Income Tax Appellate Tribunal - Cochin
M/S.Abad Hotels (India) P. Ltd, Cochin vs The Acit, Cochin on 21 March, 2018
1
IN THE INCOME TAX APPELLATE TRIBUNAL
COCHIN BENCH, COCHIN
BEFORE S/SHRI CHANDRA POOJARI, AM & GEORGE GEORGE K., JM
I.T.A. No.492/Coch/2016
Assessment Year : 2009-10
M/s. Abad Hotels (India) P. Ltd., Vs. The Assistant Commissioner of
M.G. Road, Income-tax, Circle-1(1), Kochi.
Kochi-35.
PAN:AACCA 2659L]
(Assessee-Appellant) (Revenue-Respondent)
Assessee by Shri Radhesh Bhat, CA
Revenue by Shri M.V. Rudran, ADCIT, Sr. DR
Date of hearing 19/03/2018
Date of pronouncement 21/03/2018
ORDER
Per CHANDRA POOJARI, ACCOUNTANT MEMBER:
This appeal filed by the assessee is directed against the order of the CIT(A)-I, Kochi dated 20/09/2016 and pertains to the assessment year 2009-10.
2. The first ground is Ground No. 2 which reads as follows:
2. The ld. CIT(A) erred in confirming the order of the Assessing Officer (AO) and thereby restricting the depreciation on vehicles used by the appellant in the business of running on hire to 15%, instead of 30%. The CIT(A) erred I.T.A. No.492/C/2016 in stating that running vehicles on hire for transportation and catering purposes are integral part of the appellant's core business of hoteliering and restaurant running. The learned CIT(A) erred in not following the decision of the jurisdictional High Court in the case of CIT vs. Dr. KR Jayachandran (212 ITR 637) relied upon by the appellant, wherein the H'ble High Court had held that it is not necessary that running on hire must be the main business of the appellant; it can be incidental to the main business also. The Court also held that higher rate of depreciation should be allowed, even if the rent from hire of vehicles are not charged separately; whereas in the case of appellant, the rent is charged separately.
3. The facts of the issue are that the assessee owns certain vehicles (i.e., Mahindra Logan and Omni Cargo and Tata Ace Pickup), which are running on hire. On such vehicles the assessee claimed higher rate of 30% which is the rate of depreciation applicable for vehicles running on hire, for the reasons given below:
a) Mahindra Logan is used by the assessee to transport tourist guests staying in the Hotel. The income derived from the above activity is grouped under the head 'Travel Assistance and Taxi' and offered to tax.
b) Similarly Omni Cargo and TATA Ace pick up van are used in catering business of the assessee, the income of which is included under the head 'Restaurant income' and offered to tax.
However the Assessing Officer restricted the depreciation on vehicles used by the assessee in the business of running on hire to 15% instead of 30% claimed by the assessee and thereby disallowing the differential depreciation of Rs.73,784/-. 2
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4. On appeal, the CIT(A) confirmed the decision of the Assessing Officer by holding that running of vehicles on hire is integral part of the hotel business of the assessee. The CIT(A) held that so as to claim depreciation @30%, the running of vehicles on hire must be a separate independent business and hence the judgment of the Kerala High Court in the case of CIT vs. Dr. KR Jayachandran (212 ITR 637) was not applicable to the assessee's case.
5. Against this, the assessee is in appeal before us. The Ld. AR submitted that the in the case of Dr. KR Jayachandran (supra), the High Court has held that the condition precedent to grant of depreciation is that the motor care has been used in the business of plying on hire for tourists, which is a separate independent business. It was submitted that it is not necessary that running on hire must be the main business of the appellant and it can be incidental to the main business also. According to the Ld. AR, as per the said decision, there is no requirement to keep separate books to constitute the running of vehicles on hire to be a separate business. The Court also held that there is no bar on the assessee to combine many businesses. Therefore, it was contended that higher rate of depreciation should be allowed, even if the rent from hire of vehicles was not charged separately. In the case of the assessee, it was submitted that the income from running of vehicles on hire is also offered as business income and hence the assessee is eligible for higher rate of depreciation. 3
I.T.A. No.492/C/2016 5.1 The Ld. AR relied on the decision of the Delhi Bench of ITAT in the case of ACIT vs. Hotel Marina (112 ITD 159) wherein it was held that rent for running the vehicles to transporting tourists were not even charged separately. Still, it was submitted that the Tribunal held that the assessee was eligible for higher depreciation, since there was nothing on record to show that the assessee has not used the vehicle for running it on hire. The Ld. AR submitted that the in the case of the assessee the rent for running the vehicles were charged separately. The Ld. AR relied on the decision in the case of CIT vs. Lake Palace Hotels & Motels (P) Ltd. (293 ITR 281)(Raj.). The Ld. AR submitted that the CIT(A) had in assessee's own case accepted the above decisions and allowed the increased depreciation claimed by the assessee for the AY 2007-08 and the same should be allowed in the AY 2009-10 also. Hence, it was submitted that the claim of increased depreciation is to be allowed.
6. The Ld. DR relied on the orders of the lower authorities.
7. We have heard the rival submissions and perused the material on record. A similar issue came up for consideration before the Co-ordinate Bench of this Tribunal in the case of The Baliapatam Tile Works Limited vs. DCIT in ITA No. 147/Coch/2014 dated 04/07/2014 wherein the Tribunal after considering the Judgment of the Jurisdictional High Court in the case of CIT vs. Dr. KR Jayachandran (supra) held as under:
"7. We have heard both the parties and perused the record. In this case, we have come across a co-ordinate bench decision in the case of Mathew 4 I.T.A. No.492/C/2016 Abraham vs. ACIT in I.T.A. No. 92/Coch/2013 vide order dated 16/08/2013 wherein it was held that the assessee being not engaged in the business of running the vehicles on hire, the assessee is not entitled for a higher rate of depreciation on the vehicles used in his own business. The relevant portion of the observation is extracted below for the sake of convenience:
"7. We have heard the rival contentions and carefully perused the record. We notice that the Ld. CIT(A) has examined the work orders issued by the Railways and came to the conclusion that the assessee is not engaged in the business of running of vehicles on hire and hence, not entitled for a higher rate of depreciation. For the sake of convenience, we extract below the relevant observations made by the Ld. CIT(A):
"7. I have carefully, gone through the assessment order, the grounds of appeal and submissions filed by the appellant and also the case laws relied upon by the Authorised Representative for seeking relief on the issue. After a careful consideration of the same, my views on the matter with reasons thereof are as given in subsequent paragraphs.
8. During the course of appeal proceedings, the assessee has filed copies of a few work orders issued by the Railways where the nature of work has been mentioned as "collection and supply of approved quality machine crushed track ballast as per latest revised specification from outside the Railway limit and stacking for measurements at ballast depot in Wadakancheri station yard with all lead and lifts, loading and unloading, conveyance from the place of availability, crossing the track where ever required etc. complete using contractor's labour, vehicle and consumables. (payment by stack measurements without any deduction for voids)"
9. The work order shows that the appellant has to supply material and stock it at Railway site. The assessee has also stated that he is in the business of supplying metal to the railways and public. It is not the case of the assessee 5 I.T.A. No.492/C/2016 that the material owned by Railways was transported from its quarry to the railway ballast. The delivery of goods takes place at the ballast site of Railways, therefore as per Sale of Goods Act also the sale takes place only when the material is handed over to the Railways. In fact it is a case of transportation of the material owned by the appellant and not the material owned by some one else. The vehicles are used as per the requirement ascertained by the appellant himself. The control over the vehicles remains with the appellant. Under these circumstances, it cannot be said that the vehicles were given on hire to Railways or Public. The reliance placed by the appellant on the observations of the Hon'ble Supreme Court that the true test is "the user of the same in the business of the assessee of transportation" is misplaced. What the Hon'ble Supreme Court has said is that the vehicles should be used in the business of transportation of the assessee i.e.. the business of assessee should be transportation. Since in this case the assessee is not in the business of transportation and transportation of metal is just incidental to the business of sale of metal to Railways/Public, the reliance placed by the appellant is not correct. During the appellate proceedings as noted vide order sheet entry dated 26-11-2012, the Council of the appellant stated that no vehicle was given on hire to any party. In view of the above, it is held that assessee is not in the business of running of vehicles on hire".
8. Admitted facts are that the assessee is engaged in the business of selling of metals and the assessee has used his own vehicles for transporting the metals mainly to Railway yard. According to the assessee, the transportation charges are paid separately by the Railways and hence the Vehicles should be considered as run on hire.
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9. The assessee has placed reliance in the case of M/s Stanes Tyre and Rubber Products Ltd (referred supra). We have gone through the said decision and notice that the facts prevailing in that case was not found discussed by Hon'ble Madras High Court. The Hon'ble Madras High Court appear to have mainly decided that the Vans and Three wheelers used as goods vehicles are entitled to higher depreciation if they are used for hire or reward. Hence, in our view, the assessee cannot derive support from the said decision. In the case of Gupta Global Exim (P) Ltd, the Hon'ble Supreme Court in clear terms has observed as under:-
"Under item 2(ii) of heading III, the higher rate of depreciation is admissible on motor trucks used in a business of running them on hire. Therefore, the user of the same in the business of the assessee of transportation is the test.....
In our view, the entire approach of the Commissioner of Income tax (Appeals) was erroneous when he has stated that the transportation income of Rs.12,50,639 by way of running the subject vehicles on hire is an integral part of the appellant's business and its inclusion in the head "Business income" is not disputed by the Assessing officer. In our view, mere inclusion of Rs.12,50,639/- in the total business income is not the determinative factor for deciding whether trucks were used by the assessee during the relevant year in a business of running them on hire. In our view, the Commissioner of Income tax (Appeals) had erred in relying upon the accrual of income as a determinative factor for coming to the conclusion that the trucks were used in a business of running them on hire."
Since the assessee is collecting transport charges from the Railways, it is contended that the assessee is in the business of transportation of goods. However, the Hon'ble Supreme Court in the above cited case, has clearly expressed the view that the mere receipt of transport charges is not determinative factor. Thus the real test is whether the assessee has used the vehicles in the business of running them on hire.
10. In the instant case, the assessee's business is supplying metals obtained from the quarry owned by him. According to the 7 I.T.A. No.492/C/2016 contract entered with Railways, the assessee is required to supply the metals at the place specified in the Contract. Thus, as observed by Ld CIT(A), it is the responsibility of the assessee to transport the metals to the place specified by the Railways. Since the assessee was required to transport the metals to different places, it was advantageous for both the assessee as well as for the Railways to fix a price for the 'metals' and to fix transport charges separately. Hence, the transportation of metals in the vehicles owned by the assessee is part of the business carried on by the assessee, viz., operating a quarry and supplying crushed metals. Hence, we agree with the view expressed by the Ld. CIT(A) that the transportation is incidental to the business of sale of metal to Railways/public. Accordingly, we concur with the view of Ld CIT(A) that the assessee was not engaged in the business of running the vehicles on hire.
11. We notice that a similar view has been expressed by the Hon'ble Madhya Pradesh High Court in the case of Kailash Chand Bagaria Vs. CIT and Another (249 ITR 720). In the said case, the assessee therein was engaged in the business of manufacture and trading in limestone. He also used trucks for transporting limestone and claimed a higher rate of depreciation. The Hon'ble High Court held that the dominant purpose for which the assessee used the trucks has been found to be for his own business and hence the assessee is not entitled to higher rate of depreciation. Similar view was expressed by the Hon'ble Karnataka High Court in the case of Veneer Mills vs. CIT (201 ITR
764). We also notice that CBDT has issued Circular No. 652 dated 14-06-1993 (202 ITR (St.) 55) wherein the CBDT has also expressed similar view. For the sake of convenience, we extract below the Circular No. 652 referred above:
"Circular No. 652, dated 14th June, 1993 To.
All Chief Commissioners of Income-tax/ All Directors-General of Income-tax Sir, Subject: Section 32 of the Income-tax Act, 1961 -Rate of depreciation on motor lorries used in the business of transportation of goods - Regarding.8
I.T.A. No.492/C/2016 Under sub-item 2(ii) of Item No. III of Appendix I to the Income- tax Rules, 1962 higher rate of depreciation is admissible on motor buses, motor lorries and motor taxis used in a business of running them on hire. A question has been raised as to whether, for deriving the benefit of higher depreciation, motor lorries must be hired out to some other person or whether the user of the same in the assessee's business of transportation of goods on hire would suffice.
2. In Board's Circular No. 609, dated 29th July 1991, it was clarified that where a tour operator or travel agent uses motor buses or motor taxies owned by him in providing transportation services to tourists, higher rate of depreciation would be allowed on such vehicles. It is further clarified that higher depreciation will also be admissible on motor lorries used in the assessee's business of transportation of goods on hire. The higher rate of depreciation, however, will not apply if the motor buses, motor lorries, etc. are used in some other non-hiring business of the assessee.
3. This may be brought to the notice of all the officers in your charge."
12. We have already noticed that the assessee is not engaged in the business of running the vehicles on hire. The facts prevailing in the decision rendered by Hon'ble Madhya Pradesh High Court in the case of Kailash Chand Bagaria Vs. CIT and Another (supra) is identical to the facts prevailing in the instant case. Hence, we do not find any infirmity in the decision rendered by the Ld. CIT(A) in holding that the assessee is not entitled for a higher rate of depreciation on the vehicles used in his own business. Accordingly, we confirm his order.
13. In the result, the appeal filed by the assessee is dismissed."
7.1 In view of the order of the Co-ordinate Bench, we are inclined to dismiss Ground No. 2 taken by the assessee.
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8. Ground no. 3 is with regard to disallowance U/S.14A of the IT Act which reads as follows:
The ld. CIT(A) erred in confirming the disallowance made by the Assessing Officer u/s. 14A of the IT Act, r.w.s. 8D in respect of the investments made by the appellant in the shares of Harmonia Ayurveda Health Gardens Pvt. Ltd. The Learned CIT(A) ought to have noted that the appellant had not earned any dividend from the above investments. The Learned CIT(A) omitted to note that provisions of sec. 14A of the IT Act, r.w.r. 8D has not application in appellant's case since the investments made by the appellant were not for the purpose of earning exempt income, but for getting the advantage of synergy of having hotel properties at various tourist locations. The Learned CIT(A) erred on holding that the purpose and mode of making the investments are not relevant while applying the provisions of sec. 14A of the IT Act.
8.1 The facts of the case are that the assessee-company is engaged in the hospitality business and runs hotels and restaurants. Investments in shares are made through the appellant company, being the flagship company in the group.
The assessee made investments in shares of another company called M/s. Harmonia Ayurveda Health Garden Private Limited (hereinafter referred to as 'Harmonia'), running hotels and restaurant at Kovalam. The Learned AO disallowed an amount of Rs. 37,44,015/- u/s. 14A of the IT Act, r.w.r. 8D stating that since the income which shall be derived from the investment will be exempt, corresponding expenses should also be reduced from total expenditure. Though the assessee had not incurred any indirect expenses, the AO applied provisions of Rule 8 D, while arriving at the amount of disallowance. 10
I.T.A. No.492/C/2016 8.2 On appeal, the Learned CIT (A) confirmed the decision of the AO relying on the ratio decision of Bombay HC in the case of Godrej & Boyce Mfg Co. Ltd v. CIT (328 ITR 81) and on the CBDT circular no. 5/2014 dt 11.02.2014. 8.3 Against this, the assessee is in appeal before us. The Ld. AR submitted that the investments made were not meant to earn exempt income. It was submitted that out of the share capital comprising of 15000 shares, the assessee's investment amounts to 14970 shares, i.e., 99.80%, as a result, Harmonia was a subsidiary of the assessee-company. It was submitted that investment in shares of Harmonia were made out of the loan from Axis Bank and the proportionate interest paid towards investment made was Rs.24,22,223/-. According to the Ld.AR the said investment has been classified as 'Trade' Investments, meaning that the investments made were in relation to the business of the assessee. It was submitted that the assessee was to make addition to fixed assets by purchase of all the assets and liabilities of an existing Hotel at Kovalam owned by a company (Harmonia). The Ld. AR submitted that instead of purchasing the fixed assets of Harmonia, so as to reduce the transaction cost, shares of that company (Harmonia) were purchased using loan from Axis Bank. According to the Ld. AR if assets were purchased using the same bank loan, no disallowance could have been made u/s. 14 A of the IT Act. Hence it was submitted that purchase of shares also makes no difference and the 11 I.T.A. No.492/C/2016 assessee had not earned any exempt income from the said investment during the year.
8.4 The Ld. AR relied on the following case laws in support of its stand:
a) No disallowance if there is no exempt income The ITAT Cochin Bench in the case of PTL Enterprises Ltd (ITA No. 200/Coch/2015 held relying on various settled judicial decisions that disallowance u/s 14A cannot exceed exempt income and since there was no exempt income declared and claimed by the said assessee, the disallowance made by AO and sustained by CIT (A) was deleted. The Ld. AR submitted that this case was identical to the assessee's case. It is not disputed that the assessee has not earned exempt income from investments in Harmonia. Hence, it was submitted that the disallowance made is against the settled law and hence requires to be deleted.
b) No disallowance u/s.14 A if the investment made is not meant to earn any exempt income The ITAT Chennai Bench held in the case of L & T Infrastructure Development Projects Ltd. v. ITO (58 Taxmann.com 165 -2015) that expenses and interest attributable to investments made by the assessee in Special Purpose Vehicles (SPV) could not be disallowed u/s.14A r.w.r 12 I.T.A. No.492/C/2016 8D of the IT Act, as it could not be termed as expenses incurred for earning exempt income. It was submitted that in the above case, the assessee had to form a SPV in order to obtain contracts from NHAI and the same was used to execute works awarded by NHAI. The ITAT, Chennai held that in such a circumstance, no disallowance ought to have been made u/s.14 A of the IT Act.
The Ld. AR submitted that similar view was taken by Delhi High Court in the case of CIT v. Oriental Structural Engineers P. Ltd (216 Taxman 92) . The Ld. AR also relied on the decision of Chennai Tribunal in the case of NMS Consultancy P. Ltd .v. Dy. CIT (2013) 22 ITR Trib 400 (Chennai)
c) The intention of making investment is also to be looked into while applying the provisions of sec. 14A r.w.r 8D The Ld. AR relied on the decision in the case of MSA Securities P. Ltd. vs. ACIT (2013) - 58 SOT 44 (URO) Chennai (Trib.) The Ld. AR submitted that in the above decision, the Tribunal held that the intention of the assessee cannot be treated as irrelevant. In the case of assessee, the purpose of making investment was to ensure synergy of having hotel properties in all important tourist destinations in Kerala and the above decisions are applicable. The ld. AR also relied on the on 13 I.T.A. No.492/C/2016 the decision of ITAT Mumbai, in the case of Garware Wall Ropes Ltd v. ACIT (46 Taxmann.com 18), which was relied upon by the Tribunal in MSA Securities case.
d) No disallowance u/s.14 A if the investment made is. a strategic investment in subsidiary.
The Ld. AR submitted that in the case of Cheminvest v. CIT, the Delhi High Court has, relying on the decision of CIT v. Holcim India (P.) Ltd. [2015] 57 taxmann.com 28 (Delhi), held that in the case of an assessee who has made strategic investment in shares of another company and no exempted income was earned by the assessee in the relevant assessment year and the genuineness of the expenditure incurred by the assessee is not in doubt, no disallowance u/s.!4A, r.w.r 8D can be made. The Ld. AR submitted that in the assessee's case, the investment made in shares of Harmonia was a strategic investment and the purpose of making investment was not to earn dividend income and it is an undisputed fact that the appellant has not received any dividend income, hence no disallowance is to be made u/s. 14A r.w.r 8D of the Act. The Ld. AR also relied on the decision of the Mumbai Tribunal in the case of JM Financial Ltd .v. ACIT (Mum.)(Trib.) wherein the Tribunal held that no disallowance shall be made u/s. 14A in respect of strategic investment in the absence of tax free income. 14
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e) No disallowance U/S.14A, r.w.r. 8D in respect of borrowed funds, if the assessee has not received exempt income The Ld. AR relied on the judgment of the Gujarat High Court in the case of CIT v. Corrtech Energy Pvt Ltd (272 CTR 262/223 Taxman 130) where it was held that no disallowance u/s 14A, r.w.r 8D can be made in respect of interest expenditure if the assessee has not earned any exempt income.
The Ld. AR also relied on the decision of the ITAT Chennai Bench in the case of SIVA Industries Holding Ltd v. ACIT (145 TTJ 497) wherein it was held that if the investments made by the assessee had generated any dividend income which had been claimed by the assessee to be not to form part of total income, no disallowance u/s.14A could be made, even towards interest borrowed funds used for making investments. The Ld. AR also relied on the judgment of the P&H High Court in the case of CIT v. M/s. Lakhani Marketing Inc. (272 CTR 265) wherein it was held that unless and until there is receipt of exempted income for concerned assessment years (dividend from shares) section 14A cannot be invoked towards direct expenditure. The Ld. AR also relied on the judgment of the Bombay High Court in the case of CIT v. Delite Enterprises in ITA No. 110/2009 dated 26/02/2009 wherein it was held 15 I.T.A. No.492/C/2016 that in the absence of tax free income, expenditure (including interest) expenditure can be disallowed u/s.14 A of the Act.
f) Applicability of CBDT circular no.5/2014 dt 11.02.2014 relied on bv the CIT(A) The Ld. AR submitted that the bove circular relied upon by the CIT (A) is not binding on the assessee, since the CBDT circular can not override the provisions of sec. 14A of the Act. Hence, it was submitted that in the absence of any tax free income, there is no question of applicability of Sec. 14A r.w.r 8D of the IT Act.
CBDT circular dt 02.05.2016 The Ld. AR submitted that the CBDT circular dt 02.05.2016, which amended Rule 8 D has no application to the assessee's case, relating to AY 2009-10.
The Ld. AR submitted that the decision relied upon by the CIT(A) in the case of Godrej & Boyce Mfg Co. Ltd was rendered in the context of exempt actually earned by the assessee and for the AY 2002-03, i.e., for an year prior to introduction of provision of Rule 8 D. It was submitted that in the case of the assessee, there was no dividend income and hence the said decision was not applicable. Hence it was 16 I.T.A. No.492/C/2016 submitted that following the above decisions, the disallowance is to be deleted.
8.5 The Ld. DR relied on the order of the lower authorities. 8.6 We have heard the rival contentions and perused the material on record. The contention of the assessee is that there is no exempted income earned by the assessee. However it seems from the facts of the case that the assessee incurred direct expenditure on the investments made in exempted income yielding asset. Since the assessee incurred direct expenditure which was identified by the Assessing Officer and it is not disputed by the assessee, in our opinion, Rule 8D(2(i) is directly applicable.
8.7 Further, the Supreme Court in the case of Maxopp Investment Ltd. vs. CIT in Civil Appeal No. 104-109/2015 vide judgment dated 12/2/2018 observed that expenditure incurred in respect of investment in shares of the operating companies for acquiring and retaining controllable interest cannot be allowed. In other words, the dominant purpose for which the investment in shares is made by an assessee is not relevant in determining the allowability of that expenditure and section 14A of the Act has to be interpreted particularly, the word "in relation to the income" that does not form part of the total income. If the expenditure is incurred in making investment which yield exempt income, that 17 I.T.A. No.492/C/2016 much of expenditure which is attributable to that income is to be disallowed and cannot be treated as business expenditure. Further, it was held that the term "expenditure incurred" as recurring in section 14A(i) of the Act means incurring of actual expenditure and not some imagined expenditure. The "actual" expenditure that is in contemplation under section 14A(i) of the Act is the "actual" expenditure in relation to or in connection with or pertaining to exempted income. Hence, if no expenditure is incurred in relation to exempted income, no disallowance can be made under section 14A of the IT Act. It was further observed that only that expenditure which has been incurred in relation to non-taxable income has to be disallowed. If an expenditure incurred has no 'principal connection" with the exempted income, then such an expenditure would clearly be treated as not "in relation to the income which does not form part of the total income", and such expenditure would be allowed as business expenditure.
8.8 In view of the above, in the present case, direct expenditure has been incurred on the investment made in sister concern. Such expenditure has to be 18 I.T.A. No.492/C/2016 disallowed. Hence we do not find any infirmity in the order of the CIT(A) and confirm the same.
9. In the result, the appeal filed by the assessee is dismissed.
Order pronounced in the open Court on this 21st March, 2018.
sd/- sd/-
(GEORGE GEORGE K.) (CHANDRA POOJARI)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Place:
Dated: 21st March, 2018
GJ
Copy to:
1. M/s. Abad Hotels (India) P. Ltd., M.G. Road, Kochi-35.
2. The Assistant Commissioner of Income Tax, Circle-1(1), Kochi.
3. The Commissioner of Income-tax(Appeals)-I, Kochi
4. The Pr. Commissioner of Income-tax, Kochi
5. D.R., I.T.A.T., Cochin Bench, Cochin.
6. Guard File.
By Order (ASSISTANT REGISTRAR) I.T.A.T., Cochin 19