Central Information Commission
Hem Chand Verma vs Chief Commissioner Of Income Tax (Cca), ... on 28 May, 2019
के ीय सूचना आयोग
Central Information Commission
बाबा गंगनाथ माग, मुिनरका
Baba Gangnath Marg, Munirka
नई द ली, New Delhi - 110067
ि तीय अपील सं या / Second Appeal No.:- CIC/CCITD/A/2018/105257-BJ
Mr. Hem Chand Verma
....अपीलकता /Appellant
VERSUS
बनाम
CPIO
Asst. Commissioner of Income Tax (E)
Circle 2(1), Room No. 2408, 24th Floor
E - 2 Block, Pratyaksh Kar Bhawan
Dr. S. P. Mukherjee Marg, Civic Centre
New Delhi - 110002
... ितवादीगण /Respondent
Date of Hearing : 27.05.2019
Date of Decision : 28.05.2019
Date of RTI application 24.07.2017
CPIO's response 30.08.2017
Date of the First Appeal 03.10.2017
First Appellate Authority's response 20.11.2017
Date of diarised receipt of Appeal by the Commission 24.01.2018
ORDER
FACTS:
The Appellant vide his RTI application sought information on 2 points pertaining to a certificate regarding the Income returned and/ or assessed for the Assessment Years from 2006-07 till 2016-17 along with certified copies of the Assessment proceedings and certified copies of ITRs and all annexure including financial statements.
The CPIO, vide his letter dated 30.08.2017 stated that the information sought was exempt from disclosure u/s 8(1)(d), 8(1)(e) and 8(1)(j) of the RTI Act 2005 as it pertained to a third party information. Dissatisfied by the response, the Appellant approached the FAA. The FAA, vide its order dated 20.11.2017stated that there is no infirmity in the order of the CPIO.
HEARING:
Facts emerging during the hearing:
The following were present:
Appellant: Mr. Hem Chand Verma along with Adv. S. S. Grewal;
Respondent: Mr. Ajay Goyal, Dy. CIT (E) Cir 2 (1) and Mr. Arun Kumar, Income Tax Inspector;Page 1 of 9
The Appellant reiterated the contents of the RTI application and stated that the information was sought regarding the Shanti Education Society which was a Registered Firm/ Society, Distt. (SE), New Delhi and that he was a founder member of the Society since its inception, till date. Hence, he had the right to seek the information. It was further stated that he alongwith other family members and lenders from general public had paid huge working loan to the Society, hence the matter pertained to public interest and he had the right to know the status of the loan amount. It was further mentioned that the Society was allotted 25 acres of land by Yamuna Development Authority Gautambudh Nagar (UP) on lease and in the minutes of meeting dated 22.07.2011 his attendance was recorded. The Society Registered with the Government Agency had been allotted 25 acres of land on subsidized cost and it was running HIMT Group of Institutions including several colleges which were Public Institutions. Hence the Society cannot be a Private Person and information could not be denied under the guise of Fiduciary Relationship in the present case. In its reply, the Respondent re- iterated the response of the CPIO/ FAA and stated that subsequent to the receipt of the RTI application, they had sought the consent of the Third Party and the President of the Society vide letter dated 14.11.2017 denied its consent to furnish the information since the Appellant was no more a member of the Society. On being queried by the Commission, whether at any stage exemption under Section 12A/ 80G of the IT Act, 1961 were granted to the society referred in the RTI application, the Respondent replied in the affirmative.
The Commission was in receipt of a written submission from the Appellant dated 20.05.2019 (wrongly mentioned as 20.05.2016 by the Appellant) wherein it was stated that the JCIT had erroneously dismissed the Appeal on the ground that the information pertained to Third Party and was personal in nature which was wrong since he was a member of the Society, till date. A reference was made to the certified copy of the Registrar of Society where the Society was registered dated 15.01.2018. The Appellant stated that the society was allotted land by Government Agency i.e., Noida Authority in Knowledge Park for the Engineering College run by the said Society where they accept donations, capitation and other fees from students and general public hence it fell within the category of public domain institution and was bound to disclose information sought through RTI and by disclosing financial details, no loss of any kind shall incur nor the society would be exposed by any kind of threat. In support of his contention, the Appellant referred to the decision of the SC ( incorrectly written by the Appellant as SC. Decision of Division Bench of HC of Delhi in LPA No. 1090/ 2011) dated 24.05.2012 titled Central Board of Secondary Education vs. Shri Anil Kumar Kathpal wherein reliance was placed on the decision of the Institute of Chartered Accountants of India vs Shaunak H. Satya. He also made reference to the judgment of the Apex Court in the matter of Central Board of Secondary Education vs. Aditya Bandopadhyay, decision of the Commission in Bhagwan Seth vs Bank of Baroda, CIC/PB/A/2008/00558-SM dated 12.01.2009, decision of California Court of Appeals in Woolf vs Superior Court, decision of the Commission in Rajbir Singh vs. CPIO, National Fertilizers Ltd in support of his contention. It was also mentioned that the FAA passed contradictory orders since being a member of the society he could not be considered as a Third Person and ITRs submitted to the IT Department by the registered society had gone to the public domain. He also submitted that the FAA incorrectly denied information u/s 8 (1) (d) (e) and (j) of the RTI Act, 2005 which was not correct and reliance on the judgment of the Hon'ble Supreme Court on the judgement of Girish Ramachandra Deshpandey was not relevant to the present application. He further stated that the averment made by Mr. Hem Singh vide letter dated 14.11.2017 to the IT department were false, fabricated, concocted and far from the truth. Neither did he resign nor was he removed from the founder membership of the Society in any manner whatsoever and he had been regularly paying his dues.
The Commission observed that in a similar matter where information regarding charitable trusts claiming exemption u/s 12A of the IT Act, 1961 was sought, the Division Bench of the Commission Page 2 of 9 in Appeal No. in Appeal No. CIC/BS/A/2016/001091-BJ-Final dated 05.01.2018 while observing that the matter certainly involved larger public interest since the Government was granting exemptions to the Third Party from payment of taxes allowed for disclosure of information. In the said matter, the Commission made the following observation:
"The Commission took note of the issue regarding the "personal information" held by an individual in its personal capacity and the personal information held by the entities/corporations/trusts in their private capacity. In this context, a reference was drawn on the Hon'ble Delhi High Court decision in Naresh Trehan vs. Rakesh Kumar Gupta and Ors.( 2015) 216 DLT 156 wherein it was held:
"20. It has been contended by the petitioners that the expression "personal information"
must also extend to information relating to corporate entities. Inasmuch as they may also fall within the definition of expression "person" under the General Clauses Act, 1897 as well as under the Income Tax Act, 1961. However, I am unable to accept this contention for the reason that the expression "personal information" as used in clause (j) of Section 8(1) of the Act has to be read in the context of information relating to an individual. A plain reading of the aforesaid clause would indicate that the expression "personal information" is linked with "invasion of privacy of the individual". The use of the word "the" before the word "individual" immediately links the same with the expression "personal information"
21. Black's law dictionary, sixth edition, inter alia, defines the word "personal" as under:-
"The word "personal" means appertaining to the person; belonging to an individual; limited to the person; having the nature or partaking of the qualities of human beings, or of movable property."
23. In my view, the aforesaid reasoning would also be applicable to the expression "personal" used in Section 8(1)(j) of the Act. The expression 'individual' must be construed in an expansive sense and would include a body of individuals. The said exemption would be available even to unincorporated entities as also private, closely held undertaking which are in substance alter egos of their shareholders. However, the expression individual cannot be used as a synonym for the expression 'person'. Under the General Clauses Act, 1897 a person is defined to "include any company or association or body of individuals, whether incorporated or not". Thus, whereas a person would include an individual as well as incorporated entities and artificial persons, the expression 'individual' cannot be interpreted to include such entities. The context in which, the expression "personal information" is used would also exclude it application to large widely held corporations. While, confidential information of a corporation is exempt from disclosure under Section 8(1) (d) of the Act, there is no scope to exclude other information relating to such corporations under Section 8(1)(j) of the Act as the concept of a personal information cannot in ordinary language be understood to mean information pertaining to a public corporation."
22. A perusal of the above definition also indicates that the ordinary usage of the word "personal" is in the context of an individual human being and not a corporate entity. The U.S. Supreme Court has also interpreted the expression "personal" to be used in the context of an individual human being and not a corporate entity. In the case of Federal Communications Commission v. AT&T Inc: 2011 US LEXIS 1899 the US Supreme Court considered the meaning of the expression "personal privacy" in the context of the Freedom of Information Act, which required Federal Agencies to make certain records and documents publically available on request. Such disclosure was exempt if the records "could reasonably be expected to constitute an unwarranted invasion of personal privacy". The U.S. Supreme Court held that the expression "Personal" used in the aforesaid context could not be extended to corporations because the word "personal" ordinarily refers to individuals. The Page 3 of 9 Court held that the expression "personal" must be given its ordinary meaning. The relevant extract of the said judgment is as under: "Person" is a defined term in the statute;
"personal" is not. When a statute does not define a term, we typically "give the phrase its ordinary meaning," [Johnson v. United States, 559 U.S., 559 U.S. 133, 130 S. Ct. 1265, 176 L. Ed. 2d 1, 8 (2010)]. "Personal" ordinarily refers to individuals. We do not usually speak of personal characteristics, personal effects, personal correspondence, personal influence, or personal tragedy as referring to corporations or other artificial entities. This is not to say that corporations do not have correspondence, influence, or tragedies of their own, only that we do not use the word "personal" to describe them. Certainly, if the chief executive officer of a corporation approached the chief financial officer and said, "I have something personal to tell you," we would not assume the CEO was about to discuss company business. Responding to a request for information, an individual might say, "that's personal." A company spokesman, when asked for information about the company, would not. In fact, we often use the word "personal" to mean precisely the opposite of businessrelated: We speak of personal expenses and business expenses, personal life and work life, personal opinion and a company's view."
Moreover, the Commission also examined the nature of fiduciary relationship involved in the instant matter whereby the Respondent denied the information of ITRs under Section 8(1)(e) of the RTI act,2005. The Commission referred to the Hon'ble Supreme Court decision in CBSE v. Aditya Bandhopadhyay (2011) 8 SCC 497 wherein it was held as under:
22. ".... But the words 'information available to a person in his fiduciary relationship' are used in section 8(1)(e) of RTI Act in its normal and well recognized sense, that is to refer to persons who act in a fiduciary capacity, with reference to a specific beneficiary or beneficiaries who are to be expected to be protected or benefited by the actions of the fiduciary - a trustee with reference to the beneficiary of the trust, a guardian with reference to a minor/physically/infirm/mentally challenged, a parent with reference to a child, a lawyer or a chartered accountant with reference to a client, a doctor or nurse with reference to a patient, an agent with reference to a principal, a partner with reference to another partner, a director of a company with reference to a share-holder, an executor with reference to a legatee, a receiver with reference to the parties to a lis, an employer with reference to the confidential information relating to the employee, and an employee with reference to business dealings/transaction of the employer."
Furthermore, the Hon'ble High Court of Gujarat in Rajendra Vasantlal Shah vs. Central Information Commissioner and Ors. AIR 2011 Guj 70 had observed that any statutory body/ Institution/association meant to serve public good cannot claim to be working in a fiduciary capacity, and held as under:
"8.4. Respondent No. 4 is a religious charitable Trust, functioning under the Scheme formulated by the District Court, having considerable public importance and registered under the Bombay Public Trust Act, as a religious charitable Trust. Considering its nature and activities, emerging from the objects of the Trust, it can be stated that disclosure of such information is in relation to any public interest of activity. The Trust is engaged, in public activities, disclosure of its statements and accounts of income-tax returns and assessments orders cannot be withheld under Section 8(1)(e) or (j)of the R.T.I. Act."
In this context, the Commission draws reference to the observations made by the Hon'ble Delhi High Court in WRIT PETITION (CIVIL) NO. 7265 OF 2007 (Date of Decision : 25th September, 2009) wherein the Court has clarified the definition of "information under Section 2(f) of the RTI Act,2005 and held as under:
Page 4 of 98. "Information as defined in Section 2(f) means details or material available with the public authority. The later portion of Section 2(f) expands the definition to include details or material which can be accessed under any other law from others. The two definitions have to be read harmoniously. The term ―held by or under the control of any public authority in Section 2(j) of the RTI Act has to be read in a manner that it effectuates and is in harmony with the definition of the term ―information as defined in Section 2(f). The said expression used in Section 2(j) of the RTI Act should not be read in a manner that it negates or nullifies definition of the term ―information in Section 2(f) of the RTI Act. It is well settled that an interpretation which renders another provision or part thereof redundant or superfluous should be avoided. Information as defined in Section 2(f) of the RTI Act includes in its ambit, the information relating to any private body which can be accessed by public authority under any law for the time being in force. Therefore, if a public authority has a right and is entitled to access information from a private body, under any other law, it is ―information as defined in Section 2(f) of the RTI Act. The term ―held by the or under the control of the public authority used in Section 2(j) of the RTI Act will include information which the public authority is entitled to access under any other law from a private body.
13. Information available with the public authority falls within section 2(f) of the RTI Act.
The last part of section 2 (f) broadens the scope of the term information' to include information which is not available, but can be accessed by the public authority from a private authority. Such information relating to a private body should be accessible to the public authority under any other law. Therefore, section 2(f) of the RTI Act requires examination of the relevant statute or law, as broadly understood, under which a public authority can access information from a private body. If law or statute permits and allows the public authority to access the information relating to a private body, it will fall within the four corners of Section 2(f) of the RTI Act."
Furthermore, the Commission referred to the observations made by Hon'ble Courts in the light of disclosure of information in "public interest", keeping in view the true spirit behind the promulgation of the RTI Act, 2005, which are as under:
The Hon'ble Supreme Court of India in SLP(C) NO. 7526/2009 (CBSE & Anr. Vs. Aditya Bandopadhyay & Ors) had observed as under:
"37. The right to information is a cherished right. Information and right to information are intended to be formidable tools in the hands of responsible citizens to fight corruption and to bring in transparency and accountability. The provisions of RTI Act should be enforced strictly and all efforts should be made to bring to light the necessary information under Clause (b) of Section 4(1) of the Act which relates to securing transparency and accountability in the working of public authorities and in discouraging corruption"
The High Court of Delhi in General Manager Finance Air India Ltd & Anr v. Virender Singh, LPA No. 205/2012, Decided On: 16.07.2012 regarding the disclosure of information for public interest, held:
"8. The RTI Act, as per its preamble was enacted to enable the citizens to secure access to information under the control of public authorities, in order to promote transparency and accountability in the working of every public authority. An informed citizenry and transparency of information have been spelled out as vital to democracy and to contain corruption and to hold Governments and their instrumentalities accountable to the governed. The said legislation is undoubtedly one of the most significant enactments of independent India and a landmark in governance."Page 5 of 9
The High Court of Bombay in Shonkh Technology International Ltd. v. State Information Commission Maharashtra Konkan Region, Appellate Authority and United Telecom Limited v. State Information Commission Maharashtra Konkan Region and Ors., W.P. Nos. 2912 and 3137 of 2011 decided on 01.07.2011 held as under
"The RTI Act is an Act to provide for setting out the practical regime of right to information for citizens to secure access to information under the control of public authorities, in order to promote transparency and accountability in the working of every public authority. The preamble of the RTI Act itself refers to this aspect and the constitutional principles enshrined in several articles of the Constitution. It is very clearly postulated that democracy requires an informed citizenry and transparency of information which are vital to its functioning and also to contain corruption and to hold the Governments and their instrumentalities accountable to the governed. The revelation of information in actual practice is likely to conflict with other public interests including efficient operations of the Governments, optimum use of limited fiscal resources and the preservation of confidentiality of sensitive information. Therefore, the RTI Act seeks to harmonize these conflicting interests while preserving the paramount nature of democratic ideals."
Moreover, the purpose and object of the promulgation of the RTI Act,2005 was to make the public authorities more transparent and accountable to the public and to provide freedom to every citizen to secure access to information under the control of public authorities, consistent with public interest, in order to promote openness, transparency and accountability in administration and in relation to matters connected therewith or incidental thereto.
The Hon'ble Supreme Court in the matter of Bihar Public Service Commission v. Saiyed Hussain Abbas Rizwi: (2012) 13 SCC 61 while explaining the term "Public Interest" held:
"22. The expression "public interest" has to be understood in its true connotation so as to give complete meaning to the relevant provisions of the Act. The expression "public interest"
must be viewed in its strict sense with all its exceptions so as to justify denial of a statutory exemption in terms of the Act. In its common parlance, the expression "public interest", like "public purpose", is not capable of any precise definition. It does not have a rigid meaning, is elastic and takes its colour from the statute in which it occurs, the concept varying with time and state of society and its needs (State of Bihar v. Kameshwar Singh([AIR 1952 SC 252]). It also means the general welfare of the public that warrants recognition and protection; something in which the public as a whole has a stake [Black's Law Dictionary (8th Edn.)]." It is noted that certain issues have been raised in the RTI application which relate to disclosure of property details of the Public Charitable Trust that categorically works for the public welfare. Moreover, during the course of the hearing it was categorically stated by the Respondent that registration under Section 12A of the IT Act, 1961 was granted to the Third Party and that they were claiming several exemptions/ benefits under the said Act. Therefore it is apparent that the matter certainly involved larger public interest since the Government was granting several exemptions to the Third Party from payment of taxes hence there ought to exist transparency and accountability on the activities of the Third Party.
Also, the Hon'ble Supreme Court of India in the decision of R.B.I. and Ors. V. Jayantilal N. Mistry and Ors, Transferred Case (Civil) No. 91 of 2015 (Arising out of Transfer Petition (Civil) No. 707 of 2012 decided on 16.12.2015, while dealing with significance of free flow of information had stated as under:
"The ideal of 'Government by the people' makes it necessary that people have access to information on matters of public concern. The free flow of information about affairs of Page 6 of 9 Government paves way for debate in public policy and fosters accountability in Government. It creates a condition for 'open governance' which is a foundation of democracy."
The Commission further referred to the full bench decision of the CIC in File No.CIC/LS/A/2009/00190 dated 09.03.2010 wherein the CIC had decided on the issue of disclosure of information by the public charitable trusts as under:
10. "We have given a serious thought to the matter. We have also taken note of the pre-amble of the RTI Act which aims at promoting transparency and accountability in the working of the every Public Authority. In this context, it would be apt to advert to sub section 15 of section 2 of the IT Act which defines "charitable purpose". This sub section is extracted below :- "15. 'Charitable purpose' includes relief of the poor, education, medical relief and advancement of any other object of general public utility.
Needless to say, avowed purpose for which these institutions/entities come into existence is charity. Charity and secrecy are contradiction in terms. Any charitable institution should have no secrets and should be open to public for all purposes, including its finances. In other words, in our opinion, it will be in the larger public interest if the identity of the charitable trusts/institutions/entities which are granted exemption from income tax under the statutory provisions are placed in the public domain. Hence, in exercise of powers under section 25(5) of the RTI Act, we hereby recommend that the identity of the charitable trusts/institutions/entities which have been granted exemption from income tax under section 10 & under section 11/12 of the Income Tax Act is placed in public domain by way of suo- motu disclosure by the CBDT in terms of section 4(1)(b) r/w section 4(2) of the RTI Act."
The above mentioned decision of the CIC had been referred in File no.CIC/RM/A/2014/004628 (dated 23.12.2016) File no. CIC/RM/A/2014/ 003758/BS/9478 (dated 11.01.2016) and File No.CIC/DS/A/2012 /000688/RM (dated 10.04.2013).
The Commission felt that the Supreme objective/ motive with which the Central/ State Information Commission were constituted were to set out the practical regime of right to information for citizens to secure access to information under the control of public authorities, in order to promote transparency and accountability in the working of every public authority. In the light of the preamble of the RTI Act, 2005 there are several exemptions carved out under Section 8 of the RTI Act, 2005 which can be used by a Public Authority to deny information depending on the facts and circumstances of each case.
The purpose of the RTI Act, 2005 is transparency and accountability in the functioning of entities which impact citizens' daily lives. Recognizing the significance of the RTI Act, 2005 in empowering people with the means to scrutinize government action, the Hon'ble Delhi High Court in its judgment delivered by Justice Ravindra Bhat in Indian Olympic Association -Vs- Veerish Malik and others(WP)(C) No. 876/2007 had held as below:-
"The Act marks a legislative milestone in the post independence era to further democracy. It empowers citizens and information applicants to demand and be supplied with information about public records. Parliamentary endeavor is to extend it also to public authorities which impact citizens daily lives. The Act mandates disclosure of all manner of information and abolishes the concept of locus standi of the information applicant; no justification for applying (for information) is necessary; decisions and decision making processes, which affect lives of individuals and groups of citizens are now open to examination. Parliamentary intention apparently was to empower people with the means to scrutinize government and public processes, and ensure transparency. At the same time, the need of society at large, and Page 7 of 9 Governments as well as individuals in particular, to ensure that sensitive information is kept out of bounds have also been accommodated under the Act."
Furthermore, the Commission observed that a voluntary disclosure of all information that ought to be displayed in the public domain should be the rule and members of public who having to seek information should be an exception. An open government, which is the cherished objective of the RTI Act, can be realised only if all public offices comply with proactive disclosure norms. Section 4(2) of the RTI Act mandates every public authority to provide as much information suo- motu to the public at regular intervals through various means of communications, including the Internet, so that the public need not resort to the use of RTI Act.
The Hon'ble Supreme Court of India in the matter of CBSE and Anr. Vs. Aditya Bandopadhyay and Ors 2011 (8) SCC 497 held as under:
"37. The right to information is a cherished right. Information and right to information are intended to be formidable tools in the hands of responsible citizens to fight corruption and to bring in transparency and accountability. The provisions of RTI Act should be enforced strictly and all efforts should be made to bring to light the necessary information under Clause (b) of Section 4(1) of the Act which relates to securing transparency and accountability in the working of public authorities and in discouraging corruption."
The Commission also observes the Hon'ble Delhi High Court ruling in WP (C) 12714/2009 Delhi Development Authority v. Central Information Commission and Another (delivered on: 21.05.2010), wherein it was held as under:
"16.It also provides that the information should be easily accessible and to the extent possible should be in electronic format with the Central Public Information Officer or the State Public Information Officer, as the case may be. The word disseminate has also been defined in the explanation to mean - making the information known or communicating the information to the public through notice boards, newspapers, public announcements, media broadcasts, the internet, etc. It is, therefore, clear from a plain reading of Section 4 of the RTI Act that the information, which a public authority is obliged to publish under the said section should be made available to the public and specifically through the internet. There is no denying that the petitioner is duty bound by virtue of the provisions of Section 4 of the RTI Act to publish the information indicated in Section 4(1)(b) and 4(1)(c) on its website so that the public have minimum resort to the use of the RTI Act to obtain the information."
Furthermore, High Court of Delhi in the decision of General Manager Finance Air India Ltd & Anr v. Virender Singh, LPA No. 205/2012, Decided On: 16.07.2012 had held as under:
"8. The RTI Act, as per its preamble was enacted to enable the citizens to secure access to information under the control of public authorities, in order to promote transparency and accountability in the working of every public authority. An informed citizenry and transparency of information have been spelled out as vital to democracy and to contain corruption and to hold Governments and their instrumentalities accountable to the governed. The said legislation is undoubtedly one of the most significant enactments of independent India and a landmark in governance. The spirit of the legislation is further evident from various provisions thereof which require public authorities to:
A. Publish inter alia:
i) the procedure followed in the decision making process;Page 8 of 9
ii) the norms for the discharge of its functions;
iii) rules, regulations, instructions manuals and records used by its employees in discharging of its functions;
iv) the manner and execution of subsidy programmes including the amounts allocated and the details of beneficiaries of such programmes;
v) the particulars of recipients of concessions, permits or authorizations granted. [see Section 4(1) (b), (iii), (iv), (v); (xii) & (xiii)].
B. Suo moto provide to the public at regular intervals as much information as possible [see Section 4(2)]."
DECISION:
Keeping in view the facts of the case and the submissions available on record and in the light of the aforesaid decision of the Commission, the Respondent Public Authority is directed to comply with the spirit of the aforesaid decision and provide point-wise information to the Appellant within a period of 15 days from the date of receipt of this order.
The Commission also instructs the Respondent Public Authority to convene periodic conferences/seminars to sensitize, familiarize and educate the concerned officials about the relevant provisions of the RTI Act, 2005 for effective discharge of its duties and responsibilities.
The Appeals stand disposed accordingly.
(Bimal Julka) (िबमल जु का)
(Information Commissioner) (सूचना आयु )
Authenticated true copy
(अ भ मा णत स या पत त)
(K.L. Das) (के .एल.दास)
Dy. Registrar (उप-पंजीयक)
011-26182598/ [email protected]
दनांक / Date: 28.05.2019
Copy to:
1. Mr. Pramod Kumar Gupta, CCIT (Exemption) E-2 BLOCK, DR.S.P.M CIVIC CENTRE, MINTO ROAD, NEW DELHI-110002 Page 9 of 9