Income Tax Appellate Tribunal - Jaipur
Modern Threads (India) Ltd. , Jaipur vs Department Of Income Tax on 11 August, 2015
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IN THE INCOME TAX APPELLATE TRIBUNAL,
JAIPUR BENCHES, JAIPUR
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BEFORE: SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM
vk;dj vihy la-@ITA No. 795/JP/2012
fu/kZkj.k o"kZ@Assessment Year : 2002-03
The ACIT cuke M/s. Modern Threads
Circle- 6 Vs. (India) Ltd.
Jaipur A-4, Vijay Path, Tilak
Nagar, Jaipur
LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCM 1850 A
vihykFkhZ@Appellant izR;FkhZ@Respondent
jktLo dh vksj ls@ Revenue by : Smt. Neena Jeph, JCIT
fu/kZkfjrh dh vksj ls@ Assessee by : Shri Madhukar Garg &
Shri Anirudh Garg, CA
lquokbZ dh rkjh[k@ Date of Hearing : 11/06/2015
?kks"k.kk dh rkjh[k@ Date of Pronouncement : 11 /08/2015
vkns'k@ ORDER
PER T.R. MEENA, AM
This is an appeal filed by the Revenue against the order of the ld.
CIT(A)-II, Jaipur dated 20-07-2012 for the assessment year 2002-03 raising therein solitary ground as under:-
''On the facts and in the circumstances of the case, the ld. CIT(A) has erred in deleting penalty of Rs. 7,65,060/- imposed by AO u/s 271(1)(c ) holding the change of accounting system which resulted valuation of stock at a lower side do not show deliberate intention of the assessee of furnishing inaccurate particulars/ concealment of facts.'' 2 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
2.1 Brief facts of the case are that the assessee filed its return of income for the assessment year 2002-03 on 28-10-2002. The income declared therein amounted to loss of Rs. 42,66,16,836/-. The assessment was completed u/s 143(3) on 24-02-2005. The loss was at Rs.
42,42,44,972/-. The additions were made on account of change in method of valuation of closing stock amounting to Rs. 21.43 lacs and on account of late payment of PF& ESI amounting to Rs. 2,28,864/-. During the course of assessment proceedings, it was observed by the AO that as per the method of accounting employed the valuation of stock in process had been changed from cost plus expenses to estimated realizable value.
This resulted in a higher claim of loss by a sum of Rs. 21.43 lacs. The change in method of valuation had not been found justified by the AO.
Therefore, the AO made the addition under both the heads i.e. valuation of closing stock at Rs. 21.43 lacs and PF & ESI at Rs. 2,28,864/-.
2.2 This was challenged before the ld. CIT(A) who has confirmed the addition on account of change of method of valuation at Rs. 21.43 lacs vide his order dated 12-01-2009. A show cause notice dated 24-02-2010 for imposing of the penalty u/s 271(1)(c) of the Act was issued to the assessee. The assessee also filed its reply dated 09-03-2012 in response to show cause notice which has been reproduced by the AO at pages 1 to 3 in the penalty order.
3 ITA No.795/JP/2012ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
2.3 After considering the reply of the assessee, the AO held that there is no justification available with the assessee for changing the method of valuation of closing stock and thereafter also not added the under valuation of closing stock to the declared income of the assessee. The ld.
CIT(A) also confirmed the addition. He further relied on judgement of Hon'ble Apex Court in the case of Dilip N Shroff, 291 ITR 519 wherein it is held that primary burden to prove the concealment is on the Revenue.
Further the case of the assessee falls within the provision of Explanation 1 to Section 271 of the I.T. Act and held that the amount added or disallowed in computing total income of such person as a result thereof shall, for the purpose of clause (c) of this sub-section, be deemed total income represent the income in respect of which particulars have been concealed. The income includes losses also. The AO further relied on the Hon'ble Supreme judgement in the cases of CIT vs. Gold Coin Health Food (P) Ltd. (208) 172 Taxman 386/ 304 ITR 308 (SC) and also Hon'ble Jurisdictional High Court judgment in the case of CIT vs. Mohd.
Mohtram Farooqui (2002) 177 CTR 434. Thus in view of the above findings, the AO treated the addition of Rs. 21.43 lacs as concealed income on which 100% penalty of tax sought to be evaded at Rs.
7,65,051/- was imposed.
4 ITA No.795/JP/2012ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
2.4 Being aggrieved by the order of the AO, the assessee carried the matter before the ld. CIT(A) who deleted the penalty by observing as under:-
''3.1 I have duly considered the submissions of the appellant. The assessee company was engaged in the business of manufacturing of woolen yarn and synthetic yarn. As the assessee company was incurring losses consistently, it had made reference to BIFR to declare it a sick company. Even in the current year, the losses of the appellant company stood at Rs. 4266 lacs. The AO noticed that the assessee company had changed its method of valuation of closing stock and as a result the profit had been reduced by an amount of Rs. 21.43 lacs. The AO held that there was no justification whatsoever for change in the method of valuation. The AO placed reliance on the decision of Dilip N Shroff (291 ITR 519) and conclude that the case of assessee company was covered by explanation 1 to Section 271 of the I.T. Act. Accordingly, the AO levied penalty of Rs. 7,65,060/- u/s 271(1)(c) of the I.T. Act. On careful consideration of the facts in the entirety, I am not inclined to agree with the findings of the AO. In the present case, the appellant had duly disclosed the complete particulars regarding change in the method of valuation of stock in process from cost plus expenses to estimated realizable value. It was categorically mentioned in Note 18 of Schedule 15 of the annual report of the assessee company that the material cost included an amount of Rs. 21.43 lacs being valuation loss on account of valuation of tock in process of thread division which was estimated at realizable value. Further in the tax audit report, it was categorically mentioned in Annexure B that the Modern Thread Unit, the valuation of stock in process had been changed from cot plus expense to net realizable value. Thus the appellant had made complete disclosure regarding change in the method of valuation. Further the valuation of work in process had been done as per AS-2 issued by Institute of Chartered Accountant of India which provided that practice of writing down the inventories below the cost to net realizable value was consistent with the view that the asset should not be carried in excess of amount expected to be realized from its sale or use. Further appellant company was closed since 20-08-2001 as AVVNL had issued notice for recovery of its dues and had attached the entire office premises and plant. The stock of work in process had been valued at net realizable 5 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
value as on 31-03-2002 since the plant was closed and no production had been carried out. As a result, the value of stock in process had gone down substantially. No benefit whatsoever had been derived by the appellant company as the closing stock of the current year would become opening stock of the next year and in the current year, the appellant company had declared losses of Rs. 42.66 crores. The fact that the AO and CIT(A) did not accept the contentions of the assessee company and made/ confirmed addition to the returned income did not automatically invite penalty. Where divergent views exit either within the Department itself or such divergent views are expressed by different High Courts and there is no uniformity or consensus of opinion on any aspect of law, the assessee cannot be faulted for taking a particular stand. The caveat, of course, is that the assessee must have placed all his cards on the table by disclosing each and every fact to the Departmental authorities or the Court concerned or the High Court concerned does not concur with the legal stand adopted by the assessee that will not be reason enough to hold that the assessee is guilty of concealment of income or of furnishing inaccurate details. In the case of CIT vs. Devson Logistics (P) Ltd.
(329 ITR 483), the Tribunal reversed the of the CIT (Appeals) by holding that during the period under consideration, the assessee had changed its method of accounting and such change was not bona fide and the onus cast upon the assessee of proving the factum of rendering services by the sundry creditors of the assessee was not discharged by mere filing of a log book. The Assessing Officer imposed a penalty of Rs. 33,07,220/- invoking the provisions to Explanation 1 to Section 271(1)© on the ground that the assessee had concealed the particulars of its income and furnished inaccurate particulars. The CIT (A) confirmed the penalty but on further appeal, the Tribunal deleted it. On the facts, the tribunal held that the assessee could not be said to have concealed its income or furnished inaccurate particulars thereof because the assessee had itself placed the details of the total bill raised against the municipal corporation as not payable to the assessee was not declared by the assessee as its income but the non-acceptance of these particulars stated by the Assessing Officer did not amount to concealment of income. The Tribunal observed that the credit outstanding against the same creditors was accepted by the Assessing Officer in subsequent years and therefore, no penalty could be levied. Since the additions were made only on account of divergent views taken with regard to the material on record, it was unsafe to conclude that the assessee was guilty of 6 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
concealment of income or of furnishing inaccurate particulars thereof. On appeal, the Hon'ble Delhi High Court held that the Tribunal was not right in holding that change in the method of accounting by the assessee company was not justified. Even assuming the Assessing Officer was justified in not accepting the legal stand taken by the assessee itself, it could not be said that the assessee had concealed the same. The assessee's claim against the municipal corporation for deductions made by the municipal corporations from the bills of the assessee was dismissed by the High Court and hence the stand adopted by the assessee that no real income had accrued to it was also proved to be true. Making of a claim by the assessee which was not sustainable did not amount to furnishing inaccurate particulars. The assessee could not be said to have changed its method of accounting from mercantile to cash and could not be charged with suppressing receipts to the extent of Rs. 35,39,631/-. The addition in respect of the balance outstanding to the sundry creditors for hire charges had been made only because the assessee was unable to prove the balance in the manner called upon by the Department, possibly due to paucity of time, but there was ample material embedded in the record itself which was accepted by the Department in subsequent assessment proceedings, to the effect that the outstanding were genuine. The very same creditors were subsequently found by the Department itself to be genuine creditors of the assessee. The creditors were paid their entire outstanding amounts by the assessee and this fact has been verified by the Department from the creditors themselves. It is well settled that though findings recorded in the assessment proceedings may constitute evidence in the course of penalty proceedings, they cannot be regarded as conclusive. The Tribunal in assessment proceedings had restored both the additions made by the Assessing Officer but the findings of the Tribunal in assessment proceedings were not conclusive and binding on a Coordinate Bench of the Tribunal in penalty proceedings. It was incumbent upon the Tribunal in penalty proceedings to independently examine the evidence and the material on record for the purpose of judging whether the penalty proceedings on account of concealment of income or furnishing of inaccurate particulars thereof were justified. It was held that this had been done by the Tribunal in the instant case. The Hon'ble Delhi High Court held that divergent views amongst Departmental authorities in respect of both the additions positively indicated that it would be unsafe to infer that the assessee was guilty of 7 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
concealment of income or furnishing of inaccurate particulars thereof.
The ld. CIT(A) relied on the case Narita Investment (P) vs. CIT [311 ITR (AT) 398, [Mumbai] (The assessee was a builders and was following the completed project method of accounting........Penalty could not be imposed) In this case it was held that penalty could not be imposed.
The ld. CIT (A) further relied on the case of CIT vs. National Mining Co. [311 ITR 289 [P&H] (The assessee- firm derived its income from job work of various contracts.......Therefore there was no question of concealment or of furnishing of inaccurate particulars within the meaning of Section 271(1)( c ) of the Act. In this case the levy of penalty was cancelled.
The ld. CIT (A) further relied on the case ACIT vs. Pioneer Tubewell Industries (P) Ltd.[ 254 ITR AT 107, Calcutta( While framing the assessments for the assessment years 1987-88 and 1989-90, it was noticed by the Assessing Officer that the assessee had advanced unsecured loans of Rs. 19,42,049 and Rs. 8,55,833/- to its sister concern in both the assessment years under consideration for which no interest was charged by the assessee....... Mere addition made by the Assessing Officer and confirmed by the CIT (A) was not a ground for levying penalty u/s 271(1)(c ). Accordingly the order levying the penalty was cancelled.
These decisions are squarely applicable to the facts and circumstances of the present case. I therefore, direct the AO to cancel the order levying penalty of Rs. 7,65,060/- u/s 271(1)(c ) of I.T. Act. These grounds of appeal are allowed.'' 2.5 Now Revenue is before us wherein the ld. DR supported the order of the AO.
2.6 At the outset the ld. AR of the assessee through his written submission has submitted as under:-
''The learned Assessing Officer has levied penalty in respect of amount of Rs.21,43,000 /- which amount was added to the income of the assessee on account of valuation of stock in 8 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
process. It is submitted that so far as this amount is concerned, the assessee has duly furnished complete particulars regarding the change in the method of valuation of stock in process from cost plus expenses to estimated realizable value and the said fact was also disclosed by way of Note No.18 to Schedule-15 being Notes on Accounts to the Annual Accounts ( PBP No.10). Further, in the tax audit report it was also mentioned that in the Thread Unit valuation of stock in process has been changed from cost plus expenses to estimated realizable value which has resulted in higher claim of by a sum of Rs.21.43 lacs. Copy of tax audit report has been placed at PBP No.17-28 and attention is invited to the page 27 being the Annexure-B to the tax audit report wherein this fact has clearly been disclosed in the column "method of accounting employed". Further, on page 28 being Annexure-C to the tax audit report showing method of valuation of closing stock in trade against process stock it is duly mentioned that the same is valued at estimated net realizable value. Thus, complete disclosure was made by the assessee company in the return of income and in fact even the Assessing Officer has mentioned in the assessment order that it has been noticed from Annexure-B to the audit report pertaining to method of accounting employed that valuation of stock in process has been changed from cost plus expenses to estimated realizable value(para 3 page 2).
Section 210 of the Companies Act, 1956 requires the board of directors of a company to place at every annual general meeting, a balance sheet as at the end of the accounting period of company and a profit and loss account for that period. Section 211 of the Companies Act deals with form and contents of balance sheet and profit and loss account. The basic requirement of this section is that the balance sheet of a company shall give a true and fair view of the state of affairs of the company at the end of the financial year and every profit and loss account of a company shall show a true and fair view of the profit or loss of a company at the end of the financial year. The balance sheet as well as profit and loss account are required to be prepared as per Schedule VI to the Companies Act. In order to ensure that both these accounting statements present the state of affairs of the company as per the requirements of the Companies Act, specific provisions have been incorporated in the Companies Act itself. In sub-section (3)(a) to (3)(c) of section 211 inserted by the Companies (Amendment) Act, 1999(with retrospective effect from 31.10.1998), it is provided that the profit and loss account and balance sheet of the company has to comply with the Accounting Standards. As per sub-section (3)(c) 'accounting standards' 9 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
means the standard of accounting recommended by the Institute of Chartered Accountants of India constituted under the Chartered Accountants Act, 1949, as may be prescribed by the Central Government in consultation with the National Advisory Committee on accounting standards established under sub- section (1) of section 210A. The Accounting Standards-2 issued by the Institute of Chartered Accountants of India has been made mandatory in the case of companies. This Accounting Standard deals with valuation of inventories. As per clause 5 of this Accounting Standards-2, inventories should be valued at 'lower of cost or net realizable value'. Therefore, the assessee had no option but to value its closing stock of process stock at 'lower of cost or net realizable value' instead of valuing at cost as in earlier years. Since the change in the method of accounting had been made on account of statutory requirements, it could not be branded as a mala fide change in the method of valuation of closing stock.
Attention is invited to the fact that the Thread Division of the Company had been lying closed since 20th August, 2001 and the Ajmer Vidhyut Vithran Nigam Limited had issued notice for recovery of their dues and in exercise of powers conferred under Rajasthan Land Revenue Act 1956 it attached the entire plant & office of the Thread Division at Raila on 19.10,2001. As the production had stopped the net realizable value of stock of work in process had gone down substantially and the assessee had also furnished a statement showing the working of net realizable value of work in process. (PBP No.15). The learned Assessing Officer while completing the assessment had wrongly worked out the figure of profit as he has not taken into consideration the employee cost. The assessee had duly furnished the working of the losses in manufacturing before the learned CIT(Appeals)-II, Jaipur and attention is invited to PBP No.29. We may also point out that the said plant is still under the control of AVVNL and no production has been done in the said plant since 19.10.2001. Thus, in this case the assessee company had correctly done the valuation by following the Companies Act as well as the accounting standards.
In this case the assessee company had claimed deduction by reducing the value of stock which course of action was not accepted by the Assessing Officer. If there is some decline in the value of stock at the end of the year the same has to be given effect to in the annual accounts and the assessee has claimed such deduction by making complete disclosure in this regard. The Assessing Officer took a different view on such transaction. The 10 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
Hon'ble Supreme Court in the case of CIT vs. Reliance Petro Products (P) Ltd., reported in 322 ITR 158 has held that mere making of a claim, which is not sustainable in law, by itself, will not attract penalty under this section. When the assessee furnishes all the particulars in the return which are not found to be inaccurate it is upto the authorities to accept the claim of the assessee in the return or not, but the penalty cannot be levied.
Reliance in this regard is placed on the decision of Himachal Pradesh High Court in case of CIT vs. HP State Forest Corporation Limited reported in 340 ITR 204. (PBP No.40-41) In the said case the assessee was engaged in the business of extraction of timber and resin from forests. During the course of assessment proceedings it was noticed by the Assessing Officer that the assessee had reduced its closing stock of certain amount on account of deterioration of old stock. The addition was confirmed by the appellate authorities and thereafter the Assessing Officer imposed penalty u/s 271(1)( c) upon the assessee. The appellate tribunal held that no penalty could have been imposed upon the assessee as the assessee had disclosed all material facts and there was no concealment on the part of the assessee. On appeal by the department before the High Court it was held that :
"The word 'inaccurate' as used in the Act would mean something which is not accurate, not exact or not correct. Something which is untrue is inaccurate. The same facts can be given two interpretations. If the interpretation given is plausible, though not accepted by the assessing authority, it cannot be said that the statement of particular is so inaccurate or erroneous as to invite imposition of penalty. True it is, that mens rea is not required to be proved. When mens rea is proved, it shows that the person had an intention of evading payment of tax by illegal means. Merely because a wrong interpretation to the same set of facts is given, it would not mean that the assessee was liable to pay penalty also. One should remember that penalty is, by its very nature, penal and somebody is being punished for an act which is unjustified".
Reliance is also placed on the decision of ITAT, Jodhpur Bench in case of DCIT Bhilwara vs. M/s. RSWM Ltd., Gulabpura.(PBP No.34-39) In the said case the assessee was a public limited company and its shares were listed on stock exchange. On the basis of past experience it adopted a prudent accounting estimate of reducing the value of closing stock of non moving items by 10%, 25% and 50% according to their holding 11 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
period. The Assessing Officer disallowed this claims and initiated penalty proceedings under section 271(1)(c ) of the IT Act and he imposed penalty at 100% of the amount of tax sought to be evaded. The CIT(Appeals) deleted the penalty and held that in respect of under valuation of closing stock the assessee has explained reasons for claiming aging discount in respect of stock which remained unsolved for a period of 90 days or more and also held that penalty under section 271(1)( c) cannot justifiably be levied simply for the reason that additions have been sustained in appeal. Since Assessing Officer has not brought any adverse material on record to prove that the explanation given by the assessee regarding valuation of stock was false or malafide.
After considering the argument of both the parties the Tribunal upheld the deletion of penalty after holding that the assessee made a bonafide claim of placing estimated realizable value of its slow moving articles of closing stock after following a policy of prudent accountancy and has also fully disclosed all relevant particulars along with its detailed explanation which has not been found to be not bonafide. It was also held that the additions sustained in quantum appeal by itself is not sufficient to levy penalty under the provisions of section 271(1)(c ) unless the Assessing Officer proves that the explanation of the assessee was false or malafide.
Reliance is placed on the decision of Delhi High Court in the case of CIT vs. IFCI Limited reported in 328 ITR 611. In the said case the assessee had written off investments in its books of accounts and claimed deduction on account of loss occurred to it. Assessee's claim was disallowed and the Assessing Officer also levied penalty u/s 271(1)( c). The assessee contended that the entire facts were disclosed in the return and it could not be treated as concealment of income. The Commissioner of Appeals affirmed the order of the Assessing Officer but on second appeal the Tribunal held that the assessee had declared the entire material in the return of income and merely because a claim of a deduction on account of loss incurred in the capital field as revenue loss was not allowed, it would not make it liable for penalty for concealment of income or furnishing of inaccurate particulars of such income. It, therefore, deleted the penalty. It was held by the Hon'ble High Court that this was a case where a claim put forth by the assessee as regards the loss was not accepted, but that would not per se tantamount to furnishing of any kind of inaccurate particulars. Thus, there has been no concealment of income or furnishing of inaccurate particulars. The appeal of the Department was dismissed.
12 ITA No.795/JP/2012ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
Reliance is also placed on the decision of Punjab & Haryana High Court in the case of CIT vs. Jagjit Engineering Wroks reported in 275 ITR 239. In the said case it was held that where the assessee had not included the value of rejected goods in his stock due to bonafide mistake no penalty under the provisions of section 271(1)( c) was imposable.
Reliance is also placed on the decision of Hon'ble Gujarat High Court in the case of BTX Chemicals vs. CIT reported in 288 ITR 196. In the said case it was held that where the assessee has claimed double deduction for loss of stock due to fire, once by debiting the same in the P & L account and by also reducing the value of closing stock no penalty under section 271(1)( c) was imposable.'' The ld. AR of the assessee at the end of his arguments requested to confirm the order of the ld. CIT(A).
2.7 We have heard the rival contentions and perused the materials available on record. The assessee had submitted its explanation before the AO at the time of assessment proceedings as well as penalty proceedings.
The assessee has changed the method of valuation of closing stock which will automatically be the opening stock of subsequent year. The assessee had duly disclosed complete particulars regarding change in the method of valuation of stock in process from cost plus expenses to estimated realizable value which was mentioned by the assessee in its annual report of the company and tax audit report that in the Modern Thread Unit, the valuation of stock in process had been changed from cost plus expenses to net realizable value. The valuation of work in process had been done as per AS-2 issued by Institute of Chartered Accountant of India. Further the 13 ITA No.795/JP/2012 ACIT, Circle- 6,Jaipur vs. M/s. Modern Threads (India) Ltd. . .
company had been closed on 20-08-2001 and valuation of stock was done on 31-03-2002. Thus there was no production carried out by the company since 31-03-2002. The ld. DR could not controvert this findings of the ld. CIT(A). The cases relied on by the assessee are squarely applicable to the case of the assessee. Therefore, in view of the above facts and circumstances of the case, we confirm the order of the ld.
CIT(A). Hence, the appeal of the Revenue is dismissed.
3.0 In the result, the appeal of the Revenue is dismissed.
Order pronounced in the open court on 11 /08/2015.
Sd/- Sd/- ¼vkj-ih-rksykuh½ ¼Vh-vkj-ehuk½ (R.P.Tolani) (T.R. Meena) U;kf;d lnL;@Judicial Member ys[kk lnL;@ Accountant Member Tk;iqj@Jaipur fnukad@Dated:- 11 /08/2015 *Mishra
vkns'k dh izfrfyfi vxzfs 'kr@Copy of the order forwarded to:
1. vihykFkhZ@The Appellant- The ACIT, Circle- 6, Jaipur
2. izR;FkhZ@ The Respondent- M/s. Modern Threads (India) Ltd. , Jaipur
3. vk;dj vk;qDr¼vihy½@ CIT(A).
4. vk;dj vk;qDr@ CIT
5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur
6. xkMZ QkbZy@ Guard File (ITA No.795/JP/2012) vkns'kkuqlkj@ By order, lgk;d iathdkj@ Assistant. Registrar