Haryana State Roads and Bridges Development Corporation Ltd., Panchkula v. DCIT, Panchkula

ITA 1155/CHANDI/2014 | 2008-2009
Pronouncement Date: 25-11-2019 | Result: Partly Allowed

Our System has flagged this appeal as eligible for Vivad Se Vishwas Scheme. If you are party to this appeal, get on a Free Consultation Call with our team of Legal Experts who shall guide you as to how you can save huge Interest and Penalty in VSV Scheme.


Apply Now
        
Try VSV Calculator

Appeal Details

RSA Number 115521514 RSA 2014
Assessee PAN AAACH9435M
Bench Chandigarh
Appeal Number ITA 1155/CHANDI/2014
Duration Of Justice 4 year(s) 10 month(s) 26 day(s)
Appellant Haryana State Roads and Bridges Development Corporation Ltd., Panchkula
Respondent DCIT, Panchkula
Appeal Type Income Tax Appeal
Pronouncement Date 25-11-2019
Appeal Filed By Assessee
Order Result Partly Allowed
Bench Allotted B
Tribunal Order Date 25-11-2019
Date Of Final Hearing 25-11-2019
Next Hearing Date 25-11-2019
Last Hearing Date 14-10-2019
First Hearing Date 26-09-2019
Assessment Year 2008-2009
Appeal Filed On 29-12-2014
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH A CHANDIGARH !' # $ % &' '( BEFORE SHRI SANJAY GARG JUDICIAL MEMBER AND MS. ANNAPURNA GUPTA ACCOUNTANT MEMBER ./ ITA NOS. 1155 & 1156/CHD/2014 / ASSESSMENT YEARS : 2008-09 & 2011-12 HARYANA STATE ROADS AND BRIDGES DEVELOPMENT CORPORATION LIMITED BAY NO. 13-14 SECTOR 2 PANCHKULA THE DCIT CIRCLE PANCHKULA ./PAN NO: AAACH9435M / APPELLANT /RESPONDENT ! /ASSESSEE BY : SHRI HARRY RIKHY ADVOCATE ' ! / REVENUE BY : SHRI CHANDRAJIT SINGH CIT DR # $ % /DATE OF HEARING : 25.11. 2019 &'() % / DATE OF PRONOUNCEMENT : 25.11.2019 ')/ ORDER PER SANJAY GARG JUDICIAL MEMBER: THE PRESENT APPEALS HAVE BEEN PREFERRED BY THE ASSE SSEE FOR DIFFERENT ASSESSMENT YEARS AGAINST THE SEPARATE ORD ERS DATED 22.10.2014 & 14.11.2014 RESPECTIVELY OF THE COMMISSIONER OF IN COME TAX (APPEALS) PANCHKULA [HEREINAFTER REFERRED TO AS CIT(A)]. 2. BOTH THE APPEALS PERTAINING TO THE SAME ASSESSEE HAVING IDENTICAL ISSUES WERE HEARD TOGETHER AND ARE BEING DISPOSED OF BY THIS COMMON ORDER. ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 2 3. FIRST WE SHALL DEAL WITH THE APPEAL OF THE ASSES SEE FOR ASSESSMENT YEAR 2008-09 IN ITA NO. 1155/CHD/2019 WHEREIN FOL LOWING GROUNDS HAVE BEEN TAKEN BY THE ASSESSEE. :- ITA NO. 1155/CHD/2019 1. THAT THE ORDER OF THE LD. COMMISSIONER OF INCOME TA X (APPEALS) PANCHKULA IS DEFECTIVE BOTH IN LAW AND FACTS OF THE CASE. 2. THAT NO REASONABLE & PROPER OPPORTUNITY HAS BEEN GR ANTED BY THE LD. ASSESSING OFFICER TO APPELLANT TO REPRESENT ITS CASE DURING ASSESSMENT PROCEEDINGS AND REMAND REPORT PROCEEDING S THEREBY VIOLATING THE PROVISIONS OF EQUITY AND NATURAL JUST ICE. 3. THAT THE LD. COMMISSIONER OF INCOME TAX (APPEAL S) PANCHKULA IS NOT JUSTIFIED IN UPHOLDING THE ORDER OF LD. ASSESSI NG OFFICER WHICH HAS BEEN FRAMED U/S 143(3) OF THE I.T. ACT 1961 ON THE BASIS OF THE ORIGINAL INCOME TAX RETURN FILED AND IGNORING THE R EVISED RETURN/COMPUTATION OF INCOME DULY AUDITED BY STATUT ORY AUDITOR ACCORDING TO REGULAR BOOKS MAINTAINED. THIS IS UNCA LLED FOR AND AGAINST THE PROVISIONS OF LAW. 4. THAT THE LD. COMMISSIONER OF INCOME TAX (APPEAL S) PANCHKULA IS NOT JUSTIFIED IN UPHOLDING THE FOLLOWING ADDITIONS MADE BY THE LD. ASSESSING OFFICER: (I) RS.38 53 293/- ON ACCOUNT OF DIFFERENCE IN GROS S RECEIPTS. (II) RS.64 10 647/- ON ACCOUNT OF EXCESS CLAIM OF E XPENSES. (III) RS.61 117/- ON ACCOUNT OF EXCESS CLAIM OF DEP RECIATION. (IV) RS.3 97 935/- ON ACCOUNT OF EXCESS CLAIM OF TR AVELLING EXPENSES. (V) RS.7 59 612/- ON ACCOUNT OF EXCESS CLAIM OF ADV ERTISEMENT EXPENSES. (VI) RS.37 349/- ON ACCOUNT OF EXCESS CLAIM OF STAF F WELFARE EXPENSES. THE ABOVE SAID ADDITIONS HAVE BEEN MADE ON ACCOUNT OF DIFFERENCE BETWEEN THE ORIGINAL RETURN OF INCOME AND THE PROFI T & LOSS ACCOUNT/COMPUTATION OF INCOME DULY AUDITED BY STA TUTORY AUDITOR S . H O WEVER THE LD. ASSESSING OFFICER HAS IGNORED ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 3 THE FIGURES AS SHOWN IN THE STATUTORY AUDITED BALAN CE SHEET AND THE DIFFERENCE IS DUE TO THE REASON THAT WHILE FINALLY AUDITING THE ACCOUNTS THE AUDITORS CHANGED THE HEADS AS COMPARED TO UN- AUDITED ACCOUNTS WHICH ARE SUPPORTED WITH RECONCILI ATION STATEMENTS. THESE ADDITIONS ARE UNCALLED FOR AS THE LD ASSESSING OFFICER HAS ADOPTED THE PICK AND CHOOSE METHOD OUT OF HIS OWN WHIMS AND FANCIES WITHOUT POINTING OUT ANY SPECIFIC DEFECTS IN THE SAID EXPENSES WHICH ARE TOTALLY GENUINE. 5. THAT THE LD. COMMISSIONER OF INCOME TAX (APPEALS ) PANCHKULA IS NOT JUSTIFIED IN UPHOLDING THE DISALLOWANCE OF RS. 96 91 000/- MADE BY THE LD. ASSESSING OFFICER ON ACCOUNT OF GUARANTE E FEES PAID BY TREATING IT AS CAPITAL EXPENDITURE AS THE SAID EXPE NDITURE IS PURELY REVENUE IN NATURE AND CORRECTLY CLAIMED IN ITS P&L ACCOUNT AND HAS BEEN INCURRED IN THE INTEREST OF BUSINESS. 6. THAT THE LD. COMMISSIONER OF INCOME TAX (APPEALS ) PANCHKULA IS NOT JUSTIFIED IN UPHOLDING THE DISALLOWANCE OF RS.4 80 851/- MADE BY LD. ASSESSING OFFICER U/S 40(A)(IA) OF I.T. ACT 1961. THIS ADDITION IS UNCALLED FOR AND DESERVES TO BE DELETED . 7. THAT THE LD. COMMISSIONER OF INCOME TAX (APPEALS ) PANCHKULA IS NOT JUSTIFIED IN UPHOLDING THE ORDER OF THE LD. ASS ESSING OFFICER IN WHICH HE HAS TAKEN THE NET LOSS OF RS. 9 84 53 811/ - INSTEAD OF LOSS OF RS.38 52 12 694/- AS SHOWN IN THE COMPUTATION OF INCOME FILED ON 29-09-08 WHILE COMPUTING THE NET LOSS AS PER INC OME TAX RETURN IN THE ASSESSMENT ORDER. THAT ANY OTHER GROUND WHICH MAY BE TAKEN WITH THE P ERMISSION OF THE HON'BLE TRIBUNAL AT THE TIME OF HEARING. 4. GROUND NO.5 : SO FAR AS GROUND NO.5 IS CONCERNED BOTH THE LD. REPRESENTATIVES OF THE PARTIES HAVE SUBMITTED THAT THE ISSUE RAISED VIDE GROUND NO.5 RELATING TO DISALLOWANCE OF RS. 96 91 000/- MADE BY THE ASSESSING OFFICER ON ACCOUNT OF GUARANTEE FEE TREAT ED AS CAPITAL EXPENDITURE HAS BEEN SETTLED BY THE HON'BLE HIGH C OURT IN FAVOUR OF THE ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 4 ASSESSEE IN THE OWN CASE OF THE ASSESSEE OF ASSESSM ENT YEAR 2010-11 VIDE ORDER DATED 29.9.2016 PASSED IN ITA NO. 85/20 16 (O&M) REPORTED IN [2016] 288 ITR 253 (P&H) WHEREBY THE HON'BLE H IGH COURT HAS HELD THAT THE GUARANTEE FEE CAN BE ALLOWED AS DEDUCTION U/S 37 OF THE I.T. ACT. GROUND NO.5 IS ACCORDINGLY ALLOWED IN FAVOUR O F THE ASSESSEE. 5. GROUND NO.6 : AS FAR AS THIS GROUND IS CONCERNED THE LD. COUNS EL FOR THE ASSESSEE HAS STATED AT BAR THAT AS PER THE INSTRUCTIONS OF HIS CLIENT HE DOES NOT PRESS GROUND NO.6 OF THE APPEAL . A NOTE TO THIS EFFECT HAS ALSO BEEN APPENDED IN THE GROUNDS OF APPEAL ITS ELF. ACCORDINGLY THIS GROUND IS DISMISSED AS NOT PRESSED. 6. GROUND NOS. 1 TO 4 : SO FAR AS THE ISSUE RAISED VIDE GROUND NOS. 1 TO 4 IS CONCERNED THE SAME PERTAIN TO VARIOUS DISA LLOWANCES MADE BY THE ASSESSING OFFICER AS DETAILED IN GROUND NO.4 OF THE OF APPEAL. THE LD. COUNSEL FOR THE ASSESSEE HAS SUBMITTED THAT THESE D ISALLOWANCE HAVE BEEN MADE BY THE ASSESSING OFFICER ON ACCOUNT OF CERTAIN DIFFERENCE IN FIGURES IN TWO AUDIT REPORTS SUBMITTED BY THE ASSES SEE I.E. ONE FILED ALONG WITH INCOME TAX RETURN AND THE OTHER STATUTOR Y AUDIT REPORT SUBMITTED DURING THE ASSESSMENT PROCEEDINGS. THE LD. COUNSEL HAS FURTHER INVITED OUR ATTENTION TO THE PLEA RAISED IN GROUND NO.4 WHEREBY IT HAS BEEN EXPLAINED THAT THE STATUTORY AUDITOR HA D CHANGED CERTAIN HEADS OF THE EXPENSES DUE TO WHICH THERE WAS MISMAT CH OF FIGURES. THE LD. COUNSEL IN THIS RESPECT HAS SUBMITTED THAT THE ASSESSING OFFICER TOOK UP THE FIGURES WHEREBY THE ALLOWANCES / DEDUCT IONS CLAIMED BY THE ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 5 ASSESSEE IN THE ORIGINAL RETURN OF INCOME GET REDUC ED. HOWEVER WHILE DOING SO HE DID NOT GIVE BENEFIT TO THE ASSESSEE I N RESPECT OF HEADS UNDER WHICH THE DEDUCTION / ALLOWANCE CLAIMED BY TH E ASSESSEE ACCORDINGLY WERE INCREASED. THE LD. COUNSEL FURTH ER SUBMITTED THAT IN FACT THE AUDIT REPORT ATTACHED BY THE ASSESSEE WIT H THE INCOME TAX RETURN WAS A PROVISIONAL REPORT WHEREAS THE STATUTORY AU DIT REPORT PRODUCED DURING THE ASSESSMENT PROCEEDINGS WAS DELAYED DUE T O LATE APPOINTMENT OF THE STATUTORY AUDITOR BY THE OFFICE OF CHIEF COM PTROLLER AND AUDITOR GENERAL OF INDIA. THE LD. CIT(A) HOWEVER DID NOT ADMIT THE CLAIM OF THE ASSESSEE OBSERVING THAT THE AUDIT REPORT WAS DU LY FILED BY ONE D.V. CHAWLA & CO . AND THEREFORE THERE WAS NO QUESTION OF TWO AUDIT REPORTS FILED BY THE ASSESSEE. MAY IT BE SO IN THAT EVENT ASSESSING OFFICER SHOULD HAVE GONE THROUGH THE REPORT OF THE SAID AUD ITOR D.V. CHAWLA & CO. AND EXAMINED THE CORRECTNESS OF THE SAME VIS- -VIS THE FACTS OF THE CASE. THERE WAS NO QUESTION OF MAKING DISALLOWANCE ON THE BASIS OF THE SECOND REPORT WITHOUT GIVING FULL CREDENCE TO THE S AME. EVEN IF THE CREDENCE HAS TO BE GIVEN TO THE SECOND REPORT IT W AS INCUMBENT UPON THE LOWER AUTHORITIES TO ALSO CONSIDER THE RELEVANT SUB MISSIONS OF THE ASSESSEE REGARDING THE MISMATCH / DISCREPANCY IN TH E FIGURES. IT IS NOT JUSTIFIED ON THE PART OF THE LOWER AUTHORITIES TO S AY THAT ON THE FIRST HAND THAT NO CREDENCE CAN BE GIVEN TO THE SECOND REPORT AND THEN TO RELY UPON THE SAME REPORT TO FIND FAULT IN THE FIRST REPORT ON ACCOUNT OF MISMATCH OF FIGURES WITH THE SECOND REPORT. ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 6 IN VIEW OF THIS THE MATTER IS REQUIRED TO BE FACTU ALLY LOOKED INTO BY THE ASSESSING OFFICER. WE ACCORDINGLY RESTORE THIS ISSUE RAISED VIDE GROUND NOS.1 TO 4 RAISED BY THE ASSESSEE TO THE FIL E OF THE ASSESSING OFFICER TO LOOK IN THE FACTUAL ASPECTS OF THE CASE CONSIDER THE CONTENTIONS RAISED BY THE ASSESSEE AND DECIDE THE I SSUE AFRESH. IF THE ASSESSEE EXPLAINS THE MISMATCH OF THE FIGURES THE ASSESSING OFFICER WILL CONSIDER THE SAME VIS-A-VIS FACTS OF THE CASE AND A CCORDINGLY DECIDE THE ISSUE IN ACCORDANCE LAW. 7. GROUND NO.7 : SO FAR AS GROUND NO. 7 IS CONCERNED BOTH THE LD . REPRESENTATIVES OF THE PARTIES HAVE SUBMITTED THAT THIS ISSUE IS ALSO REQUIRED TO BE RESTORED TO THE FILE OF THE ASSESSIN G OFFICER AS THE ASSESSING OFFICER IS REQUIRED TO EXAMINE THE FACTUA L ASPECTS RELATING TO THE RETURNED LOSS AS COMPARED TO THE BOOK LOSS. THE PLEA OF THE LD. COUNSEL FOR THE ASSESSEE HAS BEEN THAT THE ASSESSIN G OFFICER IS REQUIRED TO CONSIDER THE LOSS AS PER THE RETURN OF INCOME BE CAUSE THE BOOKS ARE PREPARED AS PER THE COMPANIES ACT WHEREAS FOR THE PURPOSE OF CLAIMING THE LOSS AS PER INCOME TAX ACT THE RETURN OF INCOM E IS TO BE SEEN. IN VIEW OF THIS THIS ISSUE IS ALSO RESTORED TO THE FILE OF THE ASSESSING OFFICER FOR DECISION AFRESH AFTER EXAMINI NG THE FACTUAL DETAILS AS POINTED OUT BY THE LD. COUNSEL FOR THE ASSESSEE. THE APPEAL OF THE ASSESSEE IS ACCORDINGLY TREATED A S PARTLY ALLOWED FOR STATISTICAL PURPOSES. ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 7 ITA NO. 1156/CHD/2014 (A.Y.2011-12) 8. IN THIS APPEAL THE ASSESSEE HAS TAKEN FOLLOWING GROUNDS OF APPEAL:- 1. THAT THE ORDER OF THE LD. COMMISSIONER OF INCOME TA X (APPEALS) PANCHKULA IS DEFECTIVE BOTH IN LAW AND F ACTS OF THE CASE. 2. THAT THE LD. COMMISSIONER OF INCOME TAX (APPEALS) PANCHKULA IS NOT JUSTIFIED IN UPHOLDING THE ADDITIO N OF RS. 10 62 222/- MADE BY THE LD. ASSESSING OFFICER U/S 4 1(L)(A) OF THE I.T. ACT 1961 AS IT IS NOT AN INCOME AND BASIC ALLY THE SALES TAX DEDUCTED FROM THE AMOUNT OF CONTRACTORS W HICH HAS BEEN DULY DEPOSITED AFTER 30-9-2011 IN GOVERNMENT T REASURY. THE DELAY IN DEPOSITING WAS DUE TO ADMINISTRATIVE R EASON AND AS THE AMOUNT DEDUCTED AS SALES TAX HAS ALREADY BEE N DEPOSITED IT CANNOT BE TREATED AS INCOME U/S 41(L) (A) OF THE I.T. ACT 1961 AND IS UNCALLED FOR. 3. THAT THE LD. COMMISSIONER OF INCOME TAX (APPEALS) PANCHKULA IS UNJUSTIFIED IN NOT ALLOWING THE CLAIM OF DEDUCTION U/S 80IA OF THE I.T. ACT 1961 AS THE APP ELLANT DULY FULFILS THE NECESSARY CONDITIONS LAID UNDER THE ACT . 4. THAT ANY OTHER GROUND WHICH MAY BE TAKEN WITH THE H ON'BLE TRIBUNAL AT THE TIME OF HEARING 9. GROUND NOS. 1 & 4: THESE GROUNDS ARE NOT PRESSED BY THE LD. COUNSEL FOR THE ASSESSEE HENCE THESE ARE DISMISSE D AS NOT PRESSED. 10. GROUND NO.2: THE ASSESSEE VIDE GROUND NO.2 HAS RAISED THE ISSUE RELATING TO DISALLOWANCE MADE BY THE ASSESSING OFFI CER U/S 41 (1)(A) OF THE INCOME TAX ACT 1961 (IN SHORT 'THE ACT') ON AC COUNT OF CESSATION OF LIABILITY. 11. THE ASSESSING OFFICER OBSERVED FROM THE ACCOUNT OF THE ASSESSEE THAT THE ASSESSEE HAD DEDUCTED SALES TAX PAYMENT M ADE TO THE CONTRACTOR HOWEVER THE SAME WAS NOT DEPOSITED IN THE GOVERNMENT ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 8 TREASURY. HE ACCORDINGLY TREATED THIS AMOUNT OF RS. 10 62 222/- AS INCOME OF THE ASSESSEE. THE LD. CIT(A) CONFIRMED TH E ADDITION SO MADE BY THE ASSESSING OFFICER. 12. THE LD. COUNSEL FOR THE ASSESSEE HAS SUBMITTED BEFORE US THAT OUT OF THE TOTAL AMOUNT OF RS. 10 62 222/- THE ASSESSE E HAS ALREADY DEPOSITED THE AMOUNT OF RS. 7 80 525/- IN THE GOVER NMENT TREASURY ON 6.2.2012 HENCE THE SAID AMOUNT CANNOT BE TREATED AS INCOME OF THE ASSESSEE. THAT THE BALANCE AMOUNT OF RS. 2 81 697/- HAS ALREADY BEEN TREATED AS INCOME BY THE ASSESSEE IN ITS INCOME TAX RETURN FOR THE ASSESSMENT YEAR 2014-15. THE LD. COUNSEL HAS SUBMI TTED THAT THESE WERE GOVERNMENT DUES HENCE THERE WAS NO CESSATION OF LIABILITY. THE LD. COUNSEL HAS THEREFORE SUBMITTED THAT THE ISSU E MAY BE SENT TO THE ASSESSING OFFICER FOR FACTUAL EXAMINATION. 13. THE LD. DR ON THE OTHER HAND HAS RELIED ON T HE FINDINGS OF THE LOWER AUTHORITIES. 14. CONSIDERING THE RIVAL CONTENTIONS WE ARE OF TH E VIEW THAT THE ISSUE REQUIRES FACTUAL EXAMINATION AT THE HANDS OF THE ASSESSING OFFICER. IF THE ASSESSEE HAS ALREADY DEPOSITED THE AMOUNT O F SALES TAX DEDUCTED AND FURTHER THE BALANCE IS SHOWN AS ITS INCOME I N THE SUBSEQUENT YEAR THEN THERE IS NO QUESTION OF MAKING THE ADDITION ON ACCOUNT OF CESSATION OF LIABILITY U/S 41(1)(A) OF THE ACT. THE ASSESSIN G OFFICER WILL FACTUALLY ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 9 EXAMINE IT AND IF CONTENTION OF THE ASSESSEE IS FO UND CORRECT THEN NO ADDITION WILL BE WARRANTED ON THIS ISSUE. 15. GROUND NO. 3 : SO FAR AS GROUND NO. 3 IS CONCERNED THE LD. COUNSEL FOR THE ASSESSEE HAS STATED AT BAR THAT SIN CE THE ASSESSEE IS RUNNING INTO LOSSES HENCE THERE WAS NO QUESTION O F CLAIMING ANY DEDUCTION U/S 80IA OF THE ACT. HOWEVER THE ASSESS ING OFFICER WRONGLY ADOPTED THE BROUGHT FORWARD FIGURE AND HAS SHOWN TH E POSITIVE INCOME OF THE ASSESSEE. THE LD. COUNSEL HAS SUBMITTED THAT THE ISSUE REQUIRES FACTUAL EXAMINATION BY THE ASSESSING OFFICER. ACCORDINGLY GROUND NO.3 IS ALSO RESTORED TO THE FI LE OF THE ASSESSING OFFICER TO EXAMINE AS TO WHETHER THERE IS ANY POSITIVE INCOME OF THE ASSESSEE IF FOUND SO THE ASSESSING OFFICER WILL CONSIDER THE CLAIM OF THE ASSESSEE OF DEDUCTION U/S 80IA OF THE ACT. IN VIEW OF THE FINDINGS GIVEN ABOVE THIS APPEAL OF THE ASSESSEE IS TREATED AS PARTLY ALLOWED FOR STATISTICAL PURPOSES. ORDER DICTATED AND PRONOUNCED IN THE OPEN COURT IMM EDIATELY ON COMPLETION OF HEARING ON 25.11.2019. SD/- SD/- ( # $ % &' / ANNAPURNA GUPTA) '( / ACCOUNTANT MEMBER ( / SANJAY GARG) / JUDICIAL MEMBER DATED : 25.11.2019 .. '+ - .- / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT 3. # / / CIT 4. # / ( )/ THE CIT(A) ITA NOS. 1155 & 1156/CHD/2014- HARYANA STATE ROADS & BRIDGES DEVP CORPORATION LTD . PANCHKULA 10 5. -01 2 % 2 34516 / DR ITAT CHANDIGARH 6. 15 7$ / GUARD FILE '+ # / BY ORDER 8 ' / ASSISTANT REGISTRAR