Income Tax Appellate Tribunal - Ahmedabad
Mahavir Inductomelt Pvt.Ltd., ... vs Department Of Income Tax on 30 July, 2012
IN THE INCOME TAX APPELLATE TRIBUNAL AT AHMEDABAD
"B" BENCH
Before: Shri D.K. Tyagi, Judicial Member and
Shri Anil Chaturvedi, Accountant Member
I.T.A. No.727/Ahd/2012
A. Y.2008-09
The ACIT (OSD)-1, Vs. Mahavir Inductomelt Pvt. Ltd .
Range-4 28/29, Rang in Park,
Ahmedabad Opp. Rajp ath Club,
Bod akd ev, Ahmedab ad
PAN-AABCM8848G
Appellant Respondent
Department by : Shri B.K.S. Pandya, CIT-D.R.
Assessee by : Shri A.L. Thakkar, A.R.
Date of hearing : 30.07.2012
Date of pronouncement 30.07.2012
आदे श/ORDER
PER : D.K. TYAGI, JUDICIAL MEMBER
This is Revenue's appeal against the order of ld. CIT(A)-VIII, Ahmedabad dated 10.01.2012.
2. Revenue has taken following two effective grounds:-
"1. The ld. CIT(A) has erred in law and on facts in deleting addition of Rs.3,08,19,443/- on account of deemed dividend u/s 2(22)(e) without appreciating the fact that the A.O. had established that the payment covered under the provisions of section 2(22)(e).
2. The ld. CIT(A) has erred in law and on facts in deleting addition of Rs.12,00,000/- on account of payment made to GMB for acquiring rights to use plot for ship breaking without I.T.A. No.727/Ahd/2012 A. Y.2008-09 2 appreciating the fact that the A.O. had treated the same as capital expenditure."
3. The first ground relates to addition of Rs.3,08,19,443/- on account of deemed dividend u/s 2(22)(e) of the Act. While making this addition the A.O. observed as under:-
"a. In this case Mahavir Rolling Mill Pvt. Ltd. has made payments by way of advances to the assessee company in which Shri K.K. Bansal has substantial interest under the provisions of section 2(22) and Shri K.K. Bansal is holding more than 10% voting power in Mahavir Rolling Mill Pvt. Ltd. A plain reading of the provisions of section 2(22)(e) makes it clear that the assessee company is in receipt of dividend income from Mahavir Rolling Mill Pvt. Ltd.. Mahavir Rolling Mill Pvt. Ltd. has accumulated profits of Rs.3,09,94,043/- as reflected in Scheudle-2 (Reserves & Surplus) of its balance sheet. Total advances received by the assessee company is Rs.3,32,95,000/- . Therefore, advances to the extent of increase in accumulated profits or accumulated profit not taxed during earlier are in the nature of deemed dividend in the hands of the assessee company.
b. Therefore, the assessee was asked to show cause why addition should not be made in regard to this issue. The submission of the assessee in this regard dated 29-11-10 is reproduced here:
i. At the outset it is clarified that the assessee company is a private limited company in which the public is substantially interested. The details of the shareholding in the case of Mahavir Mills Ltd. are enclosed for your kind reference. There is no change in the share holding during the year under consideration. The perusal of the share holding indicates that the assessee company is not holding a single share in MRML. It is therefore stated that the assessee company is neither a registered shareholder nor a beneficial shareholder of MRML. This is an accepted position and which is not disputed at any stage. Reliance is placed on the following judicial pronouncements in support of our contention wherein it is held that for treating any loan or advance as deemed dividend the assessee company has to be a registered or beneficial shareholder of the lender company.
a. CIT v Hotel Hiltop (2009) 313 ITR 116 (Raj.) I.T.A. No.727/Ahd/2012 A. Y.2008-09 3 b. ACIT v Bhaumick Color (P) Ltd. (2009) 118 ITD (Mum.) (SB.) Relying on the above judicial pronouncements the Honourable ITAT in our group company Mahavir Rolling Mills Ltd. in ITA No.2337/A/2008 & Co. No.181/A/2008 on similar facts and circumstances has decided the issue in the favour of the group company. Xerox coy of the order passed by the Honourable ITAT in the case of Mahavir Rolling Mills Ltd. is enclosed for your kind reference. In view of the above facts and circumstances it is enclosed for your kind reference. In view of the above facts and circumstances it is requested that no additions be made with regards deemed dividend under section 2(22)(e) of the IT Act, 1961...
ii. Out of the amount of accumulated reserve of Rs.30994043, subsidy and opening balance has already brought to lax during last year at the time of calculation of deemed dividend. The amount utilized for issue of bonus share is also excluded for the purpose of deemed dividend. Therefore, the remaining amount which is not brought to lax earlier will be Rs.3,08,19,443/- and the same is taken as deemed dividend for the purpose of sec. 2(22)(e) of the IT Act, 1961, as the same is available for distribution to the shareholder.
iii. In respect of assessee's reply that earlier the addition was deleted by the appellate authorities, the Department has preferred further appeals in the same issue in assessee's own case. Therefore, advances to the extent of Rs.3,08,19,443/- is accumulated profits or taxable accumulated profit are in the nature of deemed dividend in the hands of the assessee Company. Penalty proceeding u/s 271(1)(c) is initiated for furnishing inaccurate Particulars of income."
4. The assessee went in first appeal before ld. CIT(A) who deleted this addition by following the decision of Hon'ble ITAT in assessee's own case for the assessment year 2005-06. Further aggrieved, now the Revenue is in appeal before us.
5. After hearing both the parties and perusing the record we find that the issue is now covered in favour of the assessee and against the Revenue by the I.T.A. No.727/Ahd/2012 A. Y.2008-09 4 order of the Tribunal in assessee's own case for the assessment year 2005-06 dated 10th December, 2010 in ITA No.2349/Ahd/2008 wherein following was held:-
"We have heard the rival contentions and gone through the facts and circumstances of the case. We find that the similar issue in assessee's sister concern in the case of ITO v. Mahavir Rolling Mills Ltd. in ITA No.2337/Ahd/2008 dated 19.11.2010 for assessmentyear 2005-06, wherein clear finding is given in para- 14 that the assessee-company in which public is not substantially interest and one of the Director, Shri K.K. Bansal holds more than 20% share both in assessee- company and MMRML that assessee-company is not holding even a single share in MMRML and no shareholding is held by assessee- company in MMRML. That means that the assessee-company is not shareholder of the lender company and not in the hands of the person other than a shareholder the deemed dividend can be assessed. We have taken this view in assessee's sister concern in ITA No.2337/Ahd/2008 (supra) as under:-
13. At the outset Ld. Counsel for the assessee argued that this issue is squarely covered in favour of assessee and against the Revenue by the decision of Special Bench Mumbai Tribunal in the case of ACIT v. Bhaumik Colour (P.) Ltd.(2009) 118 ITD 1 (Mum) (SB) and further by the decision of Hon'ble Rajasthan High Court in the case of CIT v. Hotel Hilltop (2009) 313 ITR116(Raj).
14. We have heard rival contentions and gone through the facts and circumstances of the case. We find from the assessment order that the Assessing Officer observed that M/s.
MIPL is a company in which the public is not substantially interest and one of the Director, Shri K.K Bansal holds more than 20% of share both in the assessee-company and M/s MRPL, the AO further observed that as per the books of account, M/s. MRPL has advanced huge sum to M/s MRPL i.e. the assessee-company and MIPL have shown reserves and surplus at Rs.1,01,54,414/-. The AO therefore observed that the loans and advances made by MIPL to MRML is liable to taxed as deemed dividend. In response to the show cause notice asking the assessee to explain why the amount should not be treated as deemed dividend u/s.2(22)(e), the assessee filed written submissions dated 22-12-2007 which had been reproduced by the AO at para-7.3 in assessment order. It was explained to the AO in the course of assessment proceedings that the assessee-company is not holding a single share in MRML and the aforesaid fact can also be ascertained from the chart which has been produced by the in para-7.1 of I.T.A. No.727/Ahd/2012 A. Y.2008-09 5 the assessment order. The AO without appreciating the relevant facts in proper perspective and the detailed submissions furnished by the assessee and made addition of Rs.1,01,54,414/-, We find from the assessment order that he has not dealt with the issue of the assessee that the assessee- company is not holding even a single share of MIPL and now before us the assessee has demonstrated that no shareholding is held by the assessee-company of MIPL. But even otherwise, this issue is squarely covered by the decision of Special Bench of ITAT Mumbai in the case of ACIT v. Bhaumik Colour (P) Ltd. (2009) 118 ITD 1 (Mum)(SB), wherein the Hon'ble Special Bench has held as under:-
"33. We may also touch upon certain other aspects of the Issue n the light of the submissions made before us. The Tribunal in the case of Nikko Technologies (supra), while holding that the payment made by a company even to a non- shareholder can be brought to tax in the hands of the non- shareholder has made the following observations.
"Section 2(22)(e) only specifies the circumstances under which a payment by way of loan/advance is to be treated as deemed dividend. Once it is determined that any payment by way of loan/advance falls within the ambit of section 2(22)(e), then, it has to be treated as dividend even though such payment in the ordinary circumstances may not be considered as dividend. At this point of time, the role of section 2(22)(e) ends. It nowhere provides as to who is to be taxed in inspect of such income. It is to be borne in mind that the tax can only be assessed in the hands of right person as held by the apex court in the case of ITO v. Ch. Atchalah (1996) 218 ITR 239, at pages 243-244. In order to find out the right person, one has to examine the charging provisions of the Act. Sections 4 and 5 of the Act are the charging provisions."
"Thereafter, the Tribunal has referred to the provisions of section 5(1) of the Act and has concluded that income accrues to the person who is the recipient of the payment from the company. The Tribunal has thereafter referred to Circular No.495 dated September 22, 1987, of the Central Board of Direct Taxes wherein it has been opined that deemed dividend would be taxed in the hands of a concern (non-shareholder) also if the conditions mentioned in the section are satisfied.
34. We are of the view that the provisions of section 2(22)(e) do not spell out as to whether the income has to be taxed din the hands of the share-holder or the concern (non- I.T.A. No.727/Ahd/2012 A. Y.2008-09 6 shareholder). The provisions are ambiguous. IT is therefore necessary to examine the intention behind enacting the provisions of section 2(22)(e)of the Act.
35. The intention behind enacting the provisions of section 2(22)(e) is that closely held companies (i.e. companies in which public are not substantially interested), which are controlled by a group of members, even though the company has accumulated profits would not distribute such profit as dividend because if so distributed the dividend income would become taxable in the hands of the shareholders. Instead of distributing accumulated profits as dividend companies distribute them as loan or advances to shareholder or to concern in which such shareholders have substantial interest or make any payment on behalf of or for the individual benefit of such shareholder. In such an event, by the deeming provisions such payment by the company is treated as dividend. The intention behind the provisions of section 2(22)(e) is to tax dividend in the hands of shareholder. The deeming provisions as it applies to the case of loans or advances by a company to a concern in which its shareholder has substantial interest, is based on the presumption that the loan or advances would ultimately, be made available to the shareholders of the company giving the loan or advance. The intention of the Legislature is therefore to tax dividend only in the hands of the shareholder and not in the hands of the concern.
36. The basis of bringing in the amendment to section 2(22) (e) of the Act by the Finance Act, 1987, with effect from April 1, 1998, is to ensure that persons who control the affairs of a company as well as that of a firm can have the payment made to a concern from the company and the person who can control the affairs of the concern can draw the same from the concern instead of the company directly making payment to the shareholder as dividend. The source of power to control the affairs of the company and the concern is the basis on which these provisions have been made. It is therefore proper to construe, those provisions as contemplating a charge to tax in the hands of the shareholder and not in the hands of a non- shareholder viz., concern. A loan or advance received by a concern is not in the nature of income. In other words there is a deemed accrual of income even under section 5(1)(b) in the hands of the shareholder only and not in the hands of the payee, viz., non-shareholder (concern). Section 5(1) (a) contemplates that the receipt or deemed receipt should be in the nature of income. Therefore, the deeming fiction can be applied only in the I.T.A. No.727/Ahd/2012 A. Y.2008-09 7 hands of the shareholder and not the non-shareholder, viz., the concern.
37. The definition of dividend under section 2(22)(e) of the Act is an inclusive definition. Such inclusive definition enlarges the meaning of the term "dividend" according to its ordinary and natural meaning to include even a loan or advance. Any loan or advance cannot be dividend according to its ordinary and natural meaning. The ordinary and natural meaning of the term dividend would be a share in profits to an investor in the share capital of a limited company. To the extent the meaning of the word "dividend" is extended to loans and advances to a shareholder or to a concern in which a shareholder is substantially interested deeming them as dividend in the hands of a shareholder the ordinary and natural meaning of the word "dividend" is altered. To this extent the definition of the term "dividend" can be said to operate. If the definition of "dividend" is extended to a loan or advance to a non-shareholder the ordinary and natural meaning of the word dividend is taken away. In the light of the intention behind the provisions of section. 2(22)(e) and in the absence of indication in section 2 (22)(e) to extended the legal fiction to a case of loan or advance to a non-shareholder also, we are of view that loan or advance to a non-shareholder cannot be taxed as deemed dividend in the hands of a non-shareholder.
38. The basic characteristic of dividend as held by the apex court in the case of Kantilal Manilal v. CIT [1961] 41 ITR 275 is a share of profits of the company given to its shareholders. Further, section 206 of the Companies Act, 1956, prohibits payment of dividend to any person other than the registered shareholder. If one were to break up the natural meaning the following components emerge (a) dividend is a share of profits of the company (b) paid to its shareholders. Section 2(22) of the Act artificially extends the scope of dividend from being more than only a distribution of profits to cover certain other types disbursements such as loans paid, etc. (the first ingredient mentioned above). It does not however alter the second component of its natural meaning, viz., paid to its shareholder. In other words all that section 2(22) seeks to do is to expand the various types payments that may be regarded as dividend. The apex court while considering what can come within the artificial definition of dividend under section 2(22) in the case of CIT v. Nalin Behari Lall Singha [1969] 74 ITR 849 (SC) described the scope of the definition of dividend thus (page 851 of 74 ITR):
"The definition is, it is true, an inclusive definition and a receipt by a shareholder which does not fall within the definition I.T.A. No.727/Ahd/2012 A. Y.2008-09 8 may possibly be regarded as dividend within the meaning of the Act unless the context negatives that view."
The contention of the Departmental representative that the provisions of section 8(a) of the Act creates a fiction by which even payments to non shareholders canbe construed as dividend cannot be accepted. Those provisions merely fix the year in which dividend has to be taxed. It is therefore clear that the shareholder alone can, if at all, be subjected to tax for having earned dividend.
39. In the decision of the Tribunal in the case of Nikko Technologies Ltd. (supra) reliance has been placed on Circular No.495, dated September 22, 1987 ([1987] 1568 ITR (St.) 87), which states as follows (page 91):
"Further, deemed dividend would be taxed in the hands of a concern where all the following conditions are satisfied... ."
We are of the view that circular of the Central Board of Direct Taxes to the extent that they do not tone down the rigor of the provisions of the Act in the sense to the extent they are not benevolent are not binding.
40. Apart from the above, it is also noticed that section 2(22)(e)(iii) provides relief to a shareholder as follows:
"Dividend does riot include,
(i) & (ii) ... ... ...
(iii) any dividend paid by accompany which is set off by the company against the whole or any part of any sum previously paid by it and treated as a dividend within the meaning of sub-clause (e) to the extent to which it is so set off."
In the event of the payment of loan or advance by a company to a concern being treated as dividend and taxed in the hands of the concern then, the benefit of set off cannot be allowed to the concern, because the concern can receive dividend from the company which is only paid to toe shareholder, who has substantial interest in the concern. The above provisions also therefore contemplate deemed dividend being taxed m the hands of a shareholder only. For the reasons stated above, we are of the view that the law laid down in the case of Nikko Technologies Ltd. (supra) is not correct. We, therefore, hold that deemed dividend under section 2(22)(e) of the Income-tax Act, 1961, can be assessed only in the hands of a shareholder of the lender company and not in the hands of any other person.
I.T.A. No.727/Ahd/2012 A. Y.2008-09 9
41. In the light of the above discussion, the questions referred to the Special Bench are answered as follows:
On the first question: Deemed dividend can be assessed only in the hands of a person who is a shareholder of the lender company nd not in the hands of a person other than a shareholder.
On the second question: The expression shareholder referred to in section 2(22)(e) refers to both a registered shareholder and beneficial shareholder. If a person is a registered shareholder but not the beneficial shareholder then the provisions of section 2(22)(e) will not apply.
42. Similarly if a person is a beneficial shareholder but not a registered shareholder then also the provisions of section 2(22)(e) will not apply. In view of the above discussion, there is no merit inn this appeal by the Revenue and the same is, therefore, dismissed.."
15. Further, the Ld Counsel for the assessee relied on Hon'ble Rajasthan High Court in the case of CIT v. Hotel Hilltop (2009) 313 ITR 116 (Raj) wherein it is held that in order to attract the provisions of Section 2(22)(e) of the Act the following four conditions are that sine qua non : (a) the assessee should be a shareholder of the company; (b) the company should be a closely held company in which the public are not substantially interested; (c) there must be payment by way of advance or loan to a shareholder or any payment by the company on behalf of or for the individual benefit of the shareholder and (d) there must be sufficient accumulated profits in the hands of the company up to the date of such payment.
16. We find from the above case law of Mumbai Special Bench of this ITAT, wherein it is categorically held that the deemed dividend can be assessed only in the hands of a person who is a shareholder of the lender company and not in the hands of a person other than a shareholder. Accordingly, this issue is squarely covered in favour of the assessee and against the Revenue, hence, we confirm the order of CIT(A) deleting the addition of deemed dividend u/s.2(22)(e) of the Act made by Assessing Officer. This issue of the Revenue's appeal is dismissed."
We find that issue is squarely covered in favour of assessee and against the Revenue in the present case also.
I.T.A. No.727/Ahd/2012 A. Y.2008-09 10 Respectfully, following the decision of this Tribunal in assessee's sister concern in the case of Mahavir Rolling Mills Ltd. (supra) we uphold the order of C1T(A) and this issue of Revenue's appeal is dismissed.
6. In view of the above, this ground of the Revenue is dismissed.
7. Second ground relates to addition of Rs.12,00,000/- on account of the payment made to GMB as plot development fees. The A.O., while making this addition has observed as under:-
"i. The assessee is engaged in the business of Ship Breaking. The assessee has paid GMB plot rent expenses of Rs.3,60,000/- and has deducted TDS on it. This is the yearly rent paid by the assessee for using GMB plot for Ship Breaking. Apart from this, the assessee has deducted Rs.12,00,000/- from the total income of the assessee as lease rental paid to GMB. The assessee was asked to show cause why the same should not be added as capital expenditure.
ii. It has been stated that why the various amounts given to GMB should not be treated as capital expenses. The payments made to GMB are with reference to plot premium charges paid GMB has issued a letter dated 09.10.2007 which is enclosed for your kind reference. The perusal of the same indicates that the development fees have to be paid for the period commencing from 01.10.2004 to 30.09.2008. They have also enclosed the copy of the development fees challan payable to GMB. Accordingly, the payments have been made to GMB and the amount pertaining to the year under assessment has been claimed by way of deduction. The assessee company has claimed the expenses of Rs.12.00 lacs for the year under assessment as it has been following the mercantile system of account. The details of plot premium charges have already been furnished earlier. The same have been furnished vide letter dated 26.11.2010.
iii. It may not be out of place to mention that both the addition have been made in the earlier years and the learned CIT(A) has for A.Y.2005-06 & 2006-07 have deleted the additions. In view of the matter being covered and decided in favour of the assessee company it is a requested that were additions be deleted and the returned income of the assessee company be accepted"
I.T.A. No.727/Ahd/2012 A. Y.2008-09 11 iv. On verification of records & after going through the reply, the reply is not found acceptable because:-
a) The assessee has deducted the same while computing total taxable income as revenue expenditure but has already paid rental on GMB plot use of Rs.3,60,000/-.
b) In the notes of accounts (Point No.8); it is stated that:-
"the lease period/or ship breaking from GMB has expired on 30.09.2004. An application for extension of the lease period has been made on which GMB has not taken any action. However in terms of the policy declared by the GMB, further Rs.12,00,000/- became payable in respect of period from 01.04.2007 to 31.03.2008. Lease rentals paid in excess of this amount is shown as advance lease rental (of Rs.6,00,000/-)."
c. The assessee is making this payment of acquiring rights to use plot for ship breaking. It is not the rent paid yearly for usage of leased plot but it is the expenses for acquiring rights for usage of plot. The rent is of Rs.3.6 lacs on this plot, which has already been claimed by the assessee in P&L A/c.
d) Apart from this in the 3CD report, Annexure-2 which is related to depreciation on assets as per IT Act, the assessee is showing reconciliation figure which is as| follows:-
(figures in Rs.) Addition as above 14,42,066 Add.: (i) Sale of mobile instrument 2,700
(ii) Leasehold plot GMB 12.00.000 Addition as per Balance Sheet 12.02.700 26,44,766
e) It clearly states that the assessee is considering the payment of Rs.12,00,000/- to GMB as plot development fees, a capital expenditure. The assessee has only given the proof of payment to GMB but the rationale behind treating it as revenue expenditure was not submitted by the assessee.
f) In this respect the following case laws are important: -
1.) National Dairy Development Board V s. Addl. CIT (ITAT ,Ahd) 310 ITR(AT) 325
2.) Gobind Sugar Mills Ltd. Vs. CIT (SC) 232 ITR 319
3.) Universal Capsules (P) Ltd. Vs. DCIT (ITAT.Mum) 76 ITD 403 I.T.A. No.727/Ahd/2012 A. Y.2008-09 12 Thus the same expense of Rs.12,00,000/- is not allowed as revenue expenses and added back to the total income of the assessee."
8. In appeal ld. CIT(A) has deleted this addition following the earlier order of the Tribunal in assessee's own case for the assessment year 2005-06.
9. After hearing both the parties we find that the issue is now covered in favour of the assessee and against the Revenue vide order dated 10th December, 2010 in ITA No.2349/Ahd/2008 for A.Y.2005-06 wherein following was held:-
"We have heard the rival contentions and gone through the facts of the case. We find that assessee-company possessed plot No.96 and on request made to GMB, permission sought was granted for plot No.V-5. The original plot No.96 was acquired by paying premium of Rs.9,11,250/- for 30 months. Since the same was used for 8 months the previous year relevant to assessment year 2003-04 the value written off is Rs.2.43 lakh. The basis on which the plot premium has been written off is given in the sheet attached herewith. The assessee-company had written off the amount of plot premium in the earlier years, the details of which are as under:-
Assessment Year Period for which the plot Amount (in Rs.) was used 2003-04 Plot No.96 for 8 months 9,47,300 Plot No.V-5 for 4 months 2004-05 Plot No.V-5 10,56,450 2005-06 Plot No.B-5 18,66,450 The outstanding amount of plot premium as on 31.03.2004 was Rs.10,56,450/- and during the assessment year under appeal, the assessee paid further amount of Rs.8.10 lakh.
Therefore the total amount works out to Rs.18,66,450/- and aforesaid amount had been written off during the year under consideration. During the year application for renewal of the lease is still pending and in the meantime, GMB had directed to make ad hoc payment of Rs.8.10 lakh which was paid for the usage of the plot for the purpose of the business and deduction u/s 37(1) for a sum of Rs.18,86,450/- had been claimed. We I.T.A. No.727/Ahd/2012 A. Y.2008-09 13 find that the plot premium paid by assessee-company at Rs.18,66,450/- is as under:-
Plot Period Amount of plot
No. premium
claimed
V-5 1.10.2004 to 30.09.2005 Rs.8,10,000
V-5 1.12.2002 to 30.09.2004 Rs.8,74,200
Plot 1.10.1994 to 30.09.2004 Rs.1,82,250
No.119
In view of the above fact, the total premium for the period from 01.10.2004 to 30.09.2005 was Rs.16.20 lakh and the assessee has claimed a sum of Rs.8.10 lakh for this period. The balance amount of Rs.8,74,200/- was claimed for the period from01.12.2002 to 30.09.2004 and Rs.1,82,250/- for the period ending 30th September, 2004. In view of this face, we are of the view that the assessee has rightly claim deduction of Rs.18,66,460/-, which was allowed by CIT(A). We confirm the order of CIT(A) and this issue of Revenue's appeal is dismissed."
10. In view of the above, this ground of the Revenue is dismissed.
11. In the result, Revenue's appeal is dismissed.
Order pronounced in open Court on 30.07.2012
Sd/- Sd/-
(Anil Chaturvedi) (D.K. Tyagi)
Accountant Member Judicial Member
True copy
N.K. Chaudhary, Sr. P.S.
Copy of the Order forwarded to:
1. The applicant
2. The Respondent
3. The CIT Concerned
4. The Ld. CIT (Appeals)
5. The DR, Ahmedabad
6. The Guard File
By order
AR,ITAT,Ahmedabad