“best judgment assessment”

Assessment ProceduresSection 144Section 1441,400 judgments

The decision most relied on for best judgment assessment is Kachwala Gems v. JCIT (288 ITR 10), cited in 332 judgments on BharatTax.

Leading authorities on best judgment assessment

Kachwala Gems v. JCIT

288 ITR 10 · 2007 · Supreme Court

332

citing judgments

In a best judgment assessment, some guesswork is inherent, but the estimate must be fair and not arbitrary. Books of account can be rejected under Section 145(3) if the assessee fails to substantiate entries or prove the genuineness of transactions, leading to estimation of income.

Commissioner of Sales Tax v. H.M. Esufali H.M. Abdulali

90 ITR 271 · 1973 · Supreme Court

232

citing judgments

The Supreme Court established principles for best judgment assessments, stating that some guesswork is inevitable but the assessment must be bona fide, rational, and free from bias or capriciousness. An appellate authority cannot substitute its judgment for that of the Assessing Officer unless the AO's assessment is shown to be biased, irrational, vindictive, or capricious, especially when the assessee fails to provide proper accounts or counter-evidence.

CIT v. Gurubachhan Singh J. Juneja

302 ITR 63 · 2008 · High Court

147

citing judgments

When unaccounted receipts or suppressed sales are detected and books of account are rejected under Section 145(3), additions to income must be restricted to the profit element embedded in such transactions, not the entire transaction value. This profit element is to be estimated by considering the assessee's regular profit ratio as per books of account.

Man Mohan Sadani v. CIT

304 ITR 52 · 2008 · High Court

132

citing judgments

When assessing income from undisclosed or unrecorded sales, the entire sale proceeds cannot be added to the assessee's income; instead, only the net profit embedded in such unaccounted sales, determined by applying the assessee's net profit rate, should be taxed.

Brij Bhushan Lal Paraduman Kumar v. CIT

115 ITR 524 · 1978 · Supreme Court

113

citing judgments

The Supreme Court holds that an Assessing Officer, when making a best judgment assessment or estimating income, must act fairly, honestly, and rationally, basing the estimation on available material and avoiding arbitrary or capricious decisions. Adherence to natural justice principles is crucial during assessment proceedings.

CIT v. Laxminarain Badridas

5 ITR 170 · 1937 · Supreme Court

citing judgments

An income tax officer making a best judgment assessment must act honestly, not dishonestly, vindictively, or capriciously. They must make a fair estimate of the assessment, considering local knowledge, repute, and previous assessments.

State of Kerala v. C. Velukutty

60 ITR 239 · 1966 · Supreme Court

citing judgments

A best judgment assessment must be based on wisdom, truth, and legal principles, not arbitrary caprice. While it involves estimation and guesswork, this must have a reasonable nexus to available material and the case's circumstances.

Shankar Khandasari Sugar Mills v. CIT

193 ITR 669 · 1992 · High Court

citing judgments

Best judgment assessments under Section 144 must be a fair and rational estimation of income by the Assessing Officer, not capricious or arbitrary. Appellate authorities should accept clarificatory evidence to test the fairness of such assessments, even if produced for the first time.

Judgments citing best judgment assessment

Response India Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 2071/KOL/2024[2006-2007]Status: DisposedITAT Kolkata28 Nov 2024AY 2006-2007

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2071/Kol/2024 Assessment Year: 2006-07 Response India Pvt. Ltd.……………........………………....Appellant 103, Tivoli Court, 1C Ballygunge Circular Road, Ballygunge, K Kolkata – 700019. [Pan: Aaccr6178B] Vs. Dcit, Circle-11(1), Kolkata...…….…............................…..…..... Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Assessee. Shri Abhijit Adhikari, Jcit, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : November 28, 2024 Date Of Pronouncing The Order : November 28, 2024 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.08.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Filed Its Original Return Of Income Declaring A Total Income Of Rs.3,06,250/-. The Assessment Was Completed U/S 143(3) Of The Act. Subsequently, The Assessing Officer Recorded Reasons To Believe That Certain Income Has Escaped Assessment. Subsequently, Proceedings U/S 147 Of The Act Was Initiated After Obtaining Requisite Approval From The Competent Authority U/S 151 Of The Act. The Assessee Through A Letter Dated 06.11.2012 Requested That The Original Return To Be Treated As Return Filed In Compliance To The Notice U/S 148. Subsequently, Notices U/S 143(2) & 142(1) Of The Act Were Issued To The Assessee. In Compliance To The

Section 143(2)Section 143(3)Section 144Section 147Section 148Section 151Section 250

discrepancy of Rs.23,80,948/. As the assessee has failed to provide credible evidence to reconcile this difference, the Assessing Officer passed best judgment assessment u/s 144 r.w.s. 147 of the Act. 3. Aggrieved by the above order, the assessee filed an appeal before the ld. CIT(A) but failed

Paresh R Pujara HUF, Mumbai vs. Income Tax Officer-Ward-27(2)(5), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 4231/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Nov 2024AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Paresh R Pujara Huf Ito Ward 27(2)(5) Room No. 421, 4Th Floor, A-3/10, Chitaranjan Nagar, Rajawadi Ghatkopar (E), Tower No. 6, Vashi Railway Station, Vs. Mumbai-400 077 Commercial Complex, Vashi, Mumbai-400 703 Pan/Gir No. Aajhp 4668 L (Assessee) : (Respondent) Assessee By : Shri Shashank Mehta : Shri Tushar Mohite Respondent By : 17.10.2024 Date Of Hearing Date Of Pronouncement : 28.11.2024 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) (‘Ld.Cit(A) For Short),National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. In The Facts & Circumstances Of The Case & In Law, The Learned National Faceless Appeal Centre (Nfac), Cit (Appeals) Has, Erred In Upholding The Assessment Order Passed In Gross Violation Of The Principle Of Natural Justice. 2. In The Facts & Circumstances Of The Case & In Law, The Learned National Faceless Appeal Centre (Nfac), Cit (Appeals) Has Erred In Dismissing The Appeal Without Condoning The Delay In Filing The Appeal. 3. In The Facts & Circumstances Of The Case & In Law, The Learned National Faceless Appeal Centre (Nfac), Cit (Appeals), Mumbai Has Erred In Upholding The Addition Of Rs.

For Appellant: Shri Shashank MehtaFor Respondent: 17.10.2024

Section 142(1)Section 144Section 250Section 69A

Assessing Officer (ld. A.O. for short) passed the assessment order u/s. 144 of the Act vide order dated 30.09.2019 being the best judgment assessment for the reason that the assessee was non compliant during the assessment proceedings and determined the total income at Rs. 12,37,080/- after making

Income Tax Officer-1(1)(3), Mumbai vs. Gas and Power Investment Company Limited, Mumbai

In the result, this appeal filed by the revenue is dismissed

ITA 2580/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Nov 2024AY 2014-15

Bench: Shri. Amarjit Singh, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Himanshu GandhiFor Respondent: Shri. Suresh Gaikwad – Sr. AR

Section 147Section 148Section 194Section 250Section 43BSection 617

compliant during the assessment proceedings, the ld. AO passed the assessment order dated 31.03.2022 u/s. 147 r.w.s. 144 r.w.s. 144B being the best judgment assessment and determined the total income at Rs. 140,49,65,231/- making an addition on income from other sources. 7. Aggrieved the assessee

Income Tax Officer-1(1)(3), Mumbai vs. Gas and Power Investment Company Limited, Mumbai

In the result, this appeal filed by the revenue is dismissed

ITA 2577/MUM/2024[2015]Status: DisposedITAT Mumbai28 Nov 2024

Bench: Shri. Amarjit Singh, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Himanshu GandhiFor Respondent: Shri. Suresh Gaikwad – Sr. AR

Section 147Section 148Section 194Section 250Section 43BSection 617

Income Tax Officer-1(1)(3), Mumbai vs. Gas and Power Investment Company Limited, Mumbai

In the result, this appeal filed by the revenue is dismissed

ITA 2575/MUM/2024[2016]Status: DisposedITAT Mumbai28 Nov 2024

Bench: Shri. Amarjit Singh, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Himanshu GandhiFor Respondent: Shri. Suresh Gaikwad – Sr. AR

Section 147Section 148Section 194Section 250Section 43BSection 617

Income Tax Officer-1(1)(3), Mumbai vs. Gas and Power Investment Company Limited, Mumbai

In the result, this appeal filed by the revenue is dismissed

ITA 2572/MUM/2024[2017]Status: DisposedITAT Mumbai28 Nov 2024

Bench: Shri. Amarjit Singh, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Himanshu GandhiFor Respondent: Shri. Suresh Gaikwad – Sr. AR

Section 147Section 148Section 194Section 250Section 43BSection 617

Asstt.Commissioner of Income Tax Circle-5, Nagpur vs. The Nirmal Ujwal Credit Co-Op Society Ltd, Nagpur

In the result, appeal filed by the Revenue for the assessment year

ITA 390/NAG/2019[2012-13]Status: HeardITAT Nagpur27 Nov 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Vikash Agrawal

Section 139(1)Section 143(1)Section 143(2)Section 80PSection 80P(2)

that if Assessing Officer is not satisfied about the completeness or correctness or accounting method used by the assessee, he can resort to best judgment assessment. In this case the Assessing Officer in current year as well as preceding years have accepted accounting method followed by the appellant. In most

Pukar Seva Pratishthan, Mumbai vs. Commissioner of Income Tax Exemption, Pune

In the result, appeal of the assessee is allowed for statistical purposes

ITA 5371/MUM/2024[2023-24]Status: DisposedITAT Mumbai27 Nov 2024AY 2023-24

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri R.D. Khona, CAFor Respondent: Shri R.A. Dhyani, CIT DR

Section 12ASection 12A(1)(ac)Section 80G

aside. 5. That where Assessing Officer issued statutory show cause notices to assessee at e mail address which was not in use, impugned best judgment assessment order deserved to be set aside. (Bengal & Assam Company Ltd v. National Faceless Assessment Centre-154 taxmann.com 130 (Delhi) dt. July ... aside. 4. That where Assessing Officer issued statutory show cause notices to assessee at e- mail address which was not in use, impugned best judgment assessment order deserved to be set aside. (Bengal & Assam Company Ltd v. National Faceless Assessment Centre-154 taxmann.com 130 (Delhi) dt. July

Pukar Seva Pratishthan, Mumbai vs. Commissioner of Income Tax Exemption, Pune

In the result, appeal of the assessee is allowed for statistical purposes

ITA 5370/MUM/2024[2023-24]Status: DisposedITAT Mumbai27 Nov 2024AY 2023-24

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri R.D. Khona, CAFor Respondent: Shri R.A. Dhyani, CIT DR

Section 12ASection 12A(1)(ac)Section 80G

Rajashthani Rawal Brahman Samaj Vikas Mandal, Mumbai vs. Commissioner of Income Tax (Appeals)-Income Tax Dept, Mumbai

ITA 3416/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Nov 2024AY 2017-18

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Rajasthani Rawal Brahman Samaj Commissioner Of Income Tax Vikas Mandal (Appeals) Income Tax Dept. Nfac 17, Om Shree Sai Darshan, Kailash Income Tax Officer, Circle 3, Vs. Nagar, Koper Cross Road, Opp. Kalyan, Maharashtra – 421306. Sakharam Complex, Dombivali (W), Thane – 421202. Pan/Gir No. Aacar 9376 B (Assessee) : (Respondent) Assessee By : None : Shri. R. R. Makwana Sr. Dr. Respondent By Date Of Hearing : 15.10.2024 Date Of Pronouncement : 27.11.2024 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals), Delhi (‘Ld.Cit(A) For Short),National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2017-18. 2. As There Was No Representation On Behalf Of The Assessee, We Hereby Dispose Of This Appeal By Hearing The Learned Departmental Representative ('Ld.Dr' For Short) & On Perusal Of The Materials Available On Record. 3. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: None

Section 144Section 250Section 69A

notices issued by the ld. AO and hence, the ld. AO proceeded to pass the assessment order u/s. 144 being the best judgment assessment vide order dated 25.11.2019 determining total income at Rs. 17,94,210/- after making an addition

Income Tax Officer, Ward 1, Ballari vs. Sha Ganeshmal Jewarraj Bohra, Koppal

In the result, both the appeal by the revenue and the CO by the assessee are dismissed

ITA 1202/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 Nov 2024AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar S.V., AdvocateFor Respondent: Shri Sridhar E., Jt.CIT(DR)(ITAT), Bengaluru

Section 115BSection 131Section 148Section 68

Taxman 405. The issue before the Court, in brief, was that the ITO framed the best judgment assessment under section 144 relying upon the material from the Commercial Tax Department relating to the turnover of the assessee. Before the Commissioner (Appeals), the assessee produced S.T. assessment order for the first ... revenue by considering the material produced by the assessee. A consideration of such a material by the appellate authority would have rendered the best judgment assessment, a fair proceeding and the resultant assessment order would have been a most rational one. ITA No.1202 & CO 30/Bang/2024 Page

Ar Associates, Hyderabad vs. ITO., Circle-6(1), Hyderabad

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 819/HYD/2024[2017-18]Status: DisposedITAT Hyderabad21 Nov 2024AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita No 817 To 819/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16 To 2017-18) Ar Associates Vs. Income Tax Officer Hyderabad Circle 6 (1) Pan:Aavfa2434K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Hari Agarwal, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 21/11/2024 आदेश/Order

For Appellant: Shri Hari Agarwal, CAFor Respondent: : Shri Gudimella V P Pavan

Section 147Section 148Section 250Section 271BSection 44ASection 44B

which was not responded by the assessee. Consequently, the Assessing Officer framed the assessment u/s 147 r.w.s. 144 of the Act, as “best judgment assessment” whereby the income of the assessee was estimated by the Assessing Officer by taking net profit @ 8% and further additions were made. Since the assessee

Ar Associates, Hyderabad vs. ITO., Circle-6(1), Hyderabad

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 818/HYD/2024[2016-17]Status: DisposedITAT Hyderabad21 Nov 2024AY 2016-17

For Appellant: Shri Hari Agarwal, CAFor Respondent: : Shri Gudimella V P Pavan

Section 147Section 148Section 250Section 271BSection 44ASection 44B

Ar Associates, Hyderabad vs. ITO., Circle-6(1), Hyderabad

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 817/HYD/2024[2015-16]Status: DisposedITAT Hyderabad21 Nov 2024AY 2015-16

For Appellant: Shri Hari Agarwal, CAFor Respondent: : Shri Gudimella V P Pavan

Section 147Section 148Section 250Section 271BSection 44ASection 44B

Assistant Commissioner of Income Tax, Delhi vs. Rajan Sehgal, Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 2173/DEL/2024[2016]Status: DisposedITAT Delhi20 Nov 2024

Bench: Shri Saktijit Dey, Hon’Ble & Shri S. Rifaur Rahman

For Appellant: Shri Sunil Kapoor, AdvocateFor Respondent: Ms. Ambika Aggarwal, Sr. DR

Section 143(3)Section 144Section 144CSection 144C(2)Section 147Section 69

claim.” 9. At the time of hearing, ld. DR for the Revenue submitted that the assessment under consideration is passed under best judgment assessment u/s 144 of the Act. The Assessing Officer has passed draft assessment order on 15.03.2022 and assessee has filed new evidences after draft assessment passed

Assistant Commissioner of Income Tax, New Delhi vs. Rajan Sehgal, Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 2172/DEL/2024[2015-16 ]Status: DisposedITAT Delhi20 Nov 2024

Bench: Shri Saktijit Dey, Hon’Ble & Shri S. Rifaur Rahman

For Appellant: Shri Sunil Kapoor, AdvocateFor Respondent: Ms. Ambika Aggarwal, Sr. DR

Section 143(3)Section 144Section 144CSection 144C(2)Section 147Section 69

Rajendra Pratap Yadav, Lucknow vs. Commissioner of Income Tax(Appeals), NFAC

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 614/LKW/2024[2017-18]Status: DisposedITAT Lucknow14 Nov 2024AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Rajendra Pratap Yadav V. The Cit(A) 21/202, Indira Nagar Nfac Lucknow Tan/Pan:Acmpy9678E (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 12 11 2024 Date Of Pronouncement: 14 11 2024 O R D E R

For Appellant: NoneFor Respondent: Shri Sanjeev Krishna Sharma, D.R

Section 133(6)Section 142(1)Section 144Section 271ASection 69A

provisions of section 144 of the Act may not be invoked in his case and the assessment be completed on best judgment assessment, on the basis of material available on record. Finally, the assessee submitted the copy of return for the year under consideration filed on 02.12.2019, along with written

Sukhjit Singh, Mohali vs. ITO, Ward 6(4), Mohali

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 349/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh14 Nov 2024AY 2012-13

Bench: Shri Sanjay Gargआयकरअपीलसं./I.T.A. No. 349/Chd/2024 िनधा"रणवष" / Assessment Year : 2012-13 Shri. Sukhjit Singh बनाम Income Tax Officer Prop. M/S Saini Telecom Ward 6(4), Mohali Chandigarh Road, Kurali, Sas Nagar, Mohali, Punjab "ायीलेखासं./Pan No: Bplps 5747F अपीलाथ"/Appellant ""थ"/Respondent (Physical Hearing) िनधा""रतीकीओरसे/Assessee By : Shri Aman Parthi, Adv. राज"कीओरसे/ Revenue By : Dr. Ranjeet Kaur, Sr. D.R. सुनवाईकीतारीख/Date Of Hearing : 12.11.2024 उदघोषणाकीतारीख/Date Of Pronouncement : 14.11.2024 आदेश/Order The Present Appeal Has Been Preferred By The Assessee Against The Order Passed By The Ld. Commissioner Of Income Tax, Appeal Addl/Jcit(A)-1, Nagpur Dated 05.02.2024 For The Assessment Year: 2012-13. The Assessee In This Appeal Is Aggrieved By The Action Of The Ld. Cit(A) In Confirming The Additions Made By The Assessing Officer Af Rs.48.80 Lacs On Account Of Unexplained Cash Deposits In The Bank Account Of The Assessee.

For Appellant: Shri Aman Parthi, AdvFor Respondent: Dr. Ranjeet Kaur, Sr. D.R

Section 144

आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ,च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL ‘SMC’ BENCH, CHANDIGARH BEFORE SHRI SANJAY

Mina, Kurukshetra vs. ITO, W-2, Kurukshetra

In the result, the appeal of the assessee stands allowed

ITA 778/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh14 Nov 2024AY 2011-12

Bench: Shri Sanjay Gargआयकरअपीलसं./I.T.A. No. 778/Chd/2023 िनधा"रणवष" / Assessment Year : 2011-12 Mina, H.N. 852, Vill. बनाम Jurisdictional Income Tax Mathana, Teh. Thanesar, Officer Ward-1, Kurukshetra, Haryana Kurukshetra 136131 "ायीलेखासं./Pan No: Bwdpm 8399G अपीलाथ"/Appellant ""थ"/Respondent

For Appellant: Shri. Parikshit Aggarwal, C.AFor Respondent: Dr. Ranjeet Kaur, Sr. D.R

Section 144

आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ,च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL ‘SMC’ BENCH, CHANDIGARH BEFORE SHRI SANJAY

Income Tax Officer, Ward 1, Puducherry vs. Saranya Agro Foods Private Limited, Puducherry

In the result, appeal filed by the Revenue stands dismissed

ITA 397/CHNY/2024[2016-17]Status: DisposedITAT Chennai14 Nov 2024AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. G. Natarajan, CAFor Respondent: Mr. P. Krishna Kumar, JCIT

Section 142(1)Section 144Section 44A

Rs.27,46,73,849/- i.e. Rs.2,19,73,907/- in place of the returned income of Rs.1,95,460/- u/s.144 of the Act (best judgment assessment). 5. Aggrieved, the Revenue preferred an appeal before the Ld.CIT(A) who was pleased to delete the same. 6. Aggrieved, the Revenue ... details called for by the AO M/s.Saranya Agro Foods Pvt. Ltd. :: 4 :: and despite that to its surprise, it received the best judgment assessment order dated 30.12.2018 rejecting the books of accounts and computing the income @8% on gross receipts to the tune of Rs.2,19,73,907/- in place