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“furnishing inaccurate particulars”

PenaltySection 271(1)(c)Section 271(1)(c)2,073 judgments

The decision most relied on for furnishing inaccurate particulars is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on furnishing inaccurate particulars

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 248 · 2016 · Supreme Court
953
citing judgments

A notice issued under Section 274 read with Section 271(1)(c) is invalid if it fails to specify whether penalty proceedings are for concealment of particulars of income or furnishing inaccurate particulars of income. Such lack of specificity vitiates the penalty proceedings.

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Mr. Mohd. Farhan A. Shaikh v. ACIT
434 ITR 1 · 2021 · High Court
672
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify the exact charge by not striking off the irrelevant limb (concealment of income or furnishing inaccurate particulars of income). Such an omnibus or vague notice renders the penalty proceedings bad in law, and any penalty imposed on its basis is liable to be quashed.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing furnishing inaccurate particulars

Titan Laboratories Pvt Ltd, Ghatkopare (E) vs. ACIT-14(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 3268/MUM/2023[2010-11]Status: DisposedITAT Mumbai29 Jan 2024AY 2010-11

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No. 3268/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) M/S. Titan Laboratories Pvt. बिधम/ Acit, Circle-14(3)(1) Ltd. Aayakar Bhavan, M. K. Vs. A/01-Gf & A/101 Plot No. Road, Mumbai-400020. 120, Anand Bhavan Road, Spectrum Building, Rb Mehta Marg, Tilak Road, Ghatkopare (E), Mumbai- 400077. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aacct0509Q (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Ravindra Poojari Revenue By: Shri P. D. Chougule (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 23/01/2024 घोषणा की तारीख /Date Of Pronouncement: 29/01/2024 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), Delhi Dated 30.08.2023 For The Assessment Year 2010-11. 2. The Main Grievance Of The Assessee As Discernable From Perusal Of Grounds Of Appeal Is Against The Action Of The Ld. Cit(A) Confirming The Penalty Levied By The Ao U/S 271(1)(C) Of The Income Tax Act, 1961, Act (Hereinafter “The Act”) To The Tune Of Rs.14,88,214/-.

For Appellant: Shri Ravindra PoojariFor Respondent: Shri P. D. Chougule (Sr. AR)
Section 271(1)(c)Section 274

whether the notice (proposing penalty) was issued against the assessee for (i) have concealed the particulars of your income (ii) or for furnishing inaccurate particulars of such income. Since we note that both the faults have been spelled out without striking down the in-applicable faults on which assessee

Vineet Mittal, Mumbai vs. DCIT Cent . Cir 3(3), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2428/MUM/2021[2013-14]Status: DisposedITAT Mumbai25 Jan 2024AY 2013-14

Bench: Shri Narendra Kumar Choudhry, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 10(38)Section 132Section 143(1)Section 143(2)Section 148Section 153A

unexplained cash credit u/s 68 of IT Act, 1961. Penalty proceedings under section 271(1)(c) of the Act are separately initiated for furnishing inaccurate particulars of income. Further, accommodation entry charges in the form of commission are paid in cash to entry operators. The source of cash

Vineeet Mittal, Mumbai vs. DCIT Cent. Cir 3(3), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2427/MUM/2021[2014-15]Status: DisposedITAT Mumbai25 Jan 2024AY 2014-15

Bench: Shri Narendra Kumar Choudhry, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 10(38)Section 132Section 143(1)Section 143(2)Section 148Section 153A

unexplained cash credit u/s 68 of IT Act, 1961. Penalty proceedings under section 271(1)(c) of the Act are separately initiated for furnishing inaccurate particulars of income. Further, accommodation entry charges in the form of commission are paid in cash to entry operators. The source of cash

DCIT, Circle-4(2), New Delhi vs. Bombardier Transportation India P.Ltd, New Delhi

ITA 1262/DEL/2022[2011-12]Status: DisposedITAT Delhi25 Jan 2024AY 2011-12

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharmadcit Vs. Bombardier Transportation India P. Ltd. Room No.398, 3Rd Floor, Novotel Pullman, C.R. Building, Hotel Commercial Tower, Aerocity, New Delhi. Delhi International Airport, New Delhi. Pan No.Aaaca5584C (Appellant) (Respondent)

Section 250(6)Section 271(1)(c)

Revenue has challenged the deletion of penalty of Rs.33,47,40,340/- levied u/s 271(1)(c) of the Act for furnishing inaccurate particulars of its income. 3. At the time of hearing, it transpired that the Tribunal by its order dated 09.08.2019 in ITA No.1358/Del/2017 for the relevant assessment

DCIT-2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 3375/MUM/2023[2016-17]Status: DisposedITAT Mumbai24 Jan 2024AY 2016-17

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

added back to the total income of the assessee. Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which

DCIT 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 3374/MUM/2023[2017-18]Status: DisposedITAT Mumbai24 Jan 2024AY 2017-18

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

added back to the total income of the assessee. Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which

DCIT 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 3371/MUM/2023[2018-19]Status: DisposedITAT Mumbai24 Jan 2024AY 2018-19

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

added back to the total income of the assessee. Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax-2(3)(1), Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 1785/MUM/2023[2018-2019]Status: DisposedITAT Mumbai24 Jan 2024AY 2018-2019

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

added back to the total income of the assessee. Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax-2(3)(1), Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 1784/MUM/2023[2017-2018]Status: DisposedITAT Mumbai24 Jan 2024AY 2017-2018

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

added back to the total income of the assessee. Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax-2(3)(1), Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 1783/MUM/2023[2016-2017]Status: DisposedITAT Mumbai24 Jan 2024AY 2016-2017

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

added back to the total income of the assessee. Penalty proceedings u/s 271(1)(c) of the Act are initiated for furnishing inaccurate particulars of income." 30. The CIT(A) allowed the claim of the assessee stating that the services provided by the assessee is a banking service which

Schott Glass India P.Ltd, Mumbai vs. ITO 8(3)(1), Mumbai

In the result, ITA 7356/Mum/2014 of the appeals of the assessee are allowed for statistical purpose and ITA No

ITA 7356/MUM/2014[2007-08]Status: DisposedITAT Mumbai24 Jan 2024AY 2007-08

Bench: Shri Narender Kumar Choudhry & Shri Amarjit Singhschott Glass India Private Vs. Income Tax Officer 8(3)-1 Limited, Dynasty “A” Wing Room No. 201, Aayakar 303/304, 3Rd Floor, Bhavan, M.K. Road, Andheri Kurla Road, Mumbai – 400020 Andheri (E) Mumbai – 400 059 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcs8583L Appellant .. Respondent Schott Glass India Private Vs. Deputy Commissioner Of Limited, Dynasty “A” Wing Income Tax 8(3) 303/304, 3Rd Floor, Room No. 204, Aayakar Andheri Kurla Road, Bhavan, M.K. Road, Andheri (E) Mumbai – 400020 Mumbai – 400 059 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcs8583L Appellant .. Respondent Appellant By : Ketan Ved Respondent By : Mahesh Jiwade Date Of Hearing 12.12.2023 Date Of Pronouncement 24.01.2024 आदेश / O R D E R Per Amarjit Singh (Am): Both These Appeals Filed By The Assessee Are Directed Agasint The Different Orders Of Ld. Cit(A)-15, Mumbai. Since Both These Appeals

For Appellant: Ketan VedFor Respondent: Mahesh Jiwade
Section 143(2)Section 144C(1)Section 92C

orders in the assessee’s own case. The assessing officer has also initiated penalty proceedings u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income/concealment of income. Thereafter vide order u/s 271(1)(c) of the Act dated 25.03.2013 the assessing officer has levied penalty of Rs.290 ... specified the specific offence committed by the assessee by stating as to whether the assessee has concealed his particulars of income or had furnished inaccurate particulars of income. 3.1. We find that this issue is no longer res-integra in view of the Full Bench decision

Schott Glass India Pvt. Ltd., Mumbai vs. D.C.I.T. Circle 8(3), Mumbai

In the result, ITA 7356/Mum/2014 of the appeals of the assessee are allowed for statistical purpose and ITA No

ITA 2594/MUM/2012[2007-08]Status: DisposedITAT Mumbai24 Jan 2024AY 2007-08

Bench: Shri Narender Kumar Choudhry & Shri Amarjit Singhschott Glass India Private Vs. Income Tax Officer 8(3)-1 Limited, Dynasty “A” Wing Room No. 201, Aayakar 303/304, 3Rd Floor, Bhavan, M.K. Road, Andheri Kurla Road, Mumbai – 400020 Andheri (E) Mumbai – 400 059 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcs8583L Appellant .. Respondent Schott Glass India Private Vs. Deputy Commissioner Of Limited, Dynasty “A” Wing Income Tax 8(3) 303/304, 3Rd Floor, Room No. 204, Aayakar Andheri Kurla Road, Bhavan, M.K. Road, Andheri (E) Mumbai – 400020 Mumbai – 400 059 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcs8583L Appellant .. Respondent Appellant By : Ketan Ved Respondent By : Mahesh Jiwade Date Of Hearing 12.12.2023 Date Of Pronouncement 24.01.2024 आदेश / O R D E R Per Amarjit Singh (Am): Both These Appeals Filed By The Assessee Are Directed Agasint The Different Orders Of Ld. Cit(A)-15, Mumbai. Since Both These Appeals

For Appellant: Ketan VedFor Respondent: Mahesh Jiwade
Section 143(2)Section 144C(1)Section 92C

orders in the assessee’s own case. The assessing officer has also initiated penalty proceedings u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income/concealment of income. Thereafter vide order u/s 271(1)(c) of the Act dated 25.03.2013 the assessing officer has levied penalty of Rs.290 ... specified the specific offence committed by the assessee by stating as to whether the assessee has concealed his particulars of income or had furnished inaccurate particulars of income. 3.1. We find that this issue is no longer res-integra in view of the Full Bench decision

Eureka Outsourcing Solutions Pvt Ltd, Thane vs. Deputy Commissioner of Income Tax-Circle (1), Thane

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

ITA 2845/MUM/2023[2015-16]Status: DisposedITAT Mumbai23 Jan 2024AY 2015-16

Bench: Shri S Rifaur Rahman, Am & Ms. Kavitha Rajagopal, Jm Eureka Outsourcing Solutions Pvt. Ltd. Dy. Cit, Circle (1) 5Th Floor, High Street Cum Highland Thane Corporate Centre, Kapurbawadi, Vs. Thane-400 607

For Appellant: Shri Vijaykumar S. BiyaniFor Respondent: Shri P. D. Choughule
Section 143(3)Section 197Section 250Section 271(1)(c)Section 40A(2)(b)

disallowance of Rs.2,97,436/- made by the assessee instead of Rs.13,96,517/-. The ld. A.O. also initiated the penalty proceedings for furnishing inaccurate particulars of income. The ld. A.O. vide order dated 28.06.2018 levied penalty amounting to Rs.3 ... course of any proceedings under this Act, is satisfied that any person— (c )has concealed the particulars of his income or furnished inaccurate particulars of such income." A glance at this provision would suggest that in order to be covered, there has to be concealment of the particulars

Meka Ranganayakamma, Krishna District vs. Income Tax Officer, Ward-2(3), Vijayawada

In the result, appeal of the assessee is dismissed

ITA 119/VIZ/2023[2011-12]Status: DisposedITAT Visakhapatnam22 Jan 2024AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri GVN Hari, ARFor Respondent: Sri Madhukar Aves, Sr. AR
Section 139(1)Section 142(1)Section 148Section 271(1)(c)Section 50CSection 50GSection 54G

notice U/s. 271(1) is not valid because it has not been specified whether it was issued for concealment of income or furnishing inaccurate particulars of income and the specific item have not been ticked. However, it is seen from the penalty order that the penalty has been initiated

Radhe Developers (India) Ltd., Ahmedabad vs. The ACIT, Cir-3(1)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 45/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad19 Jan 2024AY 2015-16

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2015-16 Radhe Developers (India) Ltd. Acit, Cir.3(1)(2) 1St Floor, Chunibhai Chamber Vs Ahmedabad. B/H. City Gold Cinema Ashram Road Ahmedabad 380 009. Pan : Aaacr 9177 L

For Respondent: Ms.Saumya Pandey Jain, Sr.DR
Section 250(6)Section 271(1)(c)Section 36(1)(iii)

Assessing Officer has to give a clear finding as to whether the case is that of concealment of income or that of furnishing inaccurate particulars of income. In the absence of such specific finding, the penalty order was bad in law. iii) In the facts and in the circumstances ... wherein at para-4, the AO clearly mentions that he has reasons to believe that the assessee has furnished inaccurate particulars of income pertaining to the valuation of closing stock amounting to Rs.24,53,100/-. The same is reproduced hereunder: “4. As brought out in the assessment order, the assessee

India Flysafe Aviation Ltd., New Delhi vs. DCIT, Circle-12(1), New Delhi

The appeal of the assessee is allowed

ITA 1583/DEL/2019[2013-14]Status: DisposedITAT Delhi19 Jan 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2013-14

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Ms Meenakshi Dohare, Sr. DR
Section 143(3)Section 271(1)(c)

notice does not make it clear if the assessee was called upon to explain for concealment of particulars of income or for furnishing inaccurate particulars of income. 4. As we take into account the assessment order dated 26.02.2016, it comes up that in regard to disallowances made ... primarily recorded satisfaction that the assessee has furnished inaccurate particulars of income and, accordingly, on that basis, only the impugned order was passed. 5. Thus, there is substance in the contention of the ld. AR that in the absence of striking off specific limb in the notice, the notice

Assistant Commissioner of Income Tax, Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

In the result, the appeals of the Revenue for assessment year

ITA 2154/MUM/2023[2013-2014]Status: DisposedITAT Mumbai18 Jan 2024AY 2013-2014

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Ita Nos. 1688, 1687, 1686, 1685, 1683, 1684/Mum/2023 Assessment Years: 2014-15 To 2019-2020

For Appellant: Mr. Ajay R. Singh, &

initiated 271(1)C) of the Act is initiated separately for furnishing inaccurate separately for furnishing inaccurate particulars of income. particulars of income.” 5.2 On further appeal, the Ld. CIT(A) observed that contract was On further appeal, the Ld. CIT(A) observed that contract was On further appeal

Assistant Commissioner of Income Tax-CC-5(4), Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

ITA 2153/MUM/2023[2019-20]Status: DisposedITAT Mumbai18 Jan 2024AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

Section 37(1)Section 56

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SANDEEP

Assistant Commissioner of Income Tax-CC-5(4), Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

In the result, the appeals of the Revenue for assessment year

ITA 2152/MUM/2023[2015-16]Status: DisposedITAT Mumbai18 Jan 2024AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Ita Nos. 1688, 1687, 1686, 1685, 1683, 1684/Mum/2023 Assessment Years: 2014-15 To 2019-2020

For Appellant: Mr. Ajay R. Singh, &

initiated 271(1)C) of the Act is initiated separately for furnishing inaccurate separately for furnishing inaccurate particulars of income. particulars of income.” 5.2 On further appeal, the Ld. CIT(A) observed that contract was On further appeal, the Ld. CIT(A) observed that contract was On further appeal

Assistant Commissioner of Income Tax, Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

ITA 2151/MUM/2023[2018-2019]Status: DisposedITAT Mumbai18 Jan 2024AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Ajay R. Singh, &For Respondent: Smt. Sanyogita Nagpal, CIT-DR
Section 37(1)Section 56

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SANDEEP