URVINDERPAL SINGH ATTARSINGH MADAN,NAVI MUMBAI vs. INCOME TAX OFFICER, INCOME TAX
IN THE INCOME-TAX APPELLATE TRIBUNAL “F” BENCH,
MUMBAI
BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER
&
SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER
Urvinderpal Singh
Attarsingh Madan,
Shop No. 17, APMC Market,
Sector 19, Vashi 400 703
Navi Mumbai Maharashtra v/s.
बनाम
Income
Tax
Officer,
Vashi
Railway
Station,
3rd
&
4th
Floor,
6th
Tower
Complex,
Vashi 400 703, Navi Mumbai
Maharashtra
स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AMPPS0024H
Appellant/अपीलार्थी
..
Respondent/प्रतिवादी
Appellant by :
Shri Bhupendra Shah
Respondent by :
Ms. Nidhi Agarwal (Sr. DR)
Date of Hearing
06.01.2025
Date of Pronouncement
08.01.2025
आदेश / O R D E R
PER PRABHASH SHANKAR [A.M.] :-
The present appeal arising from the appellate order dated
03.06.2024 is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless
Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] pertaining to assessment order passed u/s. 143(3) r.w.s. 147 of the Income-tax Act,
1961 [hereinafter referred to as “Act”] dated 30.12.2018 for the Assessment Year [A.Y.] 2011-12. P a g e | 2
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan
The grounds of appeal are as under: 1. In the facts and circumstances of the case and in law, the learned Assessing Officer erred passing order u/s 143(3) r.w.s. 147 by reopening, merely on the basis of borrowed satisfaction, presumption and surmises and relying upon information from Investigation wing, based on wrong reasons, without hearing, and inquiry, mechanically approved and without disposing objections well 2. In the facts and circumstances of the case and in law, the learned Assessing Officer erred in adding Rs. 1,31,88.079/- being total sale proceeds received on sale of shares of SVC Resources Limited by way of cash credit u/s 68 of IT Act, 1961 a. By ignoring the details submitted in respect of Payment made for purchase of Shares and payment received for sale of shares by cheques, Copies of Bank Statements, Demat Statement. Ledger of Share broker, Bills/ Contract Notes of shares purchased and sold, Details of Short Term Capital Gain. b. On the basis of suspicion and presumption c. Based on third party statements d. Without any proof of refund of cash e. By wrongly correlating general data of listed company with the Appellant f. By making only guesswork & overlooking documents and by relying upon cases not applicable in this case. g. By not offering the opportunity to cross-examine the brokers and other persons whose statements were never furnished for rebuttal h. By overlooking STT paid i. Without issuing notices u/s 133(6) or 131
P a g e | 3
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan j. Although the appellant is not liable to maintain books of accounts and therefore provisions of section 68 does not apply.
k. By ignoring the fact that the Appellant has already paid applicable tax on Short Term Capital Gains earned from sale of shares of SVC
Resources Limited.
3. In the facts and circumstances of the case and in law, the learned
Commissioner of Income Tax (A) erred in confirming the addition there by rejecting written submissions and several judgments cited before him.
3. Facts of the case are that the assessee is an individual. In response to the notice u/s 148 return of income was filed declaring total income as Rs 51,64,187/-. The A.O. has assessed total income of Rs. 1,83,52,266/- thereby making the additions of Rs. 1,31,88,079/- .The addition was made u/s 68 of the Act in respect of transaction in shares of SVC Resource Ltd, ignoring the short term capital gains disclosed by the assessee in the return of income. The calculation of capital gains as per assessee and based on stock market broker bills, demat A/c’s and supported by bank statement is as follows:-
Name
Date of Purchase
Qty
Amt of Purchase
Date of Sale
Amt of Sale
Gain
Anand
Credit
13/08/2010
5000
3,10,767
23/03/2011
51,220
- 2,59,546
Reliance
Industries
10/08/2010
650
6,46,272
05/10/2010
6,63,942
17,670
Reliance
Power
29/07/2010
1000
1,70,769
10/11/2010
1000
1,71,450
10/11/2010
3,42,984
765
16/07/2010
2500
6,24,864
30/07/2010
6,53,362
28,498
11/10/2010
2000
5,42,352
10/11/2010
1000
3,18,795
26/11/2010
8,97,791
36,643
29/01/2010
15000
25,77,678
P a g e | 4
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan
SVC
Resources
Limited
15/01/2010
10000
17,15,160
30/08/2010
66,04,978
23,12,138
15/01/2010
3000
5,14,548
05/01/2010
1000
1,52,377
18/02/2010
2250
3,96,850
31/08/2010
16,48,477
5,84,701
05/01/2010
2000
3,04,755
01/09/2010
5,27,889
2,23,134
05/01/2010
10750
16,38,059
07/09/2010
28,55,580
12,17,520
Unitech
27/05/2010
2000
1,40,149
16/07/2010
1,65,684
25,535
TOTAL
59150
1,02,24,850
1,44,11,911
41,87,061
Out of the above A.O. picked up the shares of SVC Resources Limited only for addition.
The capital gain on sale of SVC Resources Limited was as Follows:-
Name
Date of Purchase
Qty
Amt of Purchase
Date of Sale
Amt of Sale
Gain
SVC
Resources
Limited
16/07/2010
2500
6,24,864
30/07/2010
6,53,362
28,498
11/10/2010
2000
5,42,352
10/11/2010
1000
3,18,795
26/11/2010
8,97,791
36,643
29/01/2010
15000
25,77,678
15/01/2010
10000
17,15,160
30/08/2010
66,04,978
23,12,138
15/01/2010
3000
5,14,548
05/01/2010
1000
1,52,377
18/02/2010
2250
3,96,850
31/08/2010
16,48,477
5,84,701
05/01/2010
2000
3,04,755
01/09/2010
5,27,889
2,23,134
05/01/2010
10750
16,38,059
07/09/2010
28,55,580
12,17,520
TOTAL
87,85,441
1,31,88,079
44,02,637
1 The assessee disclosed Short Term Capital gain on sale of SVC Resources Limited of Rs. 44,02,637/-, however the A.O. added the total sale proceeds of Rs. 1,31,88,079/-by holding that in view of the Investigation Wing Report, the scrip price was rigged by market manipulators in this case as evident from chart showing abnormal increase in the price of this penny stock over a short period which fell to negligible price after that in an orchestrated manner. The net worth of the company did not justify it enhanced cost of its shares. The SEBI also P a g e | 5 A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan suspended its transaction on floor of BSE. The assessee indulged in share transaction to route its unaccounted income to show its legitimacy.
Accordingly, he treated the entire sale consideration as Undisclosed income liable to be added u/s 68 of the Act.
4. In the subsequent appeal, the ld.CIT(A) in the appellate order has repeated the modus operandi as narrated by the AO. He observed that on the basis of findings made by the Investigation Wing of the Department, assessments were reopened in a large number of entities across India. The reopening in such cases and additions made therein has been subjected to judicial scrutiny and various decisions have been rendered on the issue. In this regard, in a recent decision of Hon'ble High
Number:
IA
No.
GA/2/2022, date of Judgement/Order: 14/06/2022, wherein the Hon'ble Court has discussed in details this issue of earning long term capital LTCG/ STCG on share transactions involving penny stocks. The Hon'ble Court has analysed and evaluated various aspects of the transactions in the penny stocks and has, thereafter, concluded that such transactions are sham transactions incurred wholly for the purpose of availing accommodation entry either by way of LTCG/ STCG. While concluding so, the Hon'ble
P a g e | 6
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan
Court has discussed and placed reliance on various decisions of Hon'ble
Supreme Court. Accordingly, he upheld the addition.
In the course of hearing before us, the ld.AR orally as well as by way of written submission has agitated the impugned sum by claiming that addition was made disregarding the short term capital gains, cost of acquisition, sale and purchase bills, Demat account and bank statements. The AO on the basis of whims and fancy added the whole sale consideration of sale of shares as unexplained credit u/s 68.The addition made by AO is not justified in view of the express provisions of income tax act and the well settled principles of law. Multiple ITAT/High Court/ Supreme Court judgements are very clear and unambiguous in the matter. As long as there are proper evidences in the form of Bills, Broker notes, ledger accounts, payments and receipts by account payee cheques and dealing on stock exchange, the mere suspicion of wrong doing is not sufficient to make addition u/s 68 or any other section of Income Tax Act. AO has also not provided any evidence to suggest the wrong doing except a mere suspicion based on general analysis and general enquiries of other such dealings. He has also not provided any specific evidence which co- relates to our client. Hence the addition of Rs 1,31,88,079/- u/s 68 is not a valid proposition. Following judgements were relied upon before the ld.AO as also before the ld.CIT(A):
P a g e | 7
A.Y. 2011-12
in IT APPEAL NO. 1201 (MUM.) OF 2005 Revenue's Appeal in Supreme Court dismissed.
c. CIT vs. Pooja Agarwal (Rajasthan High Court) Appeal No 385/2011
d. DCIT vs. Rakesh Saraogi & Sons HUF (ITAT, Raipur)
1 In the present case, it is evident from the facts stated in forgoing paras that the sale consideration in respect of the above share has been treated as unexplained credit evidently on the report of Investigation Wing which is also reiterated in the assessment and appellate orders. Basically, investigation found price rigging of many penny stocks in a co-ordinated and collusive manner by several players on the floor of Exchange to legitimise their unaccounted income under the garb of Long/Short term capital gains. It is not disputed that the assessee has made transactions on floor of Exchange, dealt in listed shares, transactions supported by contract notes and also through banking channels. From the facts of the case, it is evident that the company was a listed company on Stock Exchange, subjected to various rules and regulations and compliance which have to be complied with under preferential allotment process. The assessee had filed all the relevant documents in support of the investment, transaction taking place through registered stock brokers. The investigation report of Kolkata,
P a g e | 8
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan nowhere name of the assessee figured nor evidences were found during the search and the entire allegations appear to be based on surmises, guesswork and conjectures only. Moreover, authorities below failed to establish any money trail involved in the transaction and has only guessed that the assessee might have paid his own money to route the same into books of accounts. The Hon’ble Apex Court in the case of Umacharan Saw and laws. We also find that the co-ordinate benches of ITAT, Mumbai have in several cases considered similar cases of addition arising out of Investigation wing
Kolkata report in shares.
Of one such case of ITA
No.2443/MUM/2023(Departmental appeal) in the case of ITO
Ward–23(2)(6)Mumbai Vs. Manisha Narpat Kumar Chopra, relevant paras are reproduced as below for ready reference:
“11. We heard rival contentions and perused the record. We notice that the AO has primarily placed reliance on the report given by the Investigation Wing of the Income-tax Department, Kolkata in order to arrive at the conclusion that P a g e | 9
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan the Long Term Capital Gain reported by the assessee is bogus in nature. We notice that the investigation report prepared by Investigation Wing,
Kolkata is a generalized report with regard to the modus operandi adopted in manipulation of prices of certain shares and generation of bogus capital gains. We notice that the AO has placed reliance on the said report, without bringing any material on record to show that the transactions entered by the assessee were found to be a part of manipulated transactions, i.e., it was not proved that the assessee has carried out the transactions of purchase and sale of shares in connivance with the people, who were involved in the alleged rigging of prices. .............
In the statement recorded ............ We also notice that - a) the assessee has purchased these shares by paying consideration through banking channels. b) the shares of M/s. Pine Animation Ltd., have been purchased from an existing share holder in the off market. The copy of physical share certificate is given, wherein the name of the assessee has been to have been endorsed. c) the shares have been later dematerialised and kept in the Demat account. d) the assessee has sold the shares through stock exchange platform e) the assessee has received the sale consideration through banking channels.
Further, the shares have entered and exited the demat account of the assessee.
We notice that the AO himself has not found any defect/deficiencies in the evidences furnished by the assessee with regard to purchase and sale of shares. Further, the AO has not brought on record any material to show that the assessee was part of the group, which involved in the manipulation of prices of shares. Hence, there is no reason to suspect the purchase and sale of shares undertaken by the assessee.
13. Both the parties relied on various case laws before us. We may refer to the some of the decisions rendered by Hon'ble juri ictional Bombay High
P a g e | 10
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan
Court. In the case of Shyam Pawar (54 taxmann.com 108) (Bom), the Hon'ble Bombay High Court has observed as under:-
“3. Mr. Suresh kumar seriously complained that such finding rendered concurrently should not have been interfered with by the Tribunal. In further Appeal, the Tribunal proceeded not by analyzing this material and concluding that findings of fact concurrently rendered by the Assessing Officer and the Commissioner are perverse. The Tribunal proceeded on the footing that onus was on the Department to nail the Assessee through a proper evidence and that there was some cash transaction through these suspected brokers, on whom there was an investigation conducted by the Department. Once the onus on the Department was discharged, according to Mr.Sureshkumar, by the Revenue-Department, then, such a finding by the Tribunal raises a substantial question of law. The Appeal, therefore, be admitted.
Mr.Gopal, learned Counsel appearing on behalf of the Assessee in each of these Appeals, invites our attention to the finding of the Tribunal. He submits that if this was nothing but an accommodation of cash or conversion of unaccounted money into accounted one, then, the evidence should have been complete. Change of circumstances ought to have, after the result of the investigation, connected the Assessee in some way or either with these brokers and the persons floating the two companies. It is only, after the Assessee who is supposed to dealing in shares and producing all the details including the DMAT account, the Exchange at Calcutta confirming the transaction, that the Appeal of the Assessee has been rightly allowed. The Tribunal has not merely interfered with the concurrent orders because another view was possible. It interfered because it was required to interfere with them as the Commissioner and the Assessing Officer failed to note some relevant and germane material. In these circumstances, he submits that the Appeals do not raise any substantial question of law and deserve to be dismissed.
We have perused the concurrent findings and on which heavy reliance is placed by Mr.Suresh kumar. While it is true that the Commissioner extensively referred to the correspondence and the contents of the report of the Investigation carried out in paras 20, 20.1, 20.2 and 21 of his order, what was important and vital for the purpose of the present case was whether the transactions in shares were genuine or sham and bogus. If the purchase and saleof shares are reflected in the Assessee's DMAT account, yet they are termed as arranged transactions and projected to be real,
P a g e | 11
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan then, such conclusion which has been reached by the Commissioner and the Assessing Officer required a deeper scrutiny. It was also revealed during the course of inquiry by the Assessing Officer that the Calcutta Stock Exchange records showed that the shares were purchased for code numbers S003 and R121 of Sagar
Trade Pvt. Ltd. and Rockey Marketing Pvt. Ltd. respectively. Out of these two, only Rockey Marketing Pvt.Ltd. is listed in the appraisal report and it is stated to be involved in the modus- operandi. It is on this material that he holds that the transactions in sale and purchase of shares are doubtful and not genuine. In relation to Assessee's role in all this, all that the Commissioner observed is that the Assessee transacted through brokers at Calcutta, which itself raises doubt about the genuineness of the transactions and the financial result and performance of the Company was not such as would justify the increase in the share prices.
Therefore, he reached the conclusion that certain operators and brokers devised the scheme to convert the unaccounted money of the Assessee to the accounted income and the present Assessee utilized the scheme.
It is in that regard that we find that Mr.Gopal's contentions are well founded. The Tribunal concluded that there was something more which was required, which would connect the present Assessee to the transactions and which are attributed to the Promoters/Directors of the two companies. The Tribunal referred to the entire material and found that the investigation stopped at a particular point and was not carried forward by the Revenue. There are 1,30,000 shares of Bolton Properties Ltd. purchased by the Assessee during the month of January 2003 and he continued to hold them till 31 March 2003. The present case related to 20,000 shares of Mantra Online Ltd for the total consideration of Rs.25,93,150/-. These shares were sold and how they were sold, on what dates and for what consideration and the sums received by cheques have been referred extensively by the Tribunal in para 10. A copy of the DMAT account, placed at pages 36 & 37 of the Appeal Paper Book before the Tribunal showed the credit of share transaction. The contract notes in Form-A with two brokers were available and which gave details of the transactions. The contract note is a system generated and prescribed by the Stock Exchange. From this material, in para 11 the Tribunal concluded that this was not mere accommodation of cash and enabling it to be converted into accounted or regular payment. The discrepancy pointed out by the Calcutta Stock Exchange regarding client Code has been referred to. But the Tribunal concluded that itself, is not enough to prove that the transactions in the impugned shares were bogus/sham. The details received from Stock Exchange have been relied upon and forthe purposes of faulting the P a g e | 12 A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan
Revenue in failing to discharge the basic onus. If the Tribunal proceeds on this line and concluded that inquiry was not carried forward and with a view to discharge the initial or basic onus, then such conclusion of the Tribunal cannot be termed as perverse. The conclusions as recorded in para 12 of the Tribunal's order are not vitiated by any error of law apparent on the face of the record either.
As a result of the above discussion, we do not find any substance in the contention of Mr.Sureshkumar that the Tribunal mi irected itself and in law. We hold that the Appeals do not raise any substantial question of law. They are accordingly dismissed. There would no order as to costs.
Even the additional question cannot be said to be substantial question of law, because it arises in the context of same transactions, dealings, same investigation and same charge or allegation of accommodation of unaccounted money being converted into accounted or regular as such. The relevant details pertaining to the shares were already on record. This question is also a fall out of the issue or question dealt with by the Tribunal and pertaining to the addition of Rs.25,93,150/-. Barring the figure of loss that is stated to have been taken, no distinguishable feature can be or could be placed on record. For the same reasons, even this additional question cannot be termed as substantial question of law."
No. 2012 of 2017 dated 4th March, 2022), the Hon'ble Bombay High Court has observed as under:-
"2. We have considered the impugned order with the assistance of learned counsels and we have no reason to interfere. There is a finding of fact by the Tribunal that the transaction of purchase and sale of shares of the alleged penny stock of shares of Ramkrishna Fincap Ltd ("RFL") is done through stock exchange and through the registered Stock Brokers. The payments have been made through banking channels and even Security
Transaction Tax ("STT") has also been paid. The Assessing Officer also has not criticized the documentation involving the sale and purchase of shares. The Tribunal has also come to a finding that there is no allegation against the assessee that it has participated in any price rigging in the market on the shares of RFL.
Therefore we find nothing perverse in the order of the Tribunal. 4. Mr. Walve placed reliance on a judgement of the Apex Court in Principal Commissioner of Income tax (Central)-1 vs. NRA Iron & Steel
P a g e | 13
A.Y. 2011-12
taxmann.com 529 (Bom), the Hon'ble Bombay High Court has held sale of shares were not doubted. Under these set of facts, the Hon'ble High
Court held as under:-
“....The CIT(A) came to the conclusion that respondent bought 3000
shares of RFL, on the floor of Kolkata Stock Exchange through registered share broker. In pursuance of purchase of shares the said broker had raised invoice and purchase price was paid by cheque and respondent's bank account has been debited. The shares were also transferred into respondent's Demat account where it remained for more than one year. After a period of one year the shares were sold by the said broker on various dates in the Kolkata Stock Exchange.
Pursuant to sale of shares the said broker had also issued contract notes cum bill for sale and these contract notes and bills were made available during the course of appellate proceedings. On the sale of shares respondent effected delivery of shares by way of Demat instruction slips and also received payment from Kolkata Stock
Exchange. The cheque received was deposited in respondent's bank account. In view thereof, the CIT(A) found there was no reason to add the capital gains as unexplained cash credit under section 68 of the Act.
The Tribunal while dismissing the appeals filed by the Revenue also P a g e | 14
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan observed on facts that these shares were purchased by respondent on the floor of Stock Exchange and not from the said broker, deliveries were taken, contract notes were issued and shares were also sold on the floor of Stock Exchange. The ITAT therefore, in our view, rightly concluded that there was no merit in the appeal."
………………………………………………. In the earlier paragraphs, we have followed the binding decision rendered by Hon'ble Bombay High Court. Hence, the Ld. DR cannot place reliance on the decision rendered by Hon'ble Kolkata High Court in the case of Swati Bajaj (supra). Accordingly, we are of the view that the decision rendered in the above said case cannot be taken support of by the Revenue.
In view of the foregoing discussions, we are of the view that the Ld CIT(A) was justified in deleting the addition of value of sale consideration arising on sale of shares of M/s. Pine Animation Ltd. Since we have confirmed the decision of Ld CIT(A) in holding that the sale transactions of shares cannot be doubted with, the addition made by the AO with regard to estimated commission expenses is also liable to be deleted. Accordingly, we confirm the order passed by Ld. CIT(A).
In the result, the appeal of the Revenue is dismissed.”
3 In another case of Chirag Tejprakash Dangi ITA No.3256/Mum/2022, the tribunal in para 14 of the order has categorically observed that the decisions rendered by the juri ictional Bombay High Court in the cases cited above i.e. Shyam Pawar(supra),Ziauddin Siddiquue and Jamnadevi Agrawal shall apply in the present case as well since the AO has not established that the assessee had rigged the prices and also AO did not find any fault in the documents filed by the assessee. Moreover, purchase of shares in P a g e | 15 A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan earlier years were accepted as genuine. Shares were traded on online platform of the Stock Exchange. Therefore, sale transactions could not be doubted.
In another case of Alka
Dilip
Doshi in ITA
No.1837/Mum/2023 dated 20.02.2024, the tribunal has taken note of various decisions of Ahmedabad Bench of ITAT in several cases as per similar instances of transaction were held to be genuine. In another case of Manju Hiralal Baina in ITA No. 1026/Mum/2020 dated
15.4.2024,the same bench has considered similar issue at length and deleted similar addition.Reference could also be made of the decision in the case of Shailesh Jain HUF in ITA No.6068/M/2019 dated
16.02.2021 in which also identical similar issue was involved. The co- ordinate bench of Mumbai in a detailed judgement has considered all relevant aspects of the case before deleting similar addition.
4 Considering the above discussion, the facts on record and the legal position emerging out of catena of decisions of Hon’ble Supreme Court, juri ictional High Court and direct decisions rendered by the co- ordinate benches of Mumbai, ITAT order, we hold that the addition made by the AO u/s 68 of the Act in the year under consideration is devoid of any merit. Moreover, the juri ictional High Court decisions cited supra are on identical facts as also the co-ordinate benches of Mumbai tribunal have a binding precedence. None of cited decisions by the assessee, both
P a g e | 16
A.Y. 2011-12
Urvinderpal Singh Attarsingh Madan before the AO and the ld.CIT(A) have been distinguished anywhere in the appellate order. Apparently, the order has in a preconceived manner dittoed the assessment order rather than by way of independent application of mind. No independent enquiry or investigation worth the name has been conducted by the ld.AO or the ld.CIT(A) in the matter. The assessee itself has declared substantial amount of Short Term Capital gains of Rs. 44,02,637/- and paid the Rs 6,28059/-as income tax thereon.
To conclude, we do not find any substance in the addition made by the AO and upheld by the ld.CIT(A) both on merits or the legal position emerging from the cited decisions(supra).The appellate order is accordingly set aside and the AO is, therefore, directed to delete the addition made u/s 68 of the Act.
6. In the result, the appeal is allowed.
Order pronounced in the open court on 08/01/2025. SANDEEP GOSAIN
PRABHASH SHANKAR
(न्याययक सदस्य /JUDICIAL MEMBER)
(लेखाकार सदस्य/ACCOUNTANT MEMBER)
Place: म ुंबई/Mumbai
ददनाुंक /Date 08.01.2025
Lubhna Shaikh / Steno
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Urvinderpal Singh Attarsingh Madan
आदेश की प्रयियलयि अग्रेयिि/Copy of the Order forwarded to :
1. अपीलार्थी / The Appellant
2. प्रत्यर्थी / The Respondent.
3. आयकर आयुक्त / CIT
4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT,
Mumbai
5. गार्ड फाईल / Guard file.
सत्यावपि प्रवि ////
आदेशानुसार/ BY ORDER,
उि/सहायक िंजीकार (Dy./Asstt.