Geo Tech Construction Company Pvt Ltd, Cochin v. ACIT, Cochin

ITA 14/COCH/2014 | 2005-2006
Pronouncement Date: 31-07-2014

Appeal Details

RSA Number 1421914 RSA 2014
Assessee PAN AABCG1931A
Bench Cochin
Appeal Number ITA 14/COCH/2014
Duration Of Justice 6 month(s) 10 day(s)
Appellant Geo Tech Construction Company Pvt Ltd, Cochin
Respondent ACIT, Cochin
Appeal Type Income Tax Appeal
Pronouncement Date 31-07-2014
Appeal Filed By Assessee
Bench Allotted DB
Tribunal Order Date 31-07-2014
Date Of Final Hearing 16-07-2014
Next Hearing Date 16-07-2014
Assessment Year 2005-2006
Appeal Filed On 20-01-2014
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH COCHIN BEFORE S/SHRI N.R.S.GANESAN JM AND CHANDRA POOJ ARI AM I.T.A. NO. 14/COCH/2014 ASSESSMENT YEAR : 2005-06 GEO TECH CONSTRUCTION CO. PVT. LTD. 8 TH FLOOR KSHB BUILDING PANAMPILLY NAGAR COCHIN-36 [PAN:AABCG 1931A] VS. THE ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE-1(2) KOCHI. (ASSESSEE -APPELLANT) (REVENUE-RESPONDEN T) ASSESSEE BY SHRI A.S. NARAYANAMOORTHY CA ASSESSEE BY SMT. LATHA V. KUMAR JR. DR DATE OF HEARING 16/07/2014 DATE OF PRONOUNCEMENT 31/07/2014 O R D E R PER CHANDRA POOJARI ACCOUNTANT MEMBER: THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAI NST THE ORDER DATED 27- 11-2013 PASSED BY THE LD. CIT(A)-II KOCHI FOR THE ASSESSMENT YEAR 2005-06. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E IS ENGAGED IN THE BUSINESS OF UNDERTAKING AND EXECUTING CIVIL CONTRAC TS. THE ASSESSING OFFICER COMPLETED THE ASSESSMENT VIDE HIS ORDER U/S. 143(3) R.W.S. 148 OF THE I.T. ACT DATED 29-12-2010 AT A TOTAL INCOME OF RS. 3 28 64 6 90/-. THE ASSESSING OFFICER MADE VARIOUS ADDITIONS/ALLOWANCES. I.T.A. NO.14 /COCH/2014 2 3. ON APPEAL THE CIT(A) CONFIRMED THE RE-OPENING O F THE ASSESSMENT. FURTHER HE DELETED THE ADDITION MADE ON ACCOUNT OF CONTRACT INCOME OF RS. 4 96 79 000/- BY TAKING THE CUMULATIVE WORK AS INCO ME OF THE ASSESSEE. ON THE OTHER HAND HE CONFIRMED THE ADDITION OF RS. 5 05 0 16/- RELATED TO INTEREST ON DIVERSION OF FUNDS TO SISTER CONCERN AND ALSO DISAL LOWANCE OF EXPENDITURE OF RS. 4 96 274/- ON TEMPORARY STRUCTURES. AGAINST THIS THE ASSESSEE IS IN APPEAL BEFORE US. 4. THE LD. AR SUBMITTED THAT THE RE-OPENING OF ASSE SSMENT IS BAD IN LAW AS THIS IS ONLY A CHANGE OF OPINION. HE RELIED ON THE DECISION OF THE SUPREME COURT IN THE CASE OF CIT VS. KELVINATOR OF INDIA LTD. (32 0 ITR 561) AND ALSO FOLLOWING JUDGMENTS: (I) HEAVY METAL AND TUBES LTD. VS. DCIT (364 ITR 6 09) (GUJ.) (II) CIT VS. EICHER LTD. (294 ITR 310) (DEL ) (III) ACIT VS. HOTEL BLUE MOON (321 ITR 36 2) (SC) HE ALSO SUBMITTED THAT NO PROPER NOTICE U/S. 143(2) WAS ISSUED TO THE ASSESSEE. 5. ON THE OTHER HAND THE LD. DR RELIED ON THE ORDE R OF THE CIT(A) AND ALSO ON THE JUDGMENTS OF THE SUPREME COURT IN THE CASE O F SWARAG CEMENT LTD VS. CIT (325 ITR 422) (SC) AND IN THE CASE OF ESS ESS K AY ENGG. CO. (P) LTD. VS. CIT (124 TAXMAN 491) & (247 ITR 818) (SC) WHEREIN IT WA S HELD THAT MERELY BECAUSE THE CASE OF THE ASSESSEE WAS ACCEPTED AS CO RRECT IN THE ORIGINAL ASSESSMENT FOR AN ASSESSMENT YEAR THE ITO IS NOT P RECLUDED FROM RE-OPENING I.T.A. NO.14 /COCH/2014 3 THE ASSESSMENT OF AN EARLIER YEAR ON THE BASIS OF H IS FINDING OF FACT MADE ON THE BASIS OF FRESH MATERIAL IN THE COURSE OF ASSESSMENT OF NEXT ASSESSMENT YEAR. FURTHER HE RELIED ON THE JUDGMENT OF SUPREME COURT IN THE CASE OF CIT VS. SAURASHTRA CEMENT LTD. (192 TAXMAN 300) AND ON THE DECISION OF THE DELHI HIGH COURT IN THE CASE OF CONSOLIDATED PHOTO & FINVEST L TD. VS. ACIT (281 ITR 394). FURTHER THE LD. DR SUBMITTED THAT VALID NOTICE UND ER SECTION 148 WAS ISSUED TO THE ASSESSEE AND MENTIONING OF DATE OF FILING THE R ETURN IN THE NOTICE DATED 06- 05-2010 IS NOT A TYPING ERROR. FINALLY SHE RELIED ON THE JUDGMENT OF THE DELHI HIGH COURT IN THE CASE OF CONSOLIDATED PHOTO & FINV EST LTD. VS. ACI (281 ITR 394) WHEREIN IT WAS HELD AS UNDER: HELD DISMISSING THE PETITION (I) THAT THE PROVIS O TO SECTION 147 ENVISAGES ACTION IN THE ORDINARY COURSE WITHIN A PERIOD OF FO UR YEARS FROM THE END OF THE RELEVANT ASSESSMENT YEAR. HOWEVER THAT LIMITATION DOES NOT APPLY TO CASES WHERE INCOME CHARGEABLE TO TAX HAS ESCAPED ASSESSME NT ON ACCOUNT INTER ALIA OF THE FAILURE OF THE ASSESSEE TO DISCLOSE FU LLY AND TRULY ALL MATERIAL FACTS. PRODUCTION OF THE BOOKS OF ACCOUNTS AND OTHER DOCUM ENTARY EVIDENCE RELEVANT FOR ASSESSMENT DID NOT IMPLY A FULL AND TR UE DISCLOSURE IN THE LIGHT OF EXPLANATION 1 TO SECTION 147. THEREFORE THE ACTION INITIATED BY THE ASSESSING OFFICER DID NOT SUFFER FROM ANY ERROR OF JURISDICTI ON TO WARRANT INTERFERENCE FROM THE COURT. (II) THAT THE ORDER PASSED BY THE ASSESSING OFFICER INDICATED THE BASIS ON WHICH INCOME EXIGIBLE TO TAX HAD IN HIS OPINION ESC APED ASSESSMENT. THE OFFICER PROPOSED TO EXAMINE IN THE COURSE OF REASSE SSMENT PROCEEDINGS. THERE MAY BE A PRESUMPTION THAT THE ASSESSMENT PROC EEDINGS HAD BEEN REGULARLY CONDUCTED BUT THERE COULD BE NO PRESUMPTI ON THAT EVEN WHEN THE ORDER OF ASSESSMENT WAS SILENT ALL POSSIBLE ANGLES AND ASPECTS OF A CONTROVERSY HAD BEEN EXAMINED AND DETERMINED BY THE ASSESSING OFFICER. THE PRINCIPLE THAT A MERE CHANGE OF OPINION COULD N OT BE A BASIS FOR REOPENING COMPLETED ASSESSMENTS WOULD BE APPLICABLE ONLY TO SITUATIONS WHERE THE ASSESSING OFFICER HAD APPLIED HIS MIND AN D TAKEN A CONSCIOUS DECISION ON A PARTICULAR MATTER IN ISSUE. IT WOULD HAVE NO APPLICATION WHERE I.T.A. NO.14 /COCH/2014 4 THE ORDER OF ASSESSMENT DID NOT ADDRESS ITSELF TO T HE ASPECT WHICH WAS THE BASIS FOR REOPENING OF THE ASSESSMENT. THEREFORE IT WAS INCONSEQUENTIAL WHETHER OR NOT THE MATERIAL NECESSARY FOR TAKING A DECISION WAS AVAILABLE TO THE ASSESSING OFFICER EITHER GENERALLY OR IN THE FO RM OF A REPLY TO THE QUESTIONNAIRE SERVED UPON THE ASSESSEE. WHAT IS IMP ORTANT WAS WHETHER THE ASSESSING OFFICER HAD BASED ON THE MATERIAL AVAILA BLE TO HIM TAKEN A VIEW. SINCE HE HAD NOT DONE SO THE REASSESSMENT COULD NO T BE CHALLENGED ON THE GROUND THAT IT WAS BASED ON A CHANGE OF OPINION. 6. WE HAVE HEARD BOTH THE PARTIES AND CAREFULLY GON E THROUGH THE LEGAL ISSUE. THERE WAS A NOTICE ISSUED TO THE ASSESSEE ON 06-05-2010 TO APPEAR BEFORE THE AO ON 19-05-2010 ON WHICH DATE THE ASSESSEE ACT ED UPON TO APPEAR BEFORE THE AO. ONCE THE ASSESSEE CO-OPERATED WITH THE AO THE ASSESSEE CANNOT RAISE THE ISSUE THAT NOTICE ISSUED TO THE ASSESSEE UNDER SECTION 143(2) IS BAD IN LAW MENTIONING THE DATE OF FILING OF RETURN AS 27-03-20 07 INSTEAD OF 16-04-2010 WHICH IS A TYPOGRAPHICAL ERROR IN THE NOTICE ISSUED U/S. 143(2) OF THE I.T. ACT. ACCORDINGLY WE FIND NO MERIT IN THE ARGUMENT OF TH E ASSESSEE. THIS LEGAL ISSUE IS DISMISSED. 6.1 REGARDING RE-OPENING OF THE ASSESSMENT THE MAI N CONTENTION OF THE ASSESSEES COUNSEL IS THAT THE RE-OPENING IS NOTHIN G BUT A MERE CHANGE OF OPINION AND THE ASSESSING OFFICER HAS CONSIDERED EV ERYTHING AT THE TIME OF ORIGINAL ASSESSMENT. WE ARE NOT IN A POSITION TO AG REE WITH THIS CONTENTION OF THE ASSESSEES COUNSEL. IN THIS CASE THE ASSESSMENT W AS RE-OPENED BY RECORDING REASONS FOR RE-OPENING AS FOLLOWS: I.T.A. NO.14 /COCH/2014 5 REASONS RECORDED U/S. 148(2) OF THE I.T. ACT 1961 1. ANNEXURE E TO THE 3CD REPORT CONTAIN DETAILS OF D ELAYED REMITTANCES OF TDS PERTAINING TO A GROSS AMOUNT OF RS.60 30 389/-. THE SAME WAS NOT CONSIDERED U/S. 40(A)(IA) FOR DISALLOWANCE. 2. VIDE SCHEDULE 22 TO THE ANNUAL REPORT THERE ARE SUBSTANTIAL VARIATIONS IN THE VALUES ADOPTED AS UNDER; (A) RAW MATERIAL CONSUMPTION (STEEL): FOR A.Y. 200 4-05 IT WAS RS. 19.448/KG WHEREAS FOR A.Y. 2005-06 IT HAS BEEN TAK EN AS RS.76.04/KG. (B) OPENING STOCK OF THE STEEL IS TAKEN AS RS. 22. 89/KG BUT CLOSING STOCK IS VALUED AT RS. 6.06/KG DURING THE YEAR. 3. VIDE ANNEXURE TO AUDITORS REPORT: 4. LOANS AND ADVANCES. RS. 36.17 LAKHS ARE ADVANCED TO TWO FIRMS IN WHICH DIRECTORS ARE INTERESTED DURING THE YEAR AND RS. 8.42 LAKHS TO THE RELATIVES OF THE DIRECTORS. THESE UNSECURED LOANS DO NOT SEEM TO BE EXTENDE FOR THE PURPOSES OF BUSINESS. IN THE LIGHT OF THE ABOVE DISCUSSION I HAVE REASON TO BELIEVE THAT INCOME HAS ESCAPED ASSESSMENT WITHIN THE MEANING OF SECTION 147 OF THE I.T. ACT 1961. ISSUE NOTICE U/S. 148 OF THE ACT R EQUIRING THE ASSESSEE TO FURNISH A RETURN WITHIN 10 DAYS OF ITS RECEIPT. AL SO DISPATCH A COPY OF THE REASONS RECORDED FOR REOPENING. 6.2 THE LD. AR SUBMITTED BEFORE US THAT ALL THE ABO VE INFORMATION WERE AVAILABLE WITH THE ASSESSING OFFICER AT THE TIME OF ORIGINAL ASSESSMENT. THE ASSESSING OFFICER CANNOT RE-EXAMINE THE SAME BY RE- OPENING THE ASSESSMENT. IN OUR OPINION THE ASSESSEE MAY HAVE DISCLOSED THE AB OVE PARTICULARS AT THE TIME OF ORIGINAL ASSESSMENT IF THEY ARE FOUND TO BE UNT RUE ON THE BASIS OF MATERIAL DISCOVERED BY A LATER DATE BY THE ASSESSING OFFICER THE ASSESSMENT WOULD BE VALIDLY RE-OPENED U/S. 147(A) OF THE ACT BECAUSE IN SUCH A CASE THE ASSESSEE I.T.A. NO.14 /COCH/2014 6 WOULD HAVE FAILED TO DISCLOSE TRULY AND FULLY ALL M ATERIAL FACTS NECESSARY FOR THE ASSESSMENT AND IT WOULD NOT BE A CASE OF MERE CHANG E OF OPINION. A MERE PRODUCTION OF THE BOOKS OF ACCOUNT OR DOCUMENTS OR OTHER EVIDENCES IS NOT SUFFICIENT FOR MAKING ASSESSMENT. IF THE ASSESSING OFFICER IS UNABLE TO EXAMINE THOSE DOCUMENTS AND TO DISCOVER THE UNDERSTATEMENT OF INCOME BY RELYING ON THE SAME DOCUMENTS THE ASSESSING OFFICER COULD RE- OPEN THE ASSESSMENT ON THE BASIS OF FRESH MATERIAL WHICH CAME TO THE KNOWLEDGE OF THE ASSESSING OFFICER THAT THE INCOME HAS ESCAPED ASSESSMENT. THEREFORE MERE LY BECAUSE MATERIAL LIES EMBEDDED IN THE MATERIAL OR EVIDENCE PRODUCED BY TH E ASSESSEE WHICH THE ASSESSING OFFICER COULD HAVE UNCOVERED BUT DID NOT UNCOVER IS NOT A GOOD GROUND TO CANCEL THE RE-ASSESSMENT PROCEEDINGS. THE ASSESS ING OFFICER COULD HAVE FOUND THE TRUTH BUT HE DID NOT DOES NOT PRECLUDE THE AS SESSING OFFICER FROM EXERCISING THE POWER OF RE-ASSESSMENT TO BRING TO TAX THE ESCA PED INCOME. IN THE PRESENT CASE AS SEEN FROM THE REASONS RECORDED THERE IS P RIMA FACIE ESCAPEMENT OF INCOME. HENCE THE ASSESSING OFFICER AFTER RECORDI NG THE REASONS ISSUED NOTICE TO THE ASSESSEE U/S. 148 OF THE ACT. WE DO NOT FIN D ANY INFIRMITY IN THE ORDER OF THE LOWER AUTHORITIES TO RE-OPEN THE ASSESSMENT. T HIS VIEW OF OURS IS FORTIFIED BY THE FOLLOWING JUDGMENTS: I) ESS ESS KAY ENGG. CO. (P) LTD. VS. CIT (124 TAXMAN 491 (SC). II) HONDA SEIL POWER PRODUCTS LTD. VS. DCI T (340 ITR 64) (SC). III) CONSOLIDATED PHOTO & FINVEST LTD. VS. CIT (281 ITR 394) (DEL). I.T.A. NO.14 /COCH/2014 7 ACCORDINGLY THIS GROUND IS REJECTED. 7. COMING TO THE ADDITION OF RS. 6 20 100/- TOWARDS DISALLOWANCE OF LIQUIDATION DAMAGES THE LD. AR SUBMITTED THAT THIS IS A REVENUE EXPENDITURE TO BE ALLOWED. THE LD. AR SUBMITTED THAT THE LIQUIDAT ION DAMAGES WAS INCURRED BY THE ASSESSEE FOR NOT COMPLETING THE WORK AS PER TIM E SCHEDULE. IT IS EXPENDITURE INCURRED IN THE COURSE OF BUSINESS AND FOR THE PURP OSE OF BUSINESS AND THE JUDGMENT OF THE SUPREME COURT RELIED UPON BY THE CI T(A) IN THE CASE OF SWARAG CEMENT LTD. VS. CIT 325 ITR 422 CANNOT BE APPLIED TO THE FACTS OF THE PRESENT CASE AS IT IS ON DIFFERENT SET OF FACTS. 8. ON THE OTHER HAND THE LD. DR RELIED ON THE ORDE R OF THE CIT(A) AND STATED THAT IT IS CAPITAL IN NATURE AND CANNOT BE A LLOWED AS REVENUE EXPENDITURE. 9. WE HAVE HEARD BOTH THE PARTIES AND CAREFULLY PER USED THE RECORD. THE ASSESSEE INCURRED THIS EXPENDITURE IN THE COURSE OF CARRYING ON BUSINESS OF THE ASSESSEE AND IT IS NOT INCURRED IN CONNECTION WITH THE CAPITAL ASSET. ACCORDING TO THE LD. AR IT WAS RECOVERED FROM THE COMPANY FOR N ON DELIVERY AS PER THE WORK SCHEDULE IN WORK CONTRACT. IF THE WORK CONTRACT IS TREATED BY THE ASSESSEE AS REVENUE IN NATURE CORRESPONDING EXPENDITURE RELATI NG TO THAT WORK IS TO BE CONSIDERED AS REVENUE EXPENDITURE. ON THE OTHER H AND IF IT IS RELATED TO THE CAPITAL ASSET THE SAME WILL BE TREATED AS CAPITAL EXPENDITURE. ACCORDINGLY THIS ISSUE IS REMITTED BACK TO THE FILE OF THE ASSESSING OFFICER FOR FRESH CONSIDERATION. I.T.A. NO.14 /COCH/2014 8 10. THE NEXT GROUND IS WITH REGARD TO DISALLOWANCE OF INTEREST OF RS. 5 05 016/- TOWARDS INTEREST ON DIVERSION OF FUND TO SISTER CONCERNS. ACCORDING TO THE LD. AR THE ASSESSEE HAS ENOUGH OWN FUNDS OUT OF WHICH IT WAS GIVEN TO SISTER CONCERN. 11. ON THE OTHER HAND THE LD. DR SUBMITTED THAT TH E ASSESSEE IS NOT ESTABLISHED THAT THERE IS ENOUGH FUNDS TO DIVERSIFY TO THE SISTER CONCERN ON FREE INTEREST. 12. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE RECORD. ACCORDING TO THE LD. DR THE ASSESSEE ADVANCED INTEREST BEARING FUND S AND NOT OWN FUNDS TO THE SISTER CONCERN FREE OF INTEREST. THE ASSESSEE MUST HAVE OWN FUNDS OR SURPLUS FUNDS AT THE TIME OF ADVANCING THE FUNDS TO THE SIS TER CONCERN. BEING SO IN OUR OPINION IT IS FIT AND PROPER TO REMIT THE ISSUE BA CK TO THE FILE OF THE ASSESSING OFFICER WITH A DIRECTION TO THE ASSESSEE TO PLACE O N RECORD CASH FLOW STATEMENT AS ON THE DATE OF ADVANCEMENT OF FUNDS TO THE SISTER C ONCERN BEFORE THE ASSESSING OFFICER AND THEREAFTER THE ASSESSING OFFICER SHALL DECIDE THE ISSUE IN ACCORDANCE WITH LAW. ACCORDINGLY WE REMIT THE ISSUE BACK TO THE FILE OF THE ASSESSING OFFICER FOR FRESH CONSIDERATION. I.T.A. NO.14 /COCH/2014 9 13. THE NEXT GROUND IS WITH REGARD TO DISALLOWANCE OF EXPENDITURE ON STEEL TEMPORARY STRUCTURES AT RS. 4 96 274/-. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSING OFFICER HAS MADE THIS ADDITION TREATING I T AS CAPITAL EXPENDITURE WHICH PROVIDES ENDURING BENEFIT TO THE ASSESSEE AS STEEL HAS LONG LIFE AND THEREFORE THE ASSESSEES CONTENTION THAT STEEL STRUCTURES BECOME USELESS IN ONE YEAR HAS NOT FOUND FAVOUR WITH THE ASSESSING OFFICER. TREATING T HE EXPENDITURE OF STEEL USED FOR TEMPORARY STRUCTURE AS CAPITAL HAVING AN ENDURI NG BENEFIT THE ASSESSING OFFICER MADE THE ADDITION AND OBSERVED THAT THE STE EL STRUCTURES ARE NOT THROWN OUT AFTER A CONTRACT. IT CANNOT BE SAID BY ANY STA NDARD THAT STEEL BECOMES USELESS AND HENCE THE SAME IS SPREAD OVER MORE THAN 2-3 ASSESSMENT YEARS TO GIVE THE ASSESSEE AND ENDURING ADVANTAGE. HENCE TH E ASSESSING OFFICER TREATED THE SAME AS CAPITAL EXPENDITURE. AGAINST THIS THE ASSESSEE IS IN APPEAL BEFORE US. 14. ON APPEAL THE CIT(A) CONFIRMED THE ADDITION AN D DID NOT ACCEPT THE CONTENTION OF THE ASSESSEE THAT SINCE THE ASSESSEE IS IN THE BUSINESS OF CONSTRUCTION THE TEMPORARY STRUCTURE MADE OF STEEL CANNOT BE USED AGAIN. STEEL USED FOR TEMPORARY STRUCTURE CAN BE USED AND REUSED AND ALSO CARRIED FOR DIFFERENT PROJECTS. HENCE THE CIT(A) AGREED WITH T HE ASSESSING OFFICER THAT THE SUCH EXPENDITURE WOULD PROVIDE AN ENDURING BENEFIT TO THE ASSESSEE. I.T.A. NO.14 /COCH/2014 10 15. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE RECORD. IN OUR OPINION CONSIDERING THE RAW MATERIAL GONE INTO THE CONSTRUC TION ACTIVITIES THE SAME CANNOT BE RETRIEVED IT SHOULD BE CONSIDERED AS REV ENUE EXPENDITURE. THUS IT SHOULD BE CONSIDERED AS ALLOWABLE EXPENDITURE WHILE COMPUTATION OF THE INCOME OF THE ASSESSEE. THIS GROUND IS ALLOWED. 16. IN THE RESULT THE APPEAL FILED BY THE ASSESSEE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES. PRONOUNCED ACCORDINGLY ON 3 1-07-2014. SD/- SD/- (N.R.S.GANESAN) (CHANDRA POOJARI) JUDICIAL MEMBER ACCOUNTANT MEMBER PLACE: KOCHI DATED: 31ST JULY 2014 GJ COPY TO: 1. GEO TECH CONSTRUCTION CO. PVT. LTD. 8 TH FLOOR KSHB BUILDING PANAMPILLY NAGAR COCHIN-36. 2. THE ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE -1(2) KOCHI. 3. THE COMMISSIONER OF INCOME-TAX(APPEALS)-II KOCH I. 4. THE 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 I.T.A. NO.14 /COCH/2014 11