sales from Rs.3,34,397/- to

Rs.4,14,652/- under this head.”

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4.1. The ld AR submitted that on the basis of the loose papers in Annexure A-19, the AO alleged that the assessee has made purchases of Rs.1,25,105/- which have not been recorded in the books of account. In this regard, it was submitted by the assessee before the Ld. AO that these papers only contained the record of sizes and rough calculations and did not reflect any purchase or sale by assessee. It was further contended that since addition on account of unaccounted sale has already been made, no further addition on account of unaccounted purchases can be made as the same would amount to double addition. However, the AO did not consider the contention of the assessee and treated the entire amount of Rs.1,25,105/- as unaccounted purchases. Before the Ld. CIT(A), the above said contention was reiterated, however the same was not considered. However, the alternative submission of assessee for allowing telescoping of this addition with the addition made on account of alleged unaccounted sales was accepted by the Ld. CIT(A) and the telescoping was allowed accordingly.

Thus, in view of the above, it is submitted that since the amount of Rs.1,25,105/- did not contain any actual amount of purchase, but was mere estimate and rough calculations, the action of Ld. CIT(A) in sustaining the addition is clearly bad in law and thus the same deserves to be deleted.

4.2 The relevant finding of the ld CIT(A) is reproduced as under:

“6.7 I have considered the submissions made by the appellant and have also gone through the judgment of the Hon’ble ITAT Jaipur and find that there is force in the contention raised by the appellant.

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However, as regards the issue of giving credit for the same against the addition made on account of profit on unaccounted sales is concerned, there has to be correlation between the quantum of addition made on account of profit earned on unaccounted sales and the investment in unaccounted purchases. The Hon’ble ITAT Jaipur has held in the above mentioned case that no separate addition on account of unexplained investment of Rs.23,600/- is required to be made and the benefit of telescoping may be given against the addition of Rs.54,789/- made on account of gross profit on unaccounted sales. “6.8 Following the ratio of the decision, I hold that the benefit of telescoping may be given to the appellant in this case, as regards the addition of Rs.1,25,105/- on account of unaccounted purchases is concerned as a trading addition of Rs.4,14,652/- on account of gross profit earned on unaccounted sales has already been confirmed above. Thus, there would be no separate addition of Rs.1,25,105/- on account of unaccounted purchases.”

5.1 The ld AR submitted that at the time of physical verification of stock during the course of survey, it was taken at Rs.8,65,436/- and as per books of account, the stock was shown at Rs.8,03,563/-, thus it was alleged that there was excess stock of Rs.61,873/- , which addition was sustained by the Ld. CIT(A), though telescoping of the same was

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allowed with the addition made on account of alleged unaccounted sales.

5.2 In this regard, it was submitted that the reason for difference in stock is that some red blocks of stones had been considered as pink stone blocks and the rate of pink blocks i.e. 140 per cft was taken instead of 70 per cft for the red blocks. Thus, there was a huge difference in the rates of pink blocks of stone and the red blocks of stones. However, while taking stock at the time of physical survey, this difference was not considered at all and this resulted in difference in stock. Thus, in view of the above it is submitted that the addition of Rs.61,873/- deserves to be deleted.

5.3 The relevant finding of the ld CIT(A) is reproduced as under:

“7.5 I have carefully considered the submissions made by the AR and find that AO has worked out the unexplained investment in the excess stock found at the time of survey at Rs.61,873/-. It is stated that the inventory valuation was done at the time of survey with the help of Shri Satish Narang (Son of the assessee), who was the main person responsible for the business. This fact was not controverted by the appellant at the time of survey or immediately thereafter. This argument has been raised by the appellant only at the assessment stage as an afterthought. The appellant has failed to furnish any evidence in support of the claim made by furnishing a quantitative record of purchases and sales of both varieties of stone. Accordingly, I confirm the addition of Rs.61,873/- made on account of unexplained investment in excess stock.”

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“7.6 Following the ratio of the decision of the Hon’ble ITAT, Jaipur in the above cited case, I hold that the benefit of telescoping may be given to the appellant in this case, as regards the addition of Rs.61,873/- on account of unaccounted investment in excess stock is concerned, as a trading addition of Rs.4,14,652/- on account of gross profit earned on unaccounted sales has already been confirmed above. Thus, there would be no separate addition of Rs.61,873/- on account of unexplained investment in excess stock.”

19 ITA No.926/JP/2013 Smt. Jamuna Devi Vs. A.C.I.T., Bharatpur

as an exceptional circumstance for making the cash payment. The ld. CIT(A) has given a finding that both the buyer and seller are functioning in an area where ample banking facilities are available. The said finding has not been controverted by the assessee. Further, the Rules provides that on the date of payment, the place where the payment is made is not served by any bank. The Rules however have not provided for a situation as in the instant case where even though the place is served by the bank but at the relevant point in time (evening) when the payment is made, whether the place is served by the bank or not. In absence of the same, we are unable to accede to the contention of the ld. AR in respect of payment amounting to Rs.2,13,314/- covered under Rule 6DD (g) of the Income Tax Rules. Accordingly, the assessee deserves relief to the extent of only Rs.79,392/-. The ground no.1 to 1.1 is thus partly allowed.

20 ITA No.926/JP/2013 Smt. Jamuna Devi Vs. A.C.I.T., Bharatpur

unaccounted sales amounting to Rs.4,14,652/-. Hence, ground no. 2 & 2.1 of assessee are dismissed.

In the result, appeal filed by the assessee is partly allowed.

Order pronounced in the open court on 08/02/2017.

Sd/- Sd/- ¼dqy Hkkjr ½ ¼foØe flag ;kno½ (Kul Bharat) (Vikram Singh Yadav) U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member Tk;iqj@Jaipur fnukad@Dated:- 08/02/2017. *Sanjeev*. आदेश की प्रतिलिपि अग्रेf’ात@ब्वचल वf जीम वतकमत वितूंतकमक जवरू 1. vihykFkhZ@The Appellant- Smt. Jamuna Devi, Bharatpur. 2. izR;FkhZ@ The Respondent- The ACIT, Circle, Bharatpur.

21 ITA No.926/JP/2013 Smt. Jamuna Devi Vs. A.C.I.T., Bharatpur 3. vk;dj vk;qDr@ CIT 4. vk;dj vk;qDr@ CIT(A) 5. विभागीय प्रतिनिधि] आयकर अपीलीय अधिकरण] जयपुर@क्त्ए प्ज्Aज्ए Jंपचनत 6. xkMZ QkbZy@ Guard File {ITA No. 926/JP/2013}

vkns'kkuqlkj@ By order,

सहायक पंजीकार@Aेेज. त्महपेजतंत