Income Tax Appellate Tribunal - Amritsar
Euro Infrastructure & Power Limited, ... vs Department Of Income Tax on 19 July, 2016
IN THE INCOME TAX APPELLATE TRIBUNAL
AMRITSAR BENCH; AMRITSAR
BEFORE SH. A.D.JAIN, HON'BLE JUDICIAL MEMBER AND
SH. T.S. KAPOOR, HON'BLE ACCOUNTANT MEMBER
[
I.T.A No.319 (Asr)/2016
Assessment Year: 2012-13
Income Tax Officer, Vs. M/s Euro Infrastructure &
Ward-1(1), Bathinda. Power Limited, 3400-B
St. No.6/1, Power House Road,
Bathinda.
PAN:ABCE7889F
(Appellant) (Respondent)
Appellant by: Sh. S.S. Kanwal (DR)
Respondent by: Sh. P.N.Arora (Adv.)
Date of hearing: 13.07. 2016
Date of pronouncement: 19.07.2016
ORDER
PER T. S. KAPOOR (AM):
This is an appeal filed by Revenue against the order of learned CIT(A), Bathinda, dated 28.03.2016 for Asst. Year: 2012-13.
2. The Revenue is aggrieved with the action of learned CIT(A), by which he had deleted the additions made by Assessing Officer on account of difference in value in stock statements submitted to Bank and as submitted along with Income Tax Returns. The Revenue is further aggrieved with the action of learned CIT(A) by which he had deleted the addition made by Assessing Officer on account of notional interest on interest free loans given by assessee out of interest bearing borrowed funds.
2 ITA No.319 (Asr)/2016Asst. Year: 2012-13
3. At the outset, learned AR submitted that the issue of difference in stock statement has already been decided in favour of assessee in its own case by the consolidated order of Hon'ble Tribunal vide order dated 26.03.2015 and in this respect filed a copy of the said judgment. The learned AR invited our attention to ITA No.571(Asr)/2013 for Asst.
Year:2010-11 and submitted that the appeal of the Revenue for Asst.
Year:2010-11 was dismissed under the similar facts and circumstances.
Similarly, regarding non charging of interest, the learned AR submitted that this issue was also decided against the Revenue by the same judgment.
4. The learned DR acceded that the issues were covered in favour of assessee.
5. We have heard the rival parties and have gone through the material placed on record. We find that issue in the present appeal arose due to difference in value of stock given to Bank for obtaining cash credit limits and as per books of account of the assessee. The issue has been decided by the Hon'ble Tribunal in the case of assessee itself along with bunch of appeals wherein the Tribunal had taken the lead case of M/s Ishar Infrastructure Development (P) Ltd., Bathinda. The relevant findings of the Tribunal Order as contained in para 18 onwards are reproduced below.
"18. We have heard the rival contentions and perused the facts of the case. The Ld. DR while started the arguments initially took up the matter in the case of M/s. Ishar Infrastructure Developer (P) Ltd. for the assessment year 2009-10 being a lead case and argued that all other 3 ITA No.319 (Asr)/2016 Asst. Year: 2012-13 matters are identical and therefore, the decision in the case of M/s. Ishar Infrastructure Developer (P) Ltd. for the assessment year 2009-10 is to be followed in other appeals identically. However, the ld. Counsel for the assessee while arguing the matter argued from all the appeals separately and accordingly the ld. DR submitted that counter written submission dealing with each and every appeal, which has been reproduced hereinabove. Accordingly, we deal with matter as under:
19. The Ld. DR at page 2 to 6 of his written submissions dated 02.02.2015 reproduced hereinabove, as stated that the order of the ld.
CIT(A) is perverse because the findings given by the ld. CIT(A) that the Bank Authorioties are not concerned with the availability of adequate stock as their interests are covered by the collateral security provided by the assessee. If it is so why hypothecation of the stock is made by the bank whereas the Drawing Power is determined on the basis of the stock and not on the basis of collateral securities. The ld. CIT(A) ignored the statement of Senior Branch Manager of the same very Branch and the ld. CIT(A) has not doubted the correctness of the statement of Senior Branch Manager, which cannot be trashed without giving any cogent reasons. However, the ld. DR relied upon the statement of Sh.Tejinder Sharda and DP Register which was ignored by the ld. CIT(A). The ld. Counsel for the assessee has already given his submissions to the said arguments made by the ld. DR which has been considered by us and which has been reproduced hereinabove.
20. Our findings are based on the said arguments made by the ld. DR and the ld. Counsel for the assessee with regard to the said collateral securities and DP Register and the statement of Senior Branch Manager Sh.Tejinder Sharda and the stock statement filed by the assessee for the A.Y. 2009-10 on 02.02.2015 available at PB 12 & 13 which are unsigned . The ld. Counsel for the assessee has pointed out certain deficiencies in the DP register on which the ld. DR has placed heavy reliance but has not been rebutted by the ld. DR in his counter arguments or counter written submissions. The said deficiencies even though reproduced hereinabove by the ld. Counsel for the assessee in his written submissions i.e. vital information relating to physical verification of the stock has not been recorded and there is no column in the register for keeping the record that on which date stock statement has been received. The column for accountant initials is blank and column for inspection is mostly blank except initials in some of the columns and date of 19.01.2010 against the stock statement of 31.08.2009, 30.09.2009 and 31.10.2009 which shows the reality of physical verification of stock as on different dates of three months. The ld. Counsel further argued that column for full signature of incumbent incharge is also blank except starting from entries for the month of March 2009 to Dec., 2009 but no name of the person who did the initials can be made out.
21. As regards the statement of Senior Branch Manager, Sh. Tejinder Sharda, it was only a guess work that his predecessor must have gone through the modus operandi of maintaining the records by the bank as he 4 ITA No.319 (Asr)/2016 Asst. Year: 2012-13 was not in the branch of the bank during the relevant period. In fact, Bank does not have any record of any physical verification of the stock as on 31.03.2009 and the Drawing Power Register cannot be relied upon. That the assessee had in fact more stock as compared to the stock declared in the audited profit & loss account and books of account. In fact, a procedure has been stated by Sh.Tejinder Sharda of maintaining the Drawing Power Register and in fact, nothing has been brought on record to justify that the physical verification has been done. In fact, the present incharge of the bank, who allegedly as mentioned by the AO as verified the stock physically was never cross-examined and nothing has been brought on record by the AO or even by the ld. DR, Mr. Tarsem Lal that the stock which in all the cases mentioned hereinabove, which is lying at different sites, not at one place in one city but at different cities in different States. Not even a single documentary evidence was placed on record to establish that any Bank Officer has ever visited different sites and different cities in different States and that too on any date and there are no details available with the Bank Authorities with regard to the material, specifications and weighment and/or numbers of material available. Had it been verified physically, the same should have been there. The Ld. DR totally relied upon the DP register, a copy of which is part of the assessment order but the same is not backed by any documentary evidence which can prove that the physical verification has been done by any of the Bank Authorities at any point of time during the impugned year in any of the case mentioned hereinabove.
22. Much reliance has been placed on the statement of Bank Manager, Sh. Tejinder Sharda in the case of Munish Kumar Bansal Contractor but the AO has failed to prove that any physical verification has been made of the stock. However, a statement recorded of the Branch Manager in the case of Sh. Munish Kumar Bansal contractor, who has been assessed by the AO, the same cannot affect the assessment of the present appeal and cannot be blindly applied in the present appeal automatically. However, the matter in the case of Sh. Munish Kumar Banal Contractor, travelled upto the ITAT, Amritsar Bench and the ITAT, Amritsar Bench in its decision in ITA No.391(Asr)/2012 dated 12.09.2013 deleted the addition though the facts in that case were different..
23. The Ld. DR has tried to rebut the contention of the assessee that the actual physical verification of the stock has been done by the Bank Authorities by relying on DP Register which shows that the physical verification of the stock statement dated 31.03.2009 was made on 03.04.2009 (page 45). It was explained by the ld. counsel for the assessee that it was impossible for the Bank Authorties to physically verify the stock as per stock statement dated 31.03.2009, as the stock was lying at different sites in Madhya Pradesh. This argument of the Ld. DR cannot be accepted at all in view of the above facts. Hence, it stands proved that the Bank Manager only narrated the procedure and nothing has been brought on record to prove that the stock has been physically verified at any point of time and no documentary evidence has been placed on record by the Revenue.
5 ITA No.319 (Asr)/2016Asst. Year: 2012-13 23.1 As regards the counter comments/submissions by the ld. DR, our findings are :
i) That the stock statements for the assessment year 2009-10 as claimed by the assessee are not inflated but deflated. He has compared the value of the stock as per stock statement with the sanctioned limit instead of stock as per balance sheet as on 31.03.2009. Hence, the counter comment is factually wrong.
ii) The Ld. DR stated that during the AY 2010-11, the assessee has not claimed that he filed inflated stock statement. But on page 6 of the order of the AO, the AO has reproduced in para 2.4 in written submission of the assessee and it has been claimed by the assessee that the inflated stock statements were submitted to the department for getting loans. Hence, the counter comment of the ld. DR is factually wrong.
i) On page 4 of the counter comments, the ld. DR has discussed regarding cross examination of Sh. Kamlesh Gupta but this cross examination was made by the assessee during the A.Y. 2010-11. Moreover, the ld. CIT(A) has given detailed finding regarding non-physical verification of the stock at para 12(iii) of the appellate order for AY 2009-10
ii) The Ld. DR has discussed on page 5 of the written submission regarding statement of the Bank Manager regarding independent verification of the stock dated 4.2.2010. But the AO has never taken any cognizance of this independent stock audit report in the assessment order.
Moreover, this independent verficiation relates to stock statement dated 31.01.2010 allegedly made on 4.2.2010 but not to the stock statement dated 20.03.2010 on the basis of which addition has been made . Hence, no reliance can be placed on the independent stock verification.
iii) On page 6 of the counter comments, the ld. DR has stated that the value of the stock has been mentioned at stock statement dated 31.03.2009 at Rs.12,62,06092/- but the assessee never stated that the stock statement was inflated and it has only stated by the assessee that it is unsigned. But in this regard, the assessee has all along stated that the stock as per stock statement has been inflated to avail CC limit from the Bank. The physical verification of the stock has never been proved by the department. Hence, this counter comment of the Ld. DR is also factually wrong.
iv) The Ld. DR has again relied on the DP register for the AY 2009-10 and according to him the Branch Manager signed the D.P.register in token of having physically verified the stock and the same is further counter signed by the Chief Manager at that time. But the assessee in his counter comments has brought out the vital defects in the DP 6 ITA No.319 (Asr)/2016 Asst. Year: 2012-13 Register, which has been discussed (supra). Hence, this DP Register has no authentic value and the comments of the Ld. DR are liable to be rejected.
v) The Ld. DR has also stated that the assessee has tried to rely on the decision of this Bench in the case of Munish Kumar Bansal and according to him, the facts of this case are not applicable to the facts of the present assessee. But the assessee has brought to the notice of the Bench that in the above said case, the addition has been deleted and no further reliance has been placed. Moreover, regarding difference of Rs.1,73,16,531/- pointed out by the ld. DR, this issue is covered by the finding that the assessee has filed inflated stock statement.
vi) According to the ld. DR, the assessee has stated that the audited accounts filed with the bank are the same as with the Income tax Department and because of this fact, it was in the knowledge of the bank that the actual stock as on 13.03.2009 and 20.03.2010 was much less than the stock as per stock statement but no action was taken as per stock statement submitted to the bank. As per ld. DR, the comments of the assessee has no relevance. But this fact is important because the bank has not taken note of difference in stock.
vii) The ld. DR has given comments on hypothecation of stock, which has already been discussed in this order supra.
viii) The Ld. DR has further stated that the assessee made blanket claim that it has shown inflated stock for the AY 2010-11. This is in contradiction to the counter comments of the ld. DR on page 4 that no such claim was made by the assessee in AY 2010-11.
xi The same facts have been discussed in respect of other cases which are before us and the findings already recorded above shall apply accordingly to all other cases mentioned hereinabove, mutatis mutandis.
24. It is a fact on record that the credit facility has been extended by the Bank to the assessee against the hypothecation of stock and not against pledge of stock, in which the control and possession of the stock remained with the assessee.
25. The AO has not pointed out any discrepancy in the books of account or purchase/sales or has not brought on record to prove that extra purchases have been made by the assessee at any point of time. The books of account of the assessee are audited is not under dispute and no defect by the auditor has been pointed out. It is the real income which can be taxed, whereas in the present cases all the additions are made on conjectures and surmises.
7 ITA No.319 (Asr)/2016Asst. Year: 2012-13
26. Time and again before both the authorities below, the ld. Counsel for the assessee has submitted the explanation that the statement has been submitted before the Bank Authorities only on estimated basis to avail of the bank loan and there is no other purpose. This contention of the assessee has not been rebutted at any point of time by the AO or by the ld. DR. It is a fact that the AO as not pointed out any defects in the books of account and in fact, the AO has not invoked the provisions of section 145(3) of the Act. As argued by the Ld. DR that cash credit limit is calculated on the basis of DP register, which in turn is maintained on physical verification of the stock and no documentary evidence has been brought on record that the stock mentioned in the .DP register by third party i.e. Bank Authorities, has been maintained on physical verification of the stock, maintained by the assessee at different cities in different States.
27. The AO has much relied on the decision in the case of Devgan Rice & General Mills (supra). The issue before the Hon'ble Punjab & Haryana High Court, in the case of Devgan Rice & General Mills (supra) was with regard to the proceedings u/s 148 of the Act and whether the said proceedings u/s 148 of the Act could be initiated on the basis of information regarding inflating the value of the stock in the bank statement was received from the bank after completion of assessment u/s 143(3) of the Act.. The Hon'ble High Court has held that the reopening in such cases can be done. However, the decision of Hon'ble Punjab & Haryana High Court in the case of Devgan Rice & General Mills (supra) was with regard to a different context and did not prove that the assessee had made unexplained investment u/s 69 of the Act.
28. Much reliance has been placed by the ld. DR on the decision of the Hon'ble Punjab & Haryana High Court in the case of Smt. Shakuntla Thukral vs. CIT reported at 366 ITR 644. As required order of the CIT(A) in the case of Shakuntla Thukral was placed on record by the party and on perusal of the same in para 2.11 to 2.18 and at page 4 of CIT(A)'s order, it was found that the books of the assessee were not accurate because of specific defect of non-recording of sales in the books of account .pointed out. In para 2.8 at page 6 of CIT(A)'s order in the case of Shakuntla Thukral, stock statement filed on 04.07.2007 has been replaced by other stock statement which establishes that no stock inventory was prepared at the close of the financial year, whereas there are no such finding by the AO in any of the present appeals.
29. Further, in the case of Shakuntla Thukral (supra), the ld. CIT(A) has recorded finding at para 2.11 (page 24), of the order that the higher stock as on 31.03.2005 was given for the purpose of making payment for import of machinery cannot be accepted as the payment for purchase of machinery had already been released in February, 2005. In para 2.12.1 (Page 25) of ld. CIT(A)'s order, it has been perused that tat there are reports of physical inspection carried out by the bank authorities in respect of assessee's stock at quarterly intervals is availale and such findings has not been rebutted before the ITAT or before the Hon'ble High Court. But in the present case in view of our findings hereinabove, nothing has been 8 ITA No.319 (Asr)/2016 Asst. Year: 2012-13 established that physical inspection of the stock has been carried out as per facts on record. Further, in para 2.12.2 (page 25), of CIT(A)'s order in the case of Smt. Shakuntla Thukral (supra), it has been stated by the ld. CIT(A) that the assessee has not disputed the stock of the value which was submitted to the bank was actually lying in business premises as on 31.03.2005. But in the present appeal the assessee all along before the AO and the ld. CIT(A) and before us stating that the stock was inflated to get the cash credit limit from bank. Thus, in the case of Smt. Shakuntal Thukral (supra), the AO after pointing out defects in the books of account of the assessee a categorical finding has been given that the books of account are not accurate and meaning thereby that the books of account were rejected. But in the present appeal, there is no such finding by the AO and no books of account have been rejected and provisions of section 145(3) have not been invoked. In the case of Smt. Shakuntla Thukral (supra), the ld. CIT(A) has relied upon the physical inspection carried out by the bank authorities in respect of assessee's stock at quarterly intervals, as mentioned hereinabove and such findings have neither been rebutted before the ld. CIT(A) or ITAT or Hon'ble High Court. But in the present case, the assessee has established that no physical inspection of the stock has been carried as per facts on record.
30. Further and finally, in the case of Shakuntla Thukral (supra), the ld. CIT(A) has recorded the finding that the assessee has accepted that fact that the stock as per stock statement as on 31.03.2005 was lying in the premises of the assessee.. But in the present appeal, the assessee all along stated before the authorities below and before us that the stock was inflated to get the cash credit limit from bank and the onus is on the Revenue to prove that the assessee owned the stock more than the stock reflected in the balance sheet as on 31.03.2005, which has not been done in any of the case referred to hereinabove.
31. In view of the above discussion, the decision of Smt. Shakuntla Thukral (supra) as relied upon by the ld. DR is not applicable to the facts and circumstances of the present case.
32. The decisions relied upon by the ld. CIT(A) of the Hon'ble Punjab & Haryana High Court, in the cases of M/s.Santosh Box Factory, M/s. Sidhu Rice Mills and in the case of M/s. Devi Dayal Rice Mills are squarely applicable to the facts of the present case as the Revenue as the Revenue has not brought on record during the assessment proceedings or before the ld. CIT(A) or even before us that physical verification of the stock has actually been done and accordingly stock statements so submitted before the bank authorities and DP register cannot be relied upon.
33. In the case of CIT vs. Veerdip Roller (P) Ltd. (2010) 323 ITR 341 (Guj), the facts are that the AO made addition on account of difference in the value of closing stock furnished to the bank and the value of the stock found in the books of account furnished to the Income Tax Authorities - inflated stock was hypothetical and not pledged and the bank officials had not verified the statement showing inflated stock so produced by the 9 ITA No.319 (Asr)/2016 Asst. Year: 2012-13 assessee. The addition on account of difference furnished to the bank as per books of account u/s 69B of the Act can not be sustained. Consequently, the appeal was dismissed by the Hon'ble Gujrat High Court against the said decision, the Revenue went in appeal before the Hon'ble Supreme Court and the Hon'ble Supreme Court vide its order dated 13.12.2008 dismissed the SLP filed by the department.
34. Similar decisions have been made by various courts of law referred to hereinabove:
i) CIT vs. Sidhu Rice & General Mills reported in 281 ITR 428 (P&H)
ii) CIT vs. Santosh Box Factory (P) Ltd.., 44 IT Reps. 472 (P&H)
iii) CIT vs. N. Swamy reportede in 241 ITR 363 (Madras)
i) ITO vs. Devi Dayal Rice Mills reported in 75 TTJ 24 (ITAT, Amritsar Bench.
ii) CIT vs. Sirohi Steel Rolling Mills, reported in 200 CTR 595 (All.)
iii) Ashok Kumar vs. ITO, reported in 201 CTR 178 ( J & K)
iv) CIT vs. Das Industries, reported in 303 ITR 199 (All.)
v) CIT vs. Sri Padmavathi Cotton Mills, reported in 236 ITR 340 (Mad.)
vi) Jai Sharda Rice Mills. Vs ITO reported in 36 ITD 254 (ITAT, Asr.)
vii) CIT vs. Riddhi Steel and Tubes (P) Ltd. reported in 220 Taxman 148 (Guj.)
viii) CIT vs. Apcom Computers P. Ltd. reported in (2007) 292 ITR 630 (Mad.).
35. In the facts and circumstances, the arguments made by the ld. DR in his written submissions and counter submissions cannot help the Revenue and accordingly, we find no infirmity in the order of the ld. CIT(A) in the case of M/s. Ishar Infrastructure Developers (P Ltd. in ITA No.198(Asr)/2013 in the impugned year."
We find that the first issue is covered against Revenue, therefore, following the above judicial precedents in the case of assessee itself Ground Nos.1 to 5 are dismissed.
10 ITA No.319 (Asr)/2016Asst. Year: 2012-13
6. As regards the second issue of non charging of interest, we find that learned CIT(A) has dealt with this issue vide para 6 & 7 which for the sake of convenience is reproduced below.
"6. The other impugned issue pertains to disallowance of interest amounting to Rs.14,81,435/- on account of non-charging of interest from three debtors viz Shri Panka] Garg, Shri Rachhpal Singh and M/s Sukhbir Agro energy Ltd. While disallowing the aforesaid interest, the AO relied on the decision of the jurisdictional High Court in the case of M/s Abhishek industries, 286 ITR 1 read with the decision of the Hon'ble Supreme Court in S.A. builders Ltd Vs. CIT and Another [2007] 288 ITR 1. This issue had also cropped up in the assessment of the appellant for A.Y. 2010-11. However, the subsequent concurrent appellate orders for A.Y. 2010-11 held that if interest free advances have not been made during the year, there cannot be any notional disallowance of interest reckoned at the market rate on such interest free advances. This decision of the Hon'ble ITAT has also been challenged under section 260A of the Act on the ground that in the absence of proof regarding commercial expediency in advancing interest- free loans out of interest-bearing borrowed funds, non- disallowance of interest would be inconsistent with the judicial precedents as also the provisions of section 36(1 )(iii) of the Act.
7. In the instant case, it is seen that the debit balances in the accounts of Shri Pankaj Garg and Shri Rachhpal Singh amounting to Rs.50 Lacs each, on which the disallowance of interest of Rs. 12 lakhs has been worked out are opening brought forward balances with no fresh advances during the year. Respectfully following the decision of the jurisdictional Tribunal in the appellant's own case for A.Y. 2010-11 and subject to the outcome of the appeal under section 260A of the Act, the said disallowance of Rs.12 lakhs is directed to be deleted. However, it is seen that M/s Sukhbir Agro energy Ltd. has been advanced interest-free loan during the year in a staggered fashion on various dates, on which the disallowance of interest has been worked out to Rs.2,81,435/-. Since the appellant has not been 11 ITA No.319 (Asr)/2016 Asst. Year: 2012-13 able to prove any commercial expediency in such advancement of loan and that too sourced from borrowed funds, the said disallowance of Rs.2,81,435/- is confirmed. It is ordered accordingly."
We find that Assessing Officer had made an addition of Rs.14,81,435/-
on account of interest on interest free loans to Sh. P.K.Garg, Sh.
Rachhpal Singh and M/s Sukhbir Agro Energy Ltd. Out of these three the learned CIT(A) deleted the addition on account of loans given to Sh.
Pankaj Garg, and Sh. Rachhpal Singh. The learned CIT(A) has relied upon the order of the Tribunal in the case of assessee itself for Asst. Year 2010-11 wherein it has been held that if the interest free loans were given in earlier years no such disallowance is warranted. We find that Assessing Officer in his assessment order has himself noted down that the amount of Rs.50 lac each given to Sh. Pankaj Garg and Sh. Rachhpal Singh was out of opening balances. Therefore, relying upon the order of the Hon'ble Tribunal for Asst. Year 2010-11 we hold that learned CIT(A) has passed a reasoned and speaking order and has followed the Hon'ble Tribunal order in the case of assessee itself. The findings of Hon'ble Tribunal as contained in para 38 onwards are reproduced below.
"38. As regards ground No.1(ii) in the case of M/s. Euro Infrastructure & Power Ltd, in ITA No.571(Asr)/2013 for the assessment year 2010-11, with regard to charging of interest from debtors. The facts are that the AO made an addition of Rs.6,60,000/- on account of non charging of interest from debtors to whom no fresh advances have been made during the assessment year 2009-10 and there is only opening brought forward debit balance. It has been admitted by the AO that no fresh advances have been given to debtors during the A.Y. 2009-10 and there is opening brought forward debit balance of Rs.50,00,000/- on 01.04.2009 in the account of Sh. Pankaj Garg and Rs.5,00,000/- in the account of M/s. Ram Kumar Bansal, which has been carried forward as on 31.03.2010.12 ITA No.319 (Asr)/2016
Asst. Year: 2012-13
39. The ld. CIT(A) on considering the submissions made before him has deleted the addition, since no advance has been made during the year and it was only brought forward debit balance outstanding in the books of account of the debtors.
40. After hearing the parties, we find no infirmity in the order of the ld. CIT(A), since no advance has been made during the year and as such no addition can be made. Thus, the ground of the revenue is dismissed accordingly."
7. In view of the above facts and circumstances findings the issue is similar, we dismiss the ground no.6 of appeal also. [
8. In nutshell, the appeal filed by the Revenue is dismissed Order pronounced in the open Court on 19.07.2016.
Sd/- Sd/-
(A.D. JAIN) (T. S. KAPOOR)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated:19.07.2016.
/PK/ Ps.
Copy of the order forwarded to:
(1) The Assessee:
(2) The
(3) The CIT(A),
(4) The CIT,
(5) The SR DR, I.T.A.T.,
True copy
By order