Income Tax Appellate Tribunal - Chandigarh
Sh. Satpal Gosain, Ludhiana vs Acit, Ludhiana on 26 November, 2018
आयकर अपील य अ धकरण,च डीगढ़ यायपीठ "बी" , च डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH 'B', CHANDIGARH ी संजय गग , याय क सद य एवं ीमती अ नपणा ू ग$ता ु , लेखा सद य BEFORE: SHRI SANJAY GARG, JM & SMT.ANNAPURNA GUPTA, AM आयकर अपील सं./ ITA No.132/Chd/2016 नधा रण वष / Assessment Year : 2007-08 Sh.Satpal Gosain बनाम The A.C.I.T., C/o G.B. Auto Circlel-1, Industries (Regd.), Ludhiana.
C-84, Focal Point, Ludhiana.
थायी लेखा सं./PAN NO: A B D P G 9 9 5 2 H
अपीलाथ /Appellant यथ /Respondent
नधा रती क ओर से/Assessee by : Shri Tej Mohan Singh, Adv.
राज व क ओर से/ Revenue by : Shri J.S. Kehlon, Sr.DR
सनवाई
ु क तार#ख/Date of Hearing : 14.11.2018
उदघोषणा क तार#ख/Date of Pronouncement: 26.11.2018 आदे श/Order PER ANNA PURNA GUPTA, A M:
The present ap peal has been fi l ed by the as sessee agai nst the order of the Commi ssi oner of I ncome Ta x ( Appeal s) -1, Ludhi ana (in short CI T( A) dated 29.1.2016 passed u/s 250 ( 6) of the I ncome Ta x Act, 1961 ( i n short referred to as 'Act') , confi rmi ng the l ev y of penalt y u/s 271( 1) ( c) of the Act.
2. Th e f a c t s o f t he c a s e a r e t h a t d uri ng the course of reassessment proceedi ngs, the A.O. noti ced that a housi ng soci et y consi sti ng of 95 present and e x MLAs of Punjab Legi sl ati ve Assembl y, was the owner of 21.02 acre land in vi l l age Kansal di stri ct Ludhi ana. The sai d housi ng soci et y of 2 ITA No.132/Chd/2016 A.Y.2007-08 the MLAs, named as the Punjab Cooperati ve Housi ng Bui l di ngs Soci et y Ltd., had entered i nto a tri partite joi nt devel opment agreement wi th M/s HASH Bui l di ng Pvt. Ltd, Chandi garh and TA TA Housi ng Devel opment Co. Ltd., Mumbai ,for setting up a resi dential cum commercial pro ject CAMELO T. On p erusal of the agreement, the AO found that Punjab Cooperati ve Housi ng Bui l di ng Soci et y Ltd., woul d transfer i ts l and to TA TA Housi ng Devel opment Co. Ltd, Mumbai i n l i eu of monetar y consi derati on and consi derati on i n ki nd. As per the agreement each member of t he Punjab Cooperati ve Housi ng Bui l di ng So ci et y Ltd., havi n g a pl ot of 500 sq. yard i n the soci et y woul d recei ve Rs.82,50,000/- as monetar y consi derati on. Accordi ngl y, a total monetar y consi derati on of Rs.1,06,42,50,000/- was recei vabl e by al l the i ndi vi dual members of the soci et y taken together. I n addi ti on to thi s, as consi derati on i n ki nd each suc h member ( i .e. members o wi ng pl ot of 500 sq. yd) woul d receive one furni shed fl at measuri ng 2250 sq. ft. to be constructed by M/s Tata Housi ng Devel opment Company Ltd. The cost of each furni shed flat @ 4500/- sq. ft. havi ng an area of 2250 sq. ft was worke d out to Rs.1,01 ,25,000/-. The assessee, Sh. Satpal Gosai n, o wned a 1 000 sq. yard l a nd i n the soci et y. As per the agreement he was enti tl ed for ful l consi derati on compri si ng Rs.1,65,00,000/- as monetar y consi derati on and t wo furni sh ed fl ats of 225 0 sq.ft. as consi derati on i n ki nd. The total c ost of these t wo furni shed fl at came to Rs.2,02,50,000/-. So the total consi derati on accordi ng to the AO was at l east Rs.3,67,50,000/-. The 3 ITA No.132/Chd/2016 A.Y.2007-08 assessee had al s o recei ved t wo p a yments of Rs.3 0 l ac and Rs.36 l ac al ready. Therefore, the AO made an addi tion of Rs.3,55,21,070/- to the i ncome of the assesse e for the i mpugned year and i ni ti ated penal t y proceedi ngs u/s 271( 1) © of the Act.
3. Duri ng the course of the penal ty proceedi ngs, the AO asked the assessee as to why the penal t y ma y not be i mposed. The AR of the assessee repl i ed as under:-
"( a) T hat the Hon'bl e Pun jab & H aryan a H igh Cour t h as d irec ted th at no coerc i ve me asures shoul d be used. Coerc ive me asu res incl udes pen al ty. As p er " thes aurus. c o m" onl ine d ic tion ar y we bs i te pen al ty h as be en s tated to be synon y m of th e wo rd coerc ive me asure.
(b) T hat i t is sub mi tted th at the order of the wo r th y IT AT - Ch and ig arh Benc h h as been appe al ed in Pun jab & H ar ay an a H igh Cour t.
(c) T hat the Jo in t Devel o p men t Agr ee men t ver y cl e arl y s tates th at the soc ie ty wil l be tr ansf erring the l and onl y upon the rece ip t of cons ider ation. T he f ac t th at the l and onl y to the ex ten t wh ic h h as been tr ansf erred in f avour of T HDC, h as been reg is ter ed in f avour of T HDC and th e o wn ersh ip of the T HDC in res pec t of th is l and h as been r eg is tered in revenue records. T he l and wh ich h as no t been tr ansf erred to T HDC s tands in the n ame of soc ie ty til l d ate in the revenue records. T his is enough ev idence th at o wn ersh ip in res pec t of un tr ansf or med l and l ies wi th the soc ie ty onl y and the v ar ious r igh ts g iven under the Jo in t Devel o p men t Agr ee men t are con d ition al and no t enough to g iv e the o wn ersh ip to T HDC had possess ion as ref erred by the Ld. AO been an y cr iter i a of tr ans f er, the en tire l and shoul d h ave been tr ansf erred in the n ame of T HDC in the revenue recor ds.
( d) T he assessee al s o rel ied upon cer tain jud ic i al pronounce men ts i n h is f avour. "
4 ITA No.132/Chd/2016A.Y.2007-08 But the AO was not satisfied with the reply of the assessee and imposed penalty amounting to Rs.79,72,552/- u/s 271(1)(c) of the Act for concealing his income."
4. Th e m a t t e r w a s c a r r i e d i n a p p eal b e f o r e t h e L d.C I T( A ) w h o h e l d t h a t Ho n ' b l e P un j a b & H a r y a n a H i g h Cou r t i n th e c a s e o f C . S. A t wa l V s . CI T & An o t h e r i n i t s o rd e r d a ted 2 2 . 7 . 2 0 1 5 h ad h e l d t h a t t h e ca p i t a l g a i ns t a x w a s n o t p a y a b l e o n t h e c o n s i d e r at i o n wh i c h h a d n o t b ee n r e c e i v e d d u r i n g t h e y e a r a n d w h i c h st o o d c a n c e l l e d a n d i n c a p a b l e of p e r f o r m a nc e a t pr e s e n t d u e t o v ar i o u s o r d e r s o f th e H o n ' b l e S u p r e m e C o ur t a n d t h e H o n 'b l e H i g h C o u r t i n P I Ls f i l e d.
F o l l o w i n g th e s am e t h e L d . CI T( A ) h e l d t h a t t h e a ss e s s e e w a s l i a b l e t o pa y t a x o n l y o n t he ca p i t a l g a i n s r e l at i n g t o t h e amount r e ce i v ed by h i m . C on se q u e n t l y he held that no p e n a l t y w a s l ev i a b l e o n t h e c api t a l g a i n s w hi c h w a s n o t actually r e ce i v ed by the assessee during t he r e l e v a nt a s s e s s m e nt y e ar , h o w e v er , w i th regard to t he a m o u nt r e c e i v e d d u r i n g t h e y e a r t h e L d .C I T( A ) u p h e l d t h e l e v y o f p e n a l t y s t a t i ng t h a t t h e a s s e sse e h a d di s c l o sed t h e s ai d a m o u n t i n i t s re t u r n f i l e d i n re s p o n s e t o n ot i ce u / s 1 4 8 o n l y a f t er d e t e cti o n b y t h e D e p ar t m e n t a nd n o t s u o m o t t o.
Th e r e l e v a n t f i nd i n g s o f t h e Ld .C I T( A ) a t p ar a 2 . 4 o f h i s o r d e r a r e a s u nde r :
"2.4 I have considered the facts of the case, the basis of the penalty imposed by the Assessing Officer and arguments of the AR during the course of the penalty as well as the appellate proceedings. The Hon'ble Punjab & Haryana High court in the case of C.S. Atwal vs. CIT and Anr. in ITA No.200, 201, 232 to 25S, 271 to 273, 283 to 5 ITA No.132/Chd/2016 A.Y.2007-08 298, 303 to 308, 310 to 316, 332 to 334, 356 to 358 and 361 of 2013, 10 to 16, 25, 26, 73, 74, 90, 110, 136, 191, 192, 253, 254, 278 and 398 of 2014 vide order dated 22.07.2015 has held as under:
"As per the order of the Hon'ble Punjab & Haryana High Court " it was submitted by learned counsel for the assessee-appellant that whatever amount was received from the developer, capital gains tax has already been paid on that and sale deeds have also been executed. In view of cancellation of JDA dated 25.02.2007, no further amount has been received and no action thereon has been taken. It was urged that as and when any amount is received, capital gains tax shall be discharged thereon in accordance with law. In view of the aforesaid stand, while disposing of the appeals, we observe that the assessee appellants shall remain bound by their said stand."
Therefore, as per the said order of the Hon'ble Jurisdictional High Court, the appellant was not liable to pay capital gains tax on the consideration which had not been received during the year and which stood cancelled and incapable of performance at present due to various orders of the Hon'ble Supreme court and the Hon'ble High Court in PILs. Therefore, the appellant was liable to pay capital gains tax only on the amount received by him. Hence, in view of the said order of the Hon'ble Jurisdictional High Court, no penalty under sec271(l)(c) can be levied on the amount of capital gains which was not actually received by the appellant during the relevant assessment year.
However, the appellant has received an amount of Rs.24,00,000/- during the year under consideration on which capital gains tax was to be imposed. The original return of income was filed on 03.12.200/- in which income from capital gains was shown as 'nil'. Notice u/s 148 was issued on 04 01.2010 and served on the assessee on 07.01.2010. In response to the same, the appellant filed a revised return u/s 148 on 02.02.2010 which also included income from capital gains amounting to Rs.22,00,670/- after applying indexation. The Assessing Officer rejected this return by holding that the revised return filed by the assessee was beyond time prescribed u/s 139(5) and therefore was treated as non-est. The CIT (Appeals) in the quantum order for the year under consideration has held that the return filed in response to notice u/s 148 was valid. However, the fact remains that the same was furnished only after detection by the department and not suo motto, the said return is thus not voluntary but only after notice u/s 148 was issued" by the department. Therefore, there is no force in the appellant's plea that the capital gains were returned before detection by the department. Further, the appellant is advised by experts/C.As in income tax matters and is expected to be aware of the provisions of law and therefore the plea that he was verbally told by officials of TATA Housing Development Co. Ltd. & M/s HASH Builders Pvt Ltd. that the money paid 6 ITA No.132/Chd/2016 A.Y.2007-08 was advance money in contemplation of sale and therefore the said amount was not included in his return, is not acceptable.
The cases relied upon by the AR are distinguishable on facts. The AR has relied on the decision of the Jurisdictional Hon'ble High-Court in the case of CIT vs. Suraj Bhan (2007) 159 taxmann 26 wherein the assessee had filed revised return showing higher income and explained that the same was done to buy peace of mind and to avoid litigation and it was held that penalty cannot be imposed merely on account of subsequently declared higher income. However, in the case under consideration notice u/s 148 was issued on 04.01.2010 and the revised return filed on 02.02.2010 was treated as non-est return since it was filed beyond the time prescribed u/s 139(5) and the Assessing Officer has categorically held that the assessee has failed to disclose the profits or gains from the transfer of capital assets prior to detection by the department. Although the CIT (Appeals) held in the quantum order that The return was valid but the fact remains that it was filed after detection by the department. The AR has further relied on the case of ITO vs. Chatrabhuj Hinduji Soni of the Hon'ble ITAT Ahmadabad in ITA no. 620/Ahd/2008 wherein the revised return filed in pursuance of notice u/s 148 wherein income was surrendered was regularized by the revenue and the Assessing Officer had failed to make any objection that the income declared in the revised return or its explanation was not bonafide whereas in the instant case the Assessing Officer has declared the revised return as non-est and has recorded that the assessee had failed to disclose the said income in its return of income and that the same was not offered for tax prior to detection by the department. The AR has also placed reliance on the case of Late N.R. Palanivel vs CIT(2014) 90 CCH 0104 wherein the assessee was operating transport bus and survey was conducted u/s 133A . Further, in the said case, notice was issued u/s 148 and the revised return filed was accepted by the Assessing Officer without any addition and the explanation made on the basis of Explanation B to sec271(l)(c) was not considered by the revenue and therefore the order of Hon'ble ITAT confirming the penalty proceedings was set-aside whereas the facts in the instant case are distinguishable as discussed earlier.
It has been held in the case of Prem Pal Gandhi vs CIT 335 ITR 23 (2009) by the Jurisdictional High court that where the assessee has filed a revised return surrendering the additional income only on coming to know the detection of concealment by the department and it is not a case of bonafide voluntary disclosure, penalty u/s 271(l)(c) is leviable. Reliance is also placed on the case of Mahavir metal works vs CIT(PSH) 92 ITR 513 to hold that penalty u/s 271(l)(c) is attracted notwithstanding the fact that the assessee filed a revised return, where the omission is deliberate and where the return is revised only after the 7 ITA No.132/Chd/2016 A.Y.2007-08 department got information. Further, it has been held in Bhairav Lai Verma vs. Union of India (ALL) 238 ITR 855 that "voluntarily" means out of free will without any compulsion and that if the department has incriminating material with regard to the disclosed income, disclosure is not voluntary. In the instant case the disclosure was not voluntary. Therefcu^tJ^6 appellant had no bonafide cause for not declaring the said capital gains income of Rs.22,00,670/- on the amount of consideration received during the year in its return of income originally filed. Therefore, the penalty levied u/s 271(l)(c) for concealment of income as well as for furnishing of inaccurate particulars of income is confirmed on the said amount however, the balance amount of penalty levied on amount not actually received during the year is hereby deleted in view of the said judgment of the Hon'ble Jurisdictional High-Court. This ground of appeal is partly allowed."
5. A g g r i e v e d b y the s a m e t h e a ss es s e e h a s c o m e u p i n a p p e a l b ef o r e us r a i s i n g f o l l o wi n g g r o u n d s :
"1. That the Ld. C1T(Appeals) grossly erred in facts and on law, in confirming the levy of penalty, as imposed by the Ld. A.O. U/S 271(l)(c) of the Income-tax Act, 1961 for alleged non- disclosure of long term capital gains.
2. That the assessee had declared long-term capital gains in his return filed U/S 148 which had been declared valid and accepted as per the order of C1T(Appeals) dated:
21.12.2011.
3. That by any reckoning, the issue being highly debatable and the assessee's bonaflde not in doubt, nor his explanation held to be false, the levy of penalty was wholly illegal and hence not sustainable.
4. That the order of Ld, CIT( Appeals) is against law and facts of the case and therefore, liable to be set aside.
5. That the appellant craves, leave to add, amend, alter, modify or substitute all or any of the above mentioned grounds of appeal when the appeal is finally heard and disposed off."
6. D u r i n g t h e co u r se o f he a r i n g b e f or e u s t h e Ld . c ou n s el f o r a s s es s e e po i n t e d o u t t h a t t he p e n a l t y l e v i e d o n i d e n ti c a l i s s u e o f c o n s i d er a t i o n r e c ei v e d d u r i n g t h e y e a r o n a c c o u n t of transfer of land by virtue of Joint D e v e l o p m e nt A g r e e m e n t ( J DA) b e t w e e n Ta t a H o u s i n g B u i l d i n g S o c i e t y 8 ITA No.132/Chd/2016 A.Y.2007-08 L t d . , M /s H a sh B u i l d e r s P v t . L td . a n d P u n j a bi C o o p e r a t i v e H o u s e B u i l d i n g S o c i e t y L t d . i n w h i c h t h e a s s e ss e e o w n s a p l o t h a s b e e n d ea l t w i t h b y t h e I TA T C h a n d i g a r h B e n c h i n t h e c a s e o f S h ri C h a r a n j i t Si ng h A t w a l V s . I TO i n I TA N o . 6 6 / C h d/ 2 0 1 6 d a t e d 2 0 . 4. 2 0 18 . I t w a s po i n t ed o u t t h at t h e I . T. A . T. h a d h e l d t h e i s s u e of c h a r g i n g t h e cap i t a l g a i n s e a r n e d on t r a ns f e r o f l a n d ma d e d u r i n g t h e y e a r as a d e b a t a b l e i s s ue a n d di r e c t ed t he d e l e ti o n of p e na l t y l ev i ed o n t h e s a m e . O u r a t t e n t i o n w a s d r a w n t o t h e r e l e v a nt f i n d i n g s o f t h e I . T. A . T. a t p a r a 1 3 o f t h e o r d e r as u n d e r :
13. We have considered the rival submissions and have also gone through the records. In our view, as the facts narrated above suggests, it was not a simple case of transfer of land. The land was owned by the Society constituting 95 Members including the assessee. The consideration settled for the transfer was in cash as well as in kind i.e in the shape of flats to be given to the Members as per "their proportionate share in the property.
As discussed above, though the assessee had received the cash component by way of first two installments as per the proportionate share in the land on the pro-rata transfer of the land by society, however, the consideration in kind i.e. flats was not received by the assessee as the JDA could not mature. Hence, there seems force in the contention of the assessee that he was of the bonafide belief that the transfer in this case would be completed only when the JDA would mature or succeed. As observed above, the Hon'ble Supreme Court has already held that the transfer in respect of the remaining part of the land would not fall in the definition of the transfer as provided u/s 2(47) of the I.T. Act and there was no certainty of the transactions getting successful.
The assessee suo mo to revised the return though belatedly on 7.10.2009 when the regular assessment proceedings were under progress and offered the capital gains tax in respect of amount received by him as per his share out of the first two installments received by the Society on prorate transfer of land. Till the filing of the revised return, the assessec was never confronted by the Assessing officer on this issue. The assessee thus suo moto /I voluntarily offered capital gains on the amount actually received by him.
9 ITA No.132/Chd/2016A.Y.2007-08 The issue was highly debatable. Even the land was transferred by the society. In the JDA, society has been referred to as 'owner'. If the society was the 'owner' then the capital gains apparently would also be taxable in the hands of the society. The Assessing officer of the society has also taxed the capital gains in the hands of the society on protective basis. Hence, it was a debatable issue whether the capital gains will be taxed in the hands of the society or in the hands of the assessee. Not only the issue regarding the nature of the transactions but also about the date on which the transfer can be said to have completed, was debatable.
Further, in the similar facts and circumstances in the case of another assessee namely Shri Bal winder Singh Dhillon, the Coordinate Chandigarh Bench of the Tribunal for the assessment year 2008-09 in ITA No. 1140/Chd/2014 vide order dated 3.8.2015 has upheld the order of the CIT(A) deleting the penalty so levied by the Assessing officer u/s 271(l)(c) of the Act. The said decision has been further followed by the Chandigarh Bench of the Tribunal in the case of 'ITO Vs. Smt. Neena Chaudhary' in ITA No. 1096/Chd/2014 for assessment year 2008-09 wherein also the Departmental appeal challenging the deletion of penalty levied u/s 271(l)(c) has been dismissed. The said decision have also been followed by the Amritsar Bench of the Tribunal in 'Shri Raghunath S ah ai Puri Vs. DCIT order dated 13.6. 2016 in IT A No. 633/ASR/2014 for assessment year 2007-08. Considering the overall facts and circumstances of the case, and in view of the decisions of the Coordinate Benches of the Tribunal, in respect of income earned by the other members of the society from the same transactions, whereby, upholding the order of the CIT(A) in cancelling penalty u/s 271(l)(c) of the Act, we are of the view that this is not a case of furnishing of inaccurate particulars of income or concealment of income so as to attract the penal provisions of section 271(l)(c) of the Act. The penalty so levied by the lower authorities in this case is hereby ordered to be deleted."
7. Th e L d . c o u n s e l f o r a s s e s se e , t h er e f o r e , st a t e d t ha t t he i s s u e w a s d i r ec tl y c o v e r e d b y t he a f o r e s a i d d ec i si o n o f t h e I . T. A . T. a n d n o p e n a l t y w as l ev i a b l e i n te r e s t h e p r e s e n t case.
8. Th e L d . D R , o n t h e o t h e r h a n d , r e l i e d u p o n t h e o r d e r o f t h e CI T( A ) .
10 ITA No.132/Chd/2016A.Y.2007-08
9. W e h a v e h e a rd th e r i v al c on t e n t i o n s , g on e t hr o u gh t he o r d e r s o f a u t h o ri t i e s b e l o w a n d a l s o t h e d e c i s i on s r e f e r r ed t o b e f o r e u s . A dm i t t e d l y t he p e na l t y i n t h e p r e sen t c a s e h a s been l e v i ed on the c a p i t al gai ns l i abl e to ta x in the i mpugned year by vi rtue of the deci si on of the Hon'bl e Juri sdi cti onal Hi gh Court i n the case of C.S.At wa l ( supra) .
We have al so gone through the order passed by the I . T.A. T. on the i ssue of penal t y l evi ed on the sai d capi tal gai ns i n the case of C.S.At wal ( supra) i tsel f and fi nd that i t had found the i ssue of chargi ng the capi tal gai ns to ta x in the i mpugned year as a debatabl e i ssue. The I . T.A. T. had hel d that the l and wa s transferred by the soci et y and even JDA referred the soci et y as the o wner, therefore the capi tal gai ns shoul d have bee n ta xed i n the h ands of the soci et y, whi ch the A.O. had do ne on protecti ve basi s. On thi s basis the I . T.A. T. hel d th a t the i ssue whet her the capi tal gai ns were ta xabl e i n the hands of the assessee was a debatable i ssue.
The I . T.A. T. al s o hel d that eve n the date on whi ch the transfer coul d be sai d to have bee n compl eted was debatabl e si nce whi l e the Revenue of the vi e w that the tr ansfer took pl ace when JDA was entered i nt o, the Hon'bl e Hi gh Court had hel d other wi se and had subjected to ta x onl y capi tal gai ns earned on transfer of l and whi ch had actual l y taken pl ace. The I TA T al so hel d that there was for ce in the contenti on of the assessee that he was of the bonafi de bel i ef that the transfe r woul d be com pl eted onl y whe n the JDA woul d mature si nce the consi der ati on i n ki nd ha d not been recei ved as the JDA coul d not mature. Si nce the facts and 11 ITA No.132/Chd/2016 A.Y.2007-08 ci rcumstances l eadi ng the l ev y of penal t y i n the present case are i denti cal to t he case of C.S.At wal ( supra) and Ld. DR has not brought to our noti ce an y di sti ngui shi ng facts wi th regard to the sai d case, the deci si on rendered therei n wi l l appl y squarel y t o the present ca se al so, fol l o wi ng whi ch we del ete the penal t y l evi ed.
10. The assessee has al so rai sed l egal ground before u s but no arguments were made vi s-à-vi s the same. The same, therefore, i s di smi ssed.
11. I n e f f e ct , t h e a p pe a l o f th e a s s es se e i s p a rt l y al l o we d .
O r d e r p r on o u n c ed i n t h e O p e n Cou r t .
Sd/- Sd/-
संजय गग अ नपणा
ू ग$ता
ु
(SANJAY GARG ) (ANNAPURNA GUPTA)
याय क सद य/ Judicial Member लेखा सद य/ Accountant Member
*दनांक /Dated: 26th November, 2018
*रती*
आदे श क त*ल+प अ,े+षत/ Copy of the order forwarded to :
1. अपीलाथ / The Appellant
2. यथ / The Respondent
3. आयकर आय-त
ु / CIT
4. आयकर आय-त
ु (अपील)/ The CIT(A)
5. +वभागीय त न0ध, आयकर अपील#य आ0धकरण, च2डीगढ़/ DR, ITAT, CHANDIGARH
6. गाड फाईल/ Guard File
आदे शानसार
ु / By order,
सहायक पंजीकार/ Assistant Registrar
12 ITA No.132/Chd/2016
A.Y.2007-08