Income Tax Appellate Tribunal - Ahmedabad
Aarvee Denims & Exports Ltd.,, ... vs Assessee
IN THE INCOME TAX APPELLATE TRIBUNAL
AHMEDABAD BENCH "A"
(BEFORE S/SHRI BHAVNESH SAINI AND N S SAINI)
ITA Nos.158 and 159/Ahd/2007
(Assessment Years:-2002-03 and 2003-04)
M/s Aarvee Denims & V/s The Income-tax Officer,
Exports Limited, 188/2, Ward-1(3),
Ranipur Patia, Narol, Ahmedabad
Ahmedabad
[Appellant] [Respondent]
Appellant by :- Shri S N Soparkar, Senior Advocate
Respondent by:- Shri Govind Singhal, Senior DR
ORDER
Per N S Saini (Accountant Member): These two appeals have been filed by the assessee against two separate orders both dated 09-11- 2006 passed by the Learned Commissioner of Income-tax (Appeals)- V, Ahmedabad [the "CIT(A)"] for Assessment Years 2002-03 and 2003-04.
2 Since certain grounds involved in these two appeals are common, they were heard together and are being disposed of by this common order.
3. The grounds of appeals taken by the assessee in both the appeals are as under:
For AY 2002-03:
1. The learned CIT(A) has erred in law and on facts in confirming the action of AO in reopening the assessment proceedings u/s 147 of the Income Tax Act, 1961. Under the facts and circumstances of the case the action of reopening is without jurisdiction and not permissible 2 either in law or on fact. The present proceedings, therefore, are required to be quashed.
2. The learned CIT(A) has erred in law and on facts in confirming the action of AO in disallowing the claim of deduction u/s 80HHC of the Act at Rs.1,62,80,923/- while calculating book profit u/s 115JB of the Act.
3. Both lower authorities have passed the respective orders without properly appreciating the fact and that they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time which ought to have been considered before passing the impugned order.
4. The learned CIT(A) has erred in law and on facts in confirming the action of AO in levying interest u/s 234B and 234C of the Act particularly when the income was assessed u/s 115JB of the Act.
5. The learned CIT(A) has erred in law and on facts in confirming the action of AO in initiating penalty under section 271(1)(c) of the Act without appreciating that the AO has not recorded mandatory satisfaction as contemplated under the Act.
For AY 2003-04:
1. The learned CIT(A) has erred in law and on facts in confirming the action of AO in disallowing the claim of deduction u/s 80HHC of the Act at Rs.7,36,23,341/- while calculating book profit u/s 115JB of the Act.
2. Both lower authorities have passed the respective orders without properly appreciating the fact and that they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time which ought to have been considered before passing the impugned order.
3. The learned CIT(A) has erred in law and on facts in confirming the action of AO in levying interest u/s 234B and 234C of the Act particularly when the income was assessed u/s 115JB of the Act.
4. The learned CIT(A) has erred in law and on facts in confirming the action of AO in initiating penalty under section 271(1)(c) of the Act without appreciating that the AO has not recorded mandatory satisfaction as contemplated under the Act.3
4 At the outset, Ground Nos.1, 3 and 5 in AY 2002-03 and Ground Nos.2 and 4 in Assessment Year 2003-04 were not pressed by the learned counsel for the assessee. Therefore, the same are dismissed, as not pressed.
5 Ground No.2 in Assessment Year 2002-03 and Ground No.1 in Assessment Year 2003-04 relates to disallowance claimed for deduction u/s 80HHC for Rs.1,62,80,923/- in Assessment Year 2002- 03 and Rs.7,36,23,341/- in Assessment Year 2003-04 while computing book profits u/s 115JB of the Income-tax Act, 1961 [the "Act"]. Since the facts and issue are common in both the assessment years, we are considering the facts in Assessment Year 2003-04. The AO as well as the CIT(A) have dealt with the issue in great detail in Assessment Year 2003-04.
6 The brief facts of the case are that the assessee claimed deduction u/s 80HHC of Rs.1,62,80,923/- and Rs.7,36,23,341/- from the book profits computed u/s 115JB. The AO disallowed the claim of deduction to the assessee by observing that the assessee did not submit report in Form No.10CCAC and that the regular income as per the computation of income was NIL and when the gross total income is NIL, the assessee was not entitled for any deduction under Chapter VI including deduction u/s 80HHC. In appeal, the Learned Commissioner of Income-tax (Appeals) confirmed the action of the Learned Assessing Officer.
7 The Learned Authorised Representative of the Assessee argued that the audit report in Form No.10CCAC is not required to be filed by the assessee as gross total income being NIL, deduction u/s 80HHC was not available while computing "Regular Income". It was further argued that CBDT Circular No.680, dated 21 s t February, 4 1994 explaining the Explanation (iii) to section 115J, the relevant portion whereof reads as under:-
"Certain doubts have been expressed as to whether the amount quantified u/s 80HHC(3) or (3A) or section 80HHD(3) itself should be deducted under Explanation (iii) u/s 115J or whether only the manner of computation specified in those sections should be followed to quantify the amount of deduction".
In para 9.3(a) of the Circular, it is elaborated that for the purposes of the subject explanation, the "net profit" to be excluded shall be computed in the same manner as provided in section 80HHC(3) or (3A) or section 80HHD(3). Further, the Explamnation (iii) u/s 115J itself clearly lays dpown that theamount, as arrived at after adjusting the net profit as shown in the profit and loss account for the relevant previous year by the adjustment referred to in clauses
(a) to (f), (i) and (ii) of the said Explanation should be allowed as deduction, computing the deduction however in the manner specified u/s 80HHC(3) or (3A) or section 80HHD(3).
It is therefore clear that it is only the manner of computation specified in section 80HHC(3) or (3A) or 80HHD and not the amounts themselves, that should be imported into Explanation (iii) u/s 115J.
8 The Learned Authorised Representative of the Assessee in support of his contentions has relied upon the decision of the Hon'ble Madras High Court in the case of CIT vs. Rajanikant Schnelder and Associates P. Ltd. (2008) 302 ITR 22 (Mad) wherein it was held that the AO was not entitled to alter the profit and loss account prepared by the assessee under the provisions contained in the Companies Act while arriving at the book profit under section 115JA and the book profit so arrived at should be the basis for 5 taxation and, therefore, the computation under section 80HHC should be limited to the case of profits of eligible category only. The finding arrived at by the Tribunal was correct and in conformity with the decision of the Supreme Court. It was further submitted that the Department's Special Leave Petition was dismissed against this judgment of Hon'ble Madras High Court whereby the Hon'ble High Court following 302 ITR 22 affirmed the view of the Tribunal that the deduction u/s 80HHC in a case of assessment u/s 115JA had to be worked out on the basis of the adjusted book profit and not on the computation of profits and gains of business or profession. [CIT vs. SPEL Semiconductor Ltd. : SLP (C) No.32735 of 2009].
9 The Learned Departmental Representative supported the orders of the lower authorities.
10 We have heard the rival submissions and perused the orders of the lower authorities and the materials available on record. In the instant case the undisputed facts are that the assessee in the normal computation i.e. computation as per the provisions of Income-tax Act,1961, except section 115JB, has gross total income of NIL and therefore the amount deductible u/s 80HHC for that computation is restricted to NIL in view of the provisions of section 80AB of the Act. The assessee is liable to pay tax on its book profits computed under section 115JB of the Act. The assessee has furnished audit report u/s 80HHC of the Act along with the return of income. On the above facts the Learned Assessing Officer disallowed the claim for deduction u/s 80HHC while computing book profit also as in view of the Learned Assessing Officer deduction allowable to the assessee in normal computation u/s 80HHC was NIL. The Learned Commissioner of Income Tax(Appeals) confirmed the action of the Learned Assessing Officer. We find that the 6 Hon'ble Madras High Court in the case of CIT vs. Rajanikant Schnelder and Associates P. Ltd. (2008) 302 ITR 22 (Mad) held in respect of provisions of section 115JA as under:-
"The appeal is filed against the order of the Tribunal, Madras "A" Bench, made in ITA No. 346/Mad/2002, dt. 20th Feb., 2003. The relevant assessment year is 1998-99. The substantial question of law formulated for entertainment of the appeal is as follows:
"Whether, on the facts and circumstances of the case, the Tribunal was right in holding that the assessee having no profits from the export is eligible for the deduction under s. 80HHC on its book profits under s. 115J ?"
2. For the asst. yr. 1998-99, the assessee filed its return. The AO disallowed the claim of the assessee in respect of the deduction under s. 80HHC, on the ground that the book profit income computed under s. 115JA was a negative income. Aggrieved by the order of the AO, the assessee filed an appeal to the CIT(A). The CIT(A) confirmed the assessment order on the ground that the assessee did not have any profit or gain from the business under ss. 28 to 44B of the Act. The CIT (A) held that the book profits will not be eligible for deduction under s. 80HHC of the Act. Aggrieved by the order of the CIT(A), the assessee filed appeal to the Tribunal and the Tribunal allowed the appeal. The correctness of the said order is canvassed in this appeal.
3. We heard the arguments of learned counsel on either side and perused the materials on record.
4. We are not able to subscribe our view to the grounds taken in the appeal that the deduction under s. 80HHC is allowable only on the profits and gains arrived at under ss. 28 to 44B of the IT Act. In the case on hand, it is the stand of the assessee that the relief under s. 80HHC should be based on the profit ascertained under s. 115JA only but not on income computed under ss. 28 to 44 of the Act. The Tribunal after considering the judgments of the Supreme Court in the case of Surana Steels (P) Ltd. vs. Dy. CIT (1999) 153 CTR (SC) 193 : (1999) 237 ITR 777 (SC) and in the case of Apollo Tyres Ltd. vs. CIT (2002) 174 CTR (SC) 521 : (2002) 255 ITR 273 (SC), and analysing the order impugned found that the provisions of s. 115J are 7 similar to the provisions of s. 115JA of the Act. In order to come to the conclusion the Tribunal has also taken note of sub-s. (4) of s. 115JA and referred to the dictum laid down by the Supreme Court in the case of Apollo Tyres Ltd. vs. CIT (supra), wherein it was held that the AO while computing the book profits of a company under s. 115J of the IT Act, 1961, has only the power to examine whether such books of account are certified by the authorities under the Companies Act as having been properly maintained in accordance with the Companies Act. The AO thereafter has the limited power of making increases and reductions as provided for in the Explanation to s. 115J. The AO does not have the jurisdiction to go behind the net profits shown in the P&L a/c except to the extent provided in the Explanation. The use of the words "in accordance with the provisions of Parts II and III of Sch. VI to the Companies Act" in s. 115J was made for the limited purpose of empowering the AO to rely upon the authentic statement of accounts of the company. While so looking into the accounts of the company, the AO has to accept the authenticity of the accounts with reference to the provisions of the Companies Act, which obligate the company to maintain its accounts in a manner provided by that Act and the same to be scrutinised and certified by the statutory auditors and approved by the company in the general meeting and thereafter to be filed before the Registrar of Companies, who has a statutory obligation also to examine and be satisfied that the accounts of the company are maintained in accordance with the requirements of the Companies Act. Sub- s. (1A) of s. 115J does not empower the AO to embark upon a fresh enquiry in regard to the entries made in the books of account of the company.
5. The AO is not entitled to touch the P&L a/c prepared by the assessee as per the provisions contained in the Companies Act, while arriving at the book profit under s. 115J and the book profit so arrived at should be the basis for taxation and therefore the computation under s. 80HHC should be limited to the case of profits of eligible category only. The Tribunal has also come to the conclusion that in view of the non obstante clause available in s. 115JA, it was clear that the provision is a self-contained one and no other provision would have effect on it and thereby it was to be implemented as contained in the said provision. The Tribunal has also further given a reason to the effect that s. 80HHC is clear about this aspect that profit only is to be taken into account but not income and sub-s. (3) of s. 115JA itself took care of the 8 provisions relating to the adjustment of loss or depreciation and carry forward of the income. The finding arrived at by the Tribunal is correct and followed the decision of the Supreme Court. We are of the view that the conclusion arrived at by the Tribunal cannot be complained of."
11 We find that the relevant portion of section 115JA reads as under:-
Explanation : For the purposes of this section, "book profit"
means the net profit as shown in the profit and loss account for the relevant previous year prepared under sub-section (2), as increased by--
(a) the amount of income-tax paid or payable, and the provision therefor; or
(b) the amounts carried to any reserves by whatever name called; or
(c) the amount or amounts set aside to provisions made for meeting liabilities, other than ascertained liabilities; or
(d) the amount by way of provision for losses of subsidiary companies; or
(e) the amount or amounts of dividends paid or proposed; or
(f) the amount or amounts of expenditure relatable to any income to which any of the provisions of Chapter III applies;
[(g) the amount or amounts set aside as provision for diminution in the value of any asset, if any amount referred to in clauses (a) to (g) is debited to the profit and loss account, and as reduced by,--]
(i) the amount withdrawn from any reserves or provisions if any such amount is credited to the profit and loss account :
Provided that, where this section is applicable to an assessee in any previous year (including the relevant previous year), the amount withdrawn from reserves created or provisions made in a previous year relevant to the assessment year commencing on or after the 1st day of April, 1997, 1318b [but 9 ending before the 1st day of April, 2001,] shall not be reduced from the book profit unless the book profit of such year has been increased by those reserves or provisions (out of which the said amount was withdrawn) under this Explanation; or
(ii) the amount of income to which any of the provisions of Chapter III applies, if any such amount is credited to the profit and loss account; or 1318ba [
(iii) the amount of loss brought forward or unabsorbed depreciation, whichever is less as per books of account.
Explanation : For the purposes of this clause,--
(a) the loss shall not include depreciation;
(b) the provisions of this clause shall not apply if the amount of loss brought forward or unabsorbed depreciation, is nil; or]
(iv) the amount of profits derived by an industrial undertaking from the business of generation or generation and distribution of power; or
(v) the amount of profits derived by an industrial undertaking located in an industrially backward State or district as referred to in [sub-section (4) and sub-section (5) of section 80-IB], for the assessment years such industrial undertaking is eligible to claim a deduction of hundred per cent of the [profits and gains under sub-section (4) or sub-section (5) of section 80-IB]; or
(vi) the amount of profits derived by an industrial undertaking from the business of developing, maintaining and operating any infrastrucutre facility [as defined in the Explanation to sub- section (4) of section 80-IA and subject to fulfilling the conditions laid down in that sub-section]; or
(vii) the amount of profits of a sick industrial company for the assessment year commencing from the assessment year relevant to the previous year in which the said company has become a sick industrial company under sub-section (1) of section 17 of the Sick Industrial Companies (Special Provisions) Act, 1985, and ending with the assessment year during which the entire net worth of such company becomes equal to or exceeds the accumulated losses. Explanation : For 10 the purposes of this clause, "net worth" shall have the meaning assigned to it in clause (ga) of sub-section (1) of section 3 of the Sick Industrial Companies (Special Provisions) Act, 1985 (1 of 1986), [or] [(viii) the amount of profits eligible for deduction under section 80HHC, computed under clauses (a), (b) or (c) of sub-
section (3) or sub-section (3A), as the case may be, of that section, and subject to the conditions specified in sub- sections (4) and (4A) of that section;
(ix) the amount of profits eligible for deduction under section 80HHE, computed under sub-section (3) of that section.] 12 The relevant portion of section 115JB reads as under:-
Explanation [1]: For the purposes of this section, "book profit"
means the net profit as shown in the profit and loss account for the relevant previous year prepared under sub-section (2), as increased by--
(a) the amount of income-tax paid or payable, and the provision therefor; or
(b) the amounts carried to any reserves, by whatever name called [, other than a reserve specified under section 33AC ];
or
(c) the amount or amounts set aside to provisions made for meeting liabilities, other than ascertained liabilities; or
(d) the amount by way of provision for losses of subsidiary companies; or
(e) the amount or amounts of dividends paid or proposed; or
(f) the amount or amounts of expenditure relatable to any income to which [ section 10 [other than the provisions contained in clause (38) thereof]] or [* * * *] section 11 or section 12 apply; or]
(g) the amount of depreciation,] [(h) the amount of deferred tax and the provision therefor, [ 11
(i) the amount or amounts set aside as provision for diminution in the value of any asset, if any amount referred to in clauses (a) to (i) is debited to the profit and loss account, and as reduced by,--]
(i) the amount withdrawn from any reserve or provision (excluding a reserve created before the 1st day of April, 1997 otherwise than by way of a debit to the profit and loss account), if any such amount is credited to the profit and loss account:
Provided that where this section is applicable to an assessee in any previous year, the amount withdrawn from reserves created or provisions made in a previous year relevant to the assessment year commencing on or after the 1st day of April, 1997 shall not be reduced from the book profit unless the book profit of such year has been increased by those reserves or provisions (out of which the said amount was withdrawn) under this Explanation or Explanation below second proviso to section 115JA, as the case may be; or]
(ii) the amount of income to which any of the [provisions of [section 10 [other than the provisions contained in clause (38) thereof]]] or [* * * *] section 11 or section 12 apply, if any such amount is credited to the profit and loss account; or.
(iia) the amount of depreciation debited to the profit and loss account (excluding the depreciation on account of revaluation of assets); or (iib) the amount withdrawn from revaluation reserve and credited to the profit and loss account, to the extent it does not exceed the amount of depreciation on account of revaluation of assets referred to in clause (iia); or] [(iii) the amount of loss brought forward or unabsorbed depreciation, whichever is less as per books of account.
Explanation : For the purposes of this clause,--
(a) the loss shall not include depreciation;
12(b) the provisions of this clause shall not apply if the amount of loss brought forward or unabsorbed depreciation, is nil; or]
(iv) the amount of profits eligible for deduction under section 80HHC, computed under clause (a) or clause (b) or clause (c) of sub-section (3) or sub-section (3A), as the case may be, of that section, and subject to the conditions specified in that section; or
(v) the amount of profits eligible for deduction under section 80HHE computed under sub-section (3) or sub- section (3A), as the case may be, of that section, and subject to the conditions specified in that section; or
(vi) the amount of profits eligible for deduction under section 80HHF computed under sub-section (3) of that section, and subject to the conditions specified in that section; or
(vii) the amount of profits of sick industrial company for the assessment year commencing on and from the assessment year relevant to the previous year in which the said company has become a sick industrial company under sub-section (1) of section 17 of the Sick Industrial Companies (Special Provisions) Act, 1985 (1 of 1986), and ending with the assessment year during which the entire net worth of such company becomes equal to or exceeds the accumulated losses.
Explanation : For the purposes of this clause, "net worth"
shall have the meaning assigned to it in clause (ga) of sub- section (1) of section 3 of the Sick Industrial Companies (Special Provisions) Act, 1985 (1 of 1986).
[(viii) the amount of deferred tax, if any such amount is credited to the profit and loss account.]
13 Thus, it is observed that the language employed by the Legislature in section 115JB is exactly the same as is employed in section 115JA of the Act. Thus, in our considered view, the above quoted decision of the Hon'ble Madras High Court is fully applicable in respect of computation of book profit u/s 115JB also. We, 13 therefore, respectfully following the above decision of the Hon'ble Madras High Court, are of the view that for computing deduction under clause (iv) of sec. 115JB the calculations are to be made with reference to the adjusted book profit and not with reference to income assessable under the head "Profits and gains of business or profession". We, therefore, set aside the orders of the lower authorities and remit the matter back to the file of the Learned Assessing Officer for computing deduction admissible under clause
(iv) of Explanation to section 115JB(2) of the Act in light of the discussions made above afresh and thereafter re-compute the book profit and total income of the assessee as per law. The Learned Assessing Officer is also directed to ensure that the conditions of section 80HHC are satisfied in the instant case while computing the deduction allowable to the assessee out of adjusted book profit. The Learned Assessing Officer shall allow reasonable opportunity of hearing to the assessee before completing the assessment afresh. Thus, this ground of appeal of the assessee is allowed for statistical purposes.
14 Ground No.4 of the appeal in Assessment Year 2002-03 and Ground No.3 of the appeal in Assessment Year 2003-04 are directed against the order of the Learned Commissioner of Income-tax (Appeals) confirming the action of the Learned Assessing Officer in levying interest u/s 234B and 234C of the Act when the income was assessed u/s 115JB of the Act.
15 At the time of hearing, the Learned Authorised Representative of the Assessee very fairly conceded that this ground of appeal is covered against the assessee and in favour of the Revenue by the decision of the Third Member of Ahmedabad Bench of Tribunal in the case of Kanel Oil & Export Industries Ltd. vs. JCIT (Asstt.) SR-2, 14 Ahmedabad (2009) 121 ITD 596 (Ahd) (TM), wherein it was held as under:-
"The attention of the Bombay High Court in Snowcem India Ltd. was not drawn to sub-s. (4) of s. 115JA, as has been pointed out by the AM in his dissent. The High Court therefore had no occasion to examine the question whether the decisions of the Karnataka High Court and the Supreme Court in Kwality Biscuits Ltd., rendered in the context of s. 115J which did not have a sub-section similar to sub-s. (4) of s. 115JA would still be applicable as binding precedent in a case which arises under s. 115JA. This aspect has also been highlighted by the learned AM. The argument on behalf of the assessee that the section in its entirety was before the Bombay High Court in Snowcem India Ltd., which includes sub- s. (4) is not sustainable because the sub-section is considered crucial and it is the contention of the Department that it has made all the difference between s. 115J on the one hand and ss. 115JA and 115JB on the other, and therefore, non- advertance to the same makes it impossible for the assessee to rely on the judgment as authority on the interpretation of the sub- section. It is futile to speculate what would have been the decision if sub-s. (4) of s. 115JA had been brought to the notice of the Bombay High Court, but suffice to say, for the present purpose, that the judgment cannot be relied upon by the assessee as being entirely in its favour on all the aspects of s. 115JA or, more particularly, on the interpretation of sub-s. (4) of that section and therefore, it cannot be said that it should be followed in preference to the order of the Special Bench in Ashima Syntex Ltd. It was contended on behalf of the assessee, relying on several authorities, that the effect of the judgments of the Karnataka High Court and the Supreme Court in Kwality Biscuits Ltd. is that there is an inherent impossibility in the companies estimating their book profit for the purpose of paying advance tax because the book profit itself can be ascertained only when the accounts are closed on the last day of the previous year and that was why it was held in the judgments that the provisions relating to advance tax cannot apply to companies which are required to pay tax on book profit (MAT). This argument cannot be considered since such an argument appears to have been already considered and rejected by the Special Bench in Ashima Syntex Ltd. Sitting as Third Member on a dissent, the right course open is to follow the view of the Special Bench, which is binding. The thrust of the difference of opinion between the Members is not so much on the merits 15 of the chargeability of the interest as it is on the question as to whether the order of the Special Bench in Ashima Syntex Ltd. has to be followed or the later judgment of the Bombay High Court in Snowcem India Ltd. has to be followed. On the facts and circumstances of the case, the interest under s. 234B and under s. 234C is leviable for income computed under s. 115JA.--Asstt. CIT vs. Ashima Syntex Ltd. (2009) 120 TTJ (Ahd)(SB) 721 : (2009) 117 ITD 1 (Ahd)(SB) followed; Snowcem India Ltd. vs. Dy. CIT (2009) 221 CTR (Bom) 594 : (2009) 18 DTR (Bom) 58 not followed."
16 Further, it is observed that the Learned Commissioner of Income-tax (Appeals) has followed the decision of the Hon'ble Karnartaka High Court in the case of Jindal Thermal Power Co. Ltd. vs. DCIT reported in 286 ITR 182 (Kar), wherein it was held that -
"Liability for payment of advance tax in respect of income chargeable under s. 115JB arose on the insertion of s. 115JB by Finance Act, 2000, and not only in view of the provisions of s. 115JB(1) as amended by Finance Act, 2002, and, therefore, retrospective amendment of s. 115JB(1) by the Finance Act, 2002 w.e.f. 1st April, 2001, cannot at all be said to be unreasonable, excessive or harsh so as to declare it as unconstitutional; petitioner was liable to pay interest under ss. 234B and 234C for asst. yrs. 2001-02 and 2002-03 even though its income was assessed under s. 115JB."
Therefore, this ground of appeal of the assessee is dismissed.
17 In the result, the appeals of the assessee are partly allowed as above.
Order signed, dated and pronounced in the court on 26-02-2010 Sd/- Sd/-
(BHAVNESH SAINI) (N S SAINI)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Date : 26-02-2010
16
Copy of the order forwarded to :
1. M/s Aarvee Denims & Exports Limited, 188/2, Ranipur Patia, Narol, Ahmedabad
2. The ITO, Ward-1(3), Ahmedabad
3. CIT concerned
4. CIT(A)-V, Ahmedabad
5. The DR, ITAT, Ahmedabad
6. Guard File BY ORDER Deputy Registrar Assistant Registrar ITAT, AHMEDABAD