GAZAL CATERERS,NEW DELHI vs. ITO WARD - 22(2), NEW DELHI
Facts
The assessee, M/s Gazal Caterers, appealed against the CIT(A)'s order for A.Y. 2009-10, which sustained additions made during an assessment completed u/s 143(3). The primary contention was the alleged non-issuance of a mandatory notice u/s 143(2) within the statutory period, rendering the assessment invalid. Additionally, the appeal challenged additions made under Section 68 concerning capital introduction by partners, unsecured loans, and sundry creditors.
Held
The Tribunal dismissed the additional ground, holding that the assessment proceedings were saved by Section 292BB as notices u/s 143(2) were issued (though unserved) and the assessee participated in subsequent proceedings. Regarding the merits, the Tribunal deleted the additions related to capital introduction and unsecured loans, finding the assessee had discharged its onus by providing sufficient explanations and evidence. Similarly, additions concerning sundry creditors were deleted as the assessee provided confirmations and the lower authorities found no adverse material.
Key Issues
1. Whether the assessment proceedings were valid despite the alleged non-issuance of mandatory notice u/s 143(2) within the statutory period, considering the applicability of Section 292BB. 2. Whether the additions made under Section 68 concerning capital introduction, unsecured loans, and sundry creditors were justified.
Sections Cited
143(3), 143(2), 139(1), 292BB, 68, 133(6), 142(1), 271(1)(b)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI ‘B’ BENCH,
Before: SHRI SAKTIJIT DEY, & SHRI NAVEEN CHANDRA
PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:-
This appeal by the assessee is preferred against the order of the
ld. CIT(A)- 31, New Delhi dated 25.06.2019 pertaining to A.Y. 2009-10.
The grounds raised by the assessee are against the addition
sustained by the CIT(A) as under:
(i) Rs.60,000/- on account introduction of capital;
(ii) Rs.3,85,000/- on account of unsecured loan; and
(iii) Rs.11,77,085/- on account of sundry creditors, allegedly.
In addition to the above grounds, the assessee has raised an
additional ground which reads as under:
“That having regard to the facts and circumstances of the case, the ld. CIT(A) ought to have quashed the impugned assessment order passed by the Assessing Officer u/s 143(3) of the Act on the ground that mandatory notice u/s 143(2) of the Act has not been issued within the statutory allowable period.
For admission of this additional ground, strong reliance was
placed on various decisions including that of the Hon'ble Supreme
Court in the case of CIT Vs. Singhad Technical Education Society 397
ITR 344; NTPC Ltd 229 ITR 383 and Jute Corporation of India Ltd 187
ITR 688.
We have heard the rival submissions on the additional ground.
We find that the issue raised goes to core ground of assumption of
jurisdiction by the Assessing Officer and following the decision relied
upon, we allow the additional ground.
The brief facts of the case are that the assessee is a partnership
firm engaged in the business of catering. There are three partners
during the year under consideration – Mr. Vinod Malik, Mr. Rahul
Khurana and Mr. Ishan Khurana. The assessee firm filed return of
income on 25.09.2009 declaring total income at Rs.10,32,130/-. The
case was selected for scrutiny under CASS. The assessment u/s 143(3)
was completed on 16.12.2011 at assessed income of Rs.62,80,295/-
after making addition of Rs.52,48,165/-.
Aggrieved, the assessee filed appeal before the ld. CIT(A) who
sustained the addition to Rs.16,22,085/-.
Aggrieved further, the assessee is in appeal before the Tribunal.
Before us, the ld. counsel for the assessee at the outset
submitted that the return of income was filed u/s 139(1) on
25.09.2009. The statutory time limit for service of notice u/s 143(2)
was 30.09.2010. In the instant case, the notice u/s 143(2) was issued
on 05.11.2011 which is after expiry of 6 months from the end of FY
2009-10. Proviso to Section 143(2) states that no notice under this sub-
section shall be served on the assessee after expiry of 6 months from
the end of the financial year in which the return is furnished. Thus, for
scrutinising any return, it is necessary to serve the notice u/s 143(2)
within the statutorily prescribed time. In absence of the notice, the
assessment is bad in law.The ld. counsel for the assessee relied upon
the decision of the Hon’ble Supreme Court in the case of CIT vs. Hotel
Blue Moon 321 ITR 362 (SC) and submitted that the proceedings are
bad in law.
The ld DR, to meet this foundational objection raised in the
additional ground that the AO did not issue the mandatory notice u/s
143(2) of the Act within the statutory allowable period, produced the
assessment record. To examine the issue of notice, we perused the
assessment record from where we find that an order sheet has been
maintained detailing the issuance of notices u/s 143(2)/142(1). The
same is reproduced as under:
“M/s Gazel Caterers AY 2009-10
20.08.2010 Notice u/s 143(2) issued on 07.07.2010
31.08.2010 Notice return back unserved
10.09.2010 Notice u/s 115(WF) issued
15.09.2010 Unserved Notice return back
23.09.2010 Notice u/s 143(2) issued
29.09.2010 Unserved Notice return back
22.10.2010 Notice u/s 142(1) issued
29.10.2010 Unserved Notice return back
10.08.2011 Issue notice u/s 142(1) of the Act and fixing the case for 26.8.2011
26.08.2011 None attended
04.11.2011 show cause penalty u/s 271(1)(b) and notice u/s 143(2) of the Act issued and fixing the case for 14.11.2011”
From the examination of assessment record, it is seen that
notices u/s 143(2) was issued twice before the prescribed time period,
once on 20.08.2010 and second on 23.09.2010 to the assessee at the
address given in the ITR. Both the time, the notices were returned
unserved with remark of the postal Department on the envelope as
‘left’. Ultimately, the assessee appeared before the AO on 25.11.2010
in response to the notice u/s 143(2) issued on 4.11.2010. Thereafter
the counsel of the assessee participated in the proceedings under
section 143(3) till its culmination on 16.12.2010.
The facts culled out from the assessment record refute the claim
of the assessee that Notice u/s 143(2) was issued after expiry of 6
months from the end of FY 2009-10. In fact, the notices u/s 143(2) was
issued twice before the prescribed time period which could not be
served on the assessee on account of postal Department findings that
the assessee has ‘left’.
The assessee did not take up the issue of service of notice u/s
143(2) beyond the prescribed period before the AO nor he raked up
this issue before the CIT(A). This is the first time it is raising this
jurisdictional ground before us. Be that as it may, in the facts of the
instant case, we find therefore, that the ld counsel of the assessee’s
reliance on the decision of the Supreme Court in the case of Hotel Blue
Moon is distinguishable.
In the instant case as demonstrated above, the notice u/s 143(2)
was issued twice within the time period prescribed under the law while
no notice u/s 143(2) was issued in the case of M/s Hotel Blue Moon.
These notices could not be served as the postal department returned
the notices with the remark ‘left’. It is therefore not a case where
notice u/s 143(2) was not issued at all and incurable procedural
irregularity was committed by the AO. It is exactly the kind of case
which was delineated upon by the Hon’ble Supreme Court in CIT v. Laxman Das Khandelwal [2019] 417 ITR 325(SC) where it has
laid down that applicability of the provision of section 298BB as under:
"7. A closer look at section 292BB shows that if the assessee has participated in the proceedings it shall be deemed that any notice which is required to be served upon was duly served and the assessee would be precluded from taking any objections that the notice was (a) not served upon him; or (b) not served upon him in time; or (c) served upon him in an improper manner. According to Mr. Mahabir Singh, learned Senior Advocate, since the Respondent had participated in the proceedings, the provisions of section 292BB would be a complete answer.
On the other hand, Mr. Ankit Vijaywargia, learned Advocate, appearing for the Respondent submitted that the notice under section 143(2) of the Act was never issued which was evident
from the orders passed on record as well as the stand taken by the Appellant in the memo of appeal. It was further submitted that issuance of notice under section 143(2) of the Act being prerequisite, in the absence of such notice, the entire proceedings would be invalid.
The law on the point as regards applicability of the requirement of notice under section 143(2) of the Act is quite clear from the decision in Hotel Blue Moon's case (supra). The issue that however needs to be considered is the impact of section 292BB of the Act.
According to section 292BB of the Act, if the assessee had participated in the proceedings, by way of legal fiction, notice would be deemed to be valid even if there be infractions as detailed in said section. The scope of the provision is to make service of notice having certain infirmities to be proper and valid if there was requisite participation on part of the assessee. It is, however, to be noted that the Section does not save complete absence of notice. For section 292BB to apply, the notice must have emanated from the department. It is only the infirmities in the manner of service of notice that the Section seeks to cure. The Section is not intended to cure complete absence of notice itself.
Since the facts on record are clear that no notice under section 143(2) of the Act was ever issued by the Department, the findings rendered. by the High Court and the Tribunal and the conclusion arrived at were correct. We, therefore, see no reason to take a different view in the matter.
These Appeals are, therefore, dismissed. No costs."
The hon’ble Delhi High Court in the case of Principal
Commissioner of Income-tax (Central)v Grand Express Developers (P.)
Ltd[2024] 158 taxmann.com 24 (Delhi)quoting as above from the
decision of the hon’ble Supreme Court in the case Laxman Das
Khandelwal (supra), held that the application of section 292BBon the
issue of service of notice is no longer res integra.
In the instant case the notice/s 143(2) was issued, though
unserved, within the time prescribed. The assessee was served the
notice u/s 143(2) dated 5.11.2010 and in response to which the
assessee participated in the assessment proceedings. In view of the
factual matrix that emerges from the examination of assessment
record and respectfully following the decision of the hon’ble Supreme
Court in the case Laxman Das Khandelwal(supra), we are of the
considered opinion that assessment proceedings is saved by the
provision of section 292BB and consequently the same has to be held as
validly conducted. The additional ground of the assessee is accordingly
dismissed.
We now proceed to decide the grounds taken by the assessee on
merits. Ground No. 1relates to the addition sustained by Ld. CIT(A) to
the tune of Rs.60,000/- on account of introduction of capital by two
partners i.e. (i) Mr. Rahul Khurana – Rs.10,000/- and (ii) Mr. Ishan
Khurana – Rs.50,000/-.
The ld. counsel for the assessee vehemently submitted that
during the impugned year, the partners have introduced capital in the
assessee firm out of which Ld. CIT(A) has sustained the addition made
by the Assessing Officer for the capital introduced by two partners as
under:
Addition made Addition by Assessing sustained by Partner’s Name Officer CIT(A) Mr. Rahul Khurana 2,50,000 10,000 Mr. Ishan Khurana 50,000 50,000 TOTAL 2,60,000 60,000
In order to justify the above additions made by the partners, the
assessee firm filed copy of confirmed copy of ledger account of both
the partners containing amount received as capital from partners
showing inter-alia name, address and PAN of the partner along with
copy of returns and vehemently contended that these evidences
establish the nature and source of credit and hence the firm is
absolved from any further liability.
It was vehemently contended that the capital introduced by the
partners cannot be taxed in the hands of the assessee-firm u/s 68 of
the Act in absence of any material to indicate that these credits were
profits of the firm. The ld. counsel for the assessee placed reliance on
the following decisions:
(i) Darshan Enterprise vs. Additional/Joint/Deputy/Assistant Commissioner of Income-tax/Income-tax Officer, 134 taxmann.com 188 dated 03.01.2022 (Gujarat High Court) (ii) ITO vs. M/s. Nithyasudha Combines I.T.A. Nos.576 & 577/Chny/2020 dated 06.05.2022 (ITAT, Chennai Bench)
(iii) Commissioner of Income Tax, Allahabad Vs. Jaiswal Motor Finance, (1983), 141 ITR 706 (Allahabad High Court) (iv) Abhyudaya Pharmaceuticals vs. CIT, 350 ITR 358 (Allahabad High Court)
(v) Zafa Ahmed & Company vs. CIT, 93 DTR 29 (Allahabad High Court)
(vi) ITO Vs. Dhiman Systems, 100 TTJ 466 (ITAT, Amritsar Bench)
The ld. counsel for the assessee submitted that the case of the
assessee firm is directly covered by above judicial decisions and the
addition deserves to be deleted.
Per contra, the ld. DR relied upon the orders of the Assessing
Officer and the CIT(A).
We have heard the rival submissions and have perused the
relevant material on record. As regards the amount of Rs. 10,000/-
pertaining to Shri Rahul Khurana, the same was part of capital
introduced of Rs. 2,50,000/- in the assessee firm during the year under
consideration. Against this addition, the Shri Rahul Khurana had
withdrawn cash of Rs. 2,40,000/- which was accepted by the ld.
CIT(A).
However, the ld. CIT(A) sustained the addition to the extent of
Rs. 10,000/- on account of unexplained credit. It is the say of the ld.
counsel for the assessee that the assessee introduced Rs. 10,000/-
accumulated from the past savings. Shri Rahul Khurana has filed reply
dated 27.09.2013 against the notice u/s 133(6) of the Act and
confirmed the capital introduced in the assessee firm.
As regards the amount of Rs. 50,000/- by Shri Ishan Khurana, it is
submitted by the ld AR that Shri Ishan Khurana belongs to family having
multiple business of multi-core. Further, during A.Y 2008-09, Shri Ishan
Khurana earned salary income of Rs. 1,20,000/- from the assessee firm
which is evident from Tax Audit Report of A.Y 2008-09 and he also
confirmed the capital introduced in the assessee firm.
26.Per contra, the ld DR relied on the orders of ld CIT(A).
Having heard the rival submissions, we are of the considered
opinion that the assessee has discharged it’s onus of establishing the
source, nature and credit worthiness of the partners who introduced
the capital in the assessee firm. We also find force in the assessee
reliance on the decision of the Hon’ble Gujrat High Court case of M/s
Darshan Enterprise (supra) where it held that once the Firm gives a
satisfactory explanation and produces the person who has deposited
the amount, the burden of the firm is discharged and credit entry
cannot be treated as income u/s 68 of the firm. In that view of the
matter, we have no hesitation in deleting the addition on the basis of
facts and circumstances of the case. Ground No. 1 is allowed.
Ground No. 2relates to the aggregate addition of Rs.3,85,000/-
u/s 68 of the Act being the closing balances of 4 parties viz. (i) Mr.
Atul Bhatia – Rs. 70,000/-, (ii) Sh. S.K. Bhatia – Rs. 40,000/-, (iii) Smt.
Sunita Malik – Rs. 1,25,000/- and (iv) Sh. Yad Ram Kundu – Rs.
1,50,000/- in the nature of unsecured loans sustained by ld. CIT(A) by
alleging the same to be unexplained.
Before us, the ld. counsel for the assessee vehemently stated
that the loan of Rs.50,000/- from Shri Atul Bhatia only pertains to the
year under consideration out of total unsecured loan amounting to
Rs.3,85,000/- and the balance amount is pertaining to previous years
as evident from the confirmed copy of ledger accounts. Therefore, the
addition to the extent of Rs.3,35,000/- cannot be made in the
impugned year and hence is not valid, unjustified and requires to be
deleted. In this connection, the ld. counsel for the assessee placed
reliance on the decision of ITAT, Mumbai Bench in the case of ITO vs.
Shri Nasir Khan J. Mahadik in ITA No. 153/Mum/2010 order dated
30.11.2011.
The ld. counsel for the assessee submitted that the assessee firm
has taken loan of Rs. 50,000/- from Mr. Atul Bhatia during the
impugned year through banking channels and balance Rs.20,000/- is
pertaining to A.Y 2008-09 i.e. not to the relevant assessment year. To
support his contention, the ld. counsel for the assessee furnished
confirmed copy of ledger account of Shri Atul Bhatia containing
amount received as loan showing inter-alia name, address and PAN of
Shri Atul Bhatia. Copy of extract of bank statement of Mr. Atul Bhatia
showing transaction of Rs. 50,000/- during impugned year, copy of
Income Tax Return of Shri Atul Bhatia for AY 2012-13, copy of affidavit
of Shri Atul Bhatia and copy of schedule to balance sheet as on
31.03.2008 of the assessee firm showing details of unsecured loans.
The ld. counsel for the assessee further submitted that the
assessee firm has not taken any loan from Mr. S.K. Bhatia during the
year under consideration. The loan of Rs.40,000/- pertains to A.Y
2008-09 i.e. not to the relevant assessment year. Confirmed copy of
ledger account of Shri S.K. Bhatia containing opening balance of loan
showing inter-alia name, address and PAN of Shri S.K. Bhatia along
with copy of PAN card of Shri S.K. Bhatia were produced to support the
submissions. Copy of affidavit of Mr. S.K. Bhatia, copy of schedule to
balance sheet as on 31.03.2008 of the assessee firm showing details of
unsecured loans were also furnished.
The ld. counsel for the assessee further submitted that the
assessee firm has not been taken any loan from Smt Sunita Malik during
the year under consideration and the loan of Rs.1,25,000/- pertains to
A.Y. 2007-08 i.e. not to the relevant assessment year. Confirmed copy
of ledger account of Smt Sunita Malik containing opening balance of
loan showing inter-alia name, address and PAN of Shri Sunita Malik
were produced. Copy of ITR and Computation of Income for A.Y 2009-
10, copy of affidavit, copy of schedule to balance sheet as on
31.03.2008 of the assessee firm showing details of unsecured loans
were also filed.
The ld. counsel for the assessee submitted that the assessee firm
has not received any loan from Mr. Yad Ram Kundu during the year
under consideration. Further, Rs.1,50,000/- from Shri Yad Ram Kundu
pertains to A.Y 2007-08 i.e. not to the relevant assessment year.
Confirmed copy of ledger account of Mr. Yad Ram Kundu containing
opening balance of loan showing inter-alia name, address and PAN of
Mr. Yad Ram Kundu, copy of Jamabandi, copy of affidavit of Shri Yad
Ram Kundu, copy of schedule to balance sheet as on 31.03.2008 of the
assessee firm showing details of unsecured loans were also furnished
which are on record.
After considering the exhaustive details and evidences submitted
by the ld. counsel for the assessee, we are of the opinion that the
assessee has successfully demonstrated that out of total unsecured
loan amount of Rs.3,85,000/- only an amount of Rs.50,000/- pertained
to the year under consideration and the balance amount pertained to
previous years. We are of considered opinion that the loans amount of
Rs 3,35,000/- pertaining to the previous years cannot be added u/s 68
in the instant year. Further, the assessee firm has duly explained the
nature and source of the balance Rs 50,000/- with confirmation ledgers
from the parties and established their creditworthiness from their
available ITRs and bank statement etc. We find that the assessee firm
has discharged its onus to substantiate the identity, creditworthiness
and genuineness of transactions and neither the AO nor the CIT(A) has
expressed doubts on the explanation furnished by the assessee with
regard to the transaction. In view of the matter, we are of the opinion
that the addition without having any adverse material against the
transactions is not justified. We have, therefore, no hesitation in
deleting the addition made by the Assessing Officer and sustained by
the ld. CIT(A).Accordingly, the addition is deleted. Ground No. 2 is
allowed.
The third ground is against aggregate addition of Rs.11,77,085/-
u/s 68 of the Act being the closing balances of 13 parties in the nature
of creditors sustained by the CIT(A) as unexplained.
Before us, the ld. counsel for the assessee vehemently stated
that the assessee firm has filed confirmation copy of ledger accounts
from all 13 parties containing name and address along-with PAN and
other ID Proofs and that the said confirmations have not been rejected
or doubted anywhere by both the authorities below.
The ld AR stated that Notice u/s 133(6) of the Act was not served
on the following creditors and therefore addition was confirmed by the
Ld. CIT(A) –
(i) Tanduriya (Bhura) – Rs. 74,400/- (ii) Tanduriya (Ali) – Rs. 30,400/- (iii) Ajit Singh – Rs. 1,58,850/- (iv) Sanjay (Fruit wala) – Rs. 61,150/- (v) Dishwasher (Shanker/Shyam Ray) – Rs. 68,700/- (vi) Halwai (Mohar Singh) – Rs. 1,17,900/- (vii) Jain Trading – Rs. 3,57,900/- (viii) L R Foods P Ltd. – Rs. 12,820/- (ix) Prabhat – Rs. 50,600/-.
With regard to above creditors, the ld AR submitted that the
assessee firm has filed explanation along with copy of confirmed ledger
accounts of all the parties in the paper book. Further, all the payables
are current in nature and duly paid by the assessee firm in the
subsequent years. To substantiate the facts, copy of confirmed ledger
account showing closing balance of Rs.74,400/- as on 31.03.2009,
Balance Sheet as on 31.03.2009showing the list of sundry creditors
including closing balance of Rs.74,400/- in the name of Mr. Tanduriya
(Bhura) were furnished in the Paper Book. Ledger account copy
showing Nil balance payable, copy of annexure of the Balance Sheet as
on 31.03.2011 which shows there is no balance payable in the name of
Mr. Tanduriya (Bhura) were also placed on record.
It was stated by the ld AR that same situation is with regard to
Shri Tanduriya (Ali)who furnished copy of confirmed ledger account
showing closing balance of Rs.30,400/- as on 31.03.2009, copy of
annexure of the Balance Sheet as on 31.03.2009 showing the list of
sundry creditors including closing balance of Rs.30,400/- in the name
of Shri Tanduriya (Ali).
Likewise, similar evidences were filed for all the other creditors.
It is submitted that in the case of Majibul Haq – addition to the tune of
Rs. 74,461/- was made, the party confirmed the amount as on
09.01.2009 and not on 31.03.2009. There is no transaction in the
impugned year which can be clearly seen from the copy of confirmed
ledger account containing name, address and PAN of Shri Majibul Haq,
filed by the assessee company. The last transaction was on 09.01.2009
and the balance confirmed by Mr. Majibul Haq is also the same as
shown by the appellant firm.
The ld. counsel for the assessee explained that addition to the
tune of Rs. 1,18,430/- does not pertain to the impugned year which is
clear from the confirmed ledger account of late Sh. Sewa Ram Sita
Ram by his legal heir wherein it is clearly shown that there is opening
balance of Rs. 1,93,430/- out of which Rs. 75,000/- has been
transferred through bank account. The son of Late Sh. Sewa Ram Sita
Ram Wadhwa stated that he had no knowledge of business dealing with
M/s Gazal Caterers. Payment has been made by the assessee firm even
after death of Shri Sewa Ram Sita Ram that has not been objected by
his son and the fact is also mentioned in the remand report reproduced
in the order of ld. CIT(A) at page 25 of his order.
The ld. counsel for the assessee also submitted that the creditors
from whom no response was submitted against the notices u/s 133(6)
of the Act issued by Assessing Officer are Sivalam Associates – Rs.
7,076/- and Svam Power Plant – Rs. 15,720/-. It was stated that
confirmed copy of ledger accounts have been filed by the assessee firm
containing the transactions and PAN of these person which were duly
accepted by the lower authorities. It is also submitted that the
payment has been made through banking channels during the AY 2010-
11 which is evident from ledger accounts and that in any case the
above accounts are running accounts and have been duly knocked off
in subsequent years.
It is the say of the counsel that the assessee is in the business of
catering and has to deal with small businessmen like Halwai, fruitwala,
Dishwasher etc who may not receive the notice or respond to the
notices u/s 133(6). The ld AR relied on the decision of hon’ble Delhi
High Court in the case of R.K.Jain Infra Projects P Ltd (2023) 293
Taxman 465 (Delhi) for the proposition that a pragmatic view be taken
where enquiry relates to migrant worker and enquiry u/s 133(6) after
considerable time gap would not have led to fruitful result.
Per contra the ld DR relied on the CIT(A) order.
Having heard the rival submissions and perusing the relevant
material on record, we find force in the contention of the ld. counsel
for the assessee that when purchases/expenses have been duly
accepted by ld. CIT(A) from the above parties, making addition in
respect of the closing balances of their accounts will not be lawful. We
also find that there is no adverse material on record with the Assessing
Officer and ld. CIT(A) to make the addition except the ground of no
response from the creditors. We also note that the confirmations and
explanation filed by the assessee firm have been duly accepted by the
lower authorities. We are of the opinion that this is a case where the
nature of business is such that the assessee is required to take
service/goods from small business person who do not maintain proper
accounts or adhere to the requirements of lawand that the ratio of the
hon’ble Delhi High Court in the case of R.K.Jain Infra Projects P Ltd
(supra) applies in the instant case.
Even though the assessee deals with numerous small business
person, it has furnished the explanations of each sundry creditors.
Without discrediting the explanation of the assessee and without
having in possession any adverse materials, the CIT(A) fell in error in
sustaining the addition. We, therefore, are of the opinion that the
addition made by Assessing Officer and confirmed by ld. CIT(A)
deserves to be deleted in the facts and circumstances of the case.
Ground No. 3 is allowed.
In the result, the appeal of the assessee in ITA No.
7752/DEL/2019 is partly allowed.
The order is pronounced in the open court on 13.06.2024.
Sd/- Sd/-
[SAKTIJIT DEY] [NAVEEN CHANDRA] VICE PRESIDENT ACCOUNTANT MEMBER
Dated: 13th JUNE, 2024 VL/
