ITO, New Delhi v. M/s Mangal Kamna Hire Purchase (P) Ltd,, New Delhi

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH E DELHI BEFORE SHRI I.P. BANSAL AND SHRI K.G. BANSAL I.T.A. NOS. 1995 & 1996(DEL)/2009 ASSESSMENT YEARS: 2002-03 & 2003-04 INCOME-TAX OFFICER M/S MANGAL KAMNA HIRE PURCHASE WARD 6(2) NEW DELHI. VS. (P) LTD. H2/1 MODEL TOWN DELHI. (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI G.S. SAHOTA SR. D.R. RESPONDENT BY: SHR I N.K. RUSTOGI ADVOCATE ORDER PER BENCH THESE APPEALS OF THE REVENUE INVOLVING SIMIL AR GROUNDS WERE ARGUED IN A CONSOLIDATED MANNER BY THE LD. DR AND THE LD. COUNSEL FOR THE ASSESSEE. THEREFORE A CONSOLIDATED ORDER IS PASSED TO DISPOSE OFF THESE APPEALS. ITA NO. 1995(DEL)/2009- A.Y. 2002-03 2. THE FACTS MENTIONED IN THE ASSESSMENT ORDE R ARE THAT THE RETURN OF INCOME WAS FILED ON 30.10.2002 DECLARING TOT AL INCOME OF RS. 14 311/-. THE RETURN WAS PROCESSED U/S 143(1) OF THE ACT . THEREAFTER INFORMATION WAS RECEIVED FROM THE DIRECTOR OF INCOME-TAX (IN V.) NEW DELHI THAT THE ASSESSEE INTRODUCED ITS UNACCOUNTED MONEY IN ITS BOOKS OF ACCOUNT IN THE NAMES OF THREE ACCOMMODATION ENTRY OPERATORS. THE DETAILS OF THE ITA NOS. 1995 & 1996(DEL)/2009 2 ENTRY OPERATORS ARE MENTIONED ON PAGE 1 OF T HE ASSESSMENT ORDER. THESE DETAILS ARE REPRODUCED BELOW FOR READY R EFERENCE:- SL. NO. NAME OF THE PARTY AMOUNT (RS.) DATE (I) M/S RELIABLE SECURITIES LTD. 5 00 000/- 17.9.20 01 (II) M/S CONVENIENCE CONSTRUCTION PVT. LTD. 5 00 000/- 8.12.2001 (III) M/S RANI ENTERPRISES 5 00 000/- 10.1.2002 2.1 ON THE BASIS OF THE INFORMATION REASONS WERE RECORDED TO ASSESS THE INCOME U/S 147 OF THE ACT. THEREAFTER NOTI CE WAS ISSUED U/S 148 ON 26.3.2007 AFTER OBTAINING THE APPROVAL OF THE A DDITIONAL COMMISSIONER OF INCOME-TAX RANGE-6 NEW DELHI. 2.2 IN THE COURSE OF ASSESSMENT PROCEEDINGS U/S 1 47 THE ASSESSEE WAS REQUIRED TO EXPLAIN THE GENUINENESS OF THE CRED ITS MADE IN ITS BOOKS AS MENTIONED ABOVE. INFORMATION WAS ALSO OBTAINED FROM THE BANKERS OF THE ALLEGED ENTRY-OPERATORS. ON PERUSAL OF THE BANK ACCOUNTS IT WAS FOUND THAT THE ACCOUNTS OF M/S RELIABLE SECURITIE S LTD. (RELIABLE FOR SHORT) AND M/S CONVENIENCE CONSTRUCTION PVT. L TD. (CONVENIENCE FOR SHORT) WERE CREDITED WITH RS. 5.00 LAKH EACH O N THE SAME DAY ON WHICH EQUIVALENT SUMS WERE TRANSFERRED TO THE ACCOUN T OF THE ASSESSEE. IN THE CASE OF M/S RANI ENTERPRISES IT WAS FOUND THAT CASH AMOUNTING TO RS. ITA NOS. 1995 & 1996(DEL)/2009 3 5.00 LAKH WAS DEPOSITED ON 10.01.2002 AND THERE AFTER THE CHEQUE OF AN EQUIVALENT AMOUNT WAS ISSUED TO THE ASSESSEE . IT WAS SUBMITTED BY THE ASSESSEE THAT THE RELIABLE AND THE CONVENIE NCE HAVE BEEN ALLOTTED SHARES OF THE ASSESSEE COMPANY AND THE AFORESAID AMOUNTS WERE RECEIVED AS SUBSCRIPTION TO THE SHARE CAPITAL. IN THE CASE OF M/S RANI ENTERPRISE IT WAS SUBMITTED THAT THE ASSESSEE HAD EARLI ER LENT CERTAIN AMOUNT TO IT AND IT RETURNED THE AMOUNT OF RS. 5.00 LAKH ON 10.1.2002. 2.3 THE AO EXAMINED THE FACTS OF THE CASE AND SUBMISSIONS MADE BY THE ASSESSEE. IT WAS MENTIONED THAT STATEMENT OF SHRI P.K. JINDAL RESIDENT OF E-3/12 MODEL TOWN DELHI WAS RECOR DED UNDER THE PROVISIONS OF SECTION 131 BY THE INVESTIGATION WING. IN THE STATEMENT IT WAS DEPOSED THAT HE WAS CARRYING ON THE BUSINE SS OF PROVIDING ACCOMMODATION ENTRIES. FOR THIS PURPOSE HE USE D TO TAKE MONEY IN CASH FROM THE BENEFICIARY AND DEPOSIT THE SAME IN HIS BANK ACCOUNT OPENED IN VARIOUS NAMES. THEREAFTER A CHEQUE OR PAY ORDER WAS ISSUED TO THE BENEFICIARY AFTER CHARGING COMMISSION VARYING BETWEEN 0.10% TO 0.25% OF THE AMOUNT. IN VIEW OF THIS STATEMENT IT WAS HELD THAT THE ENTRIES WERE NOT REAL AND SUBSTANTIVE BUT ACCOMMODAT ION ENTRIES. THEREFORE ITA NOS. 1995 & 1996(DEL)/2009 4 THE AMOUNT OF RS. 15.00 LAKH WAS ADDED TO THE TOTAL INCOME OF THE ASSESSEE. 2.4 AGGRIEVED BY THIS ORDER THE ASSESSEE FILED APPEAL BEFORE THE LD. CIT(APPEALS)-IX NEW DELHI. IT WAS SUBMITTED THAT THE ASSESSEE HAD ALLOTTED SHARES OF RS. 5.00 LAKH EACH TO THE R ELIABLE AND THE CONVENIENCE FOR WHICH IT HAD RECEIVED ACCOUNT PAYEE CHEQUES WHICH WERE CREDITED IN ITS BANK ACCOUNT WITH UCO BANK MODEL TOWN DELHI. THE ASSESSEE HAD LENT RS. 18.00 LAKH TO M/S RANI ENTERPRISES OUT OF WHICH RS. 5.00 LAKH WERE RECEIVED IN THIS YEAR. THE AO HAD IS SUED NOTICES U/S 133(6) TO THESE PARTIES WHO FURNISHED THE REQUISITE INFORMATION ALONG WITH THEIR BANK STATEMENTS. THESE PARTIES ARE REGULARLY ASSESSED TO TAX. THEREFORE THE CREDITS IN THE BOOKS OF ACCOUNT O F THE ASSESSEE ARE GENUINE AND IN SUCH CIRCUMSTANCES NO ADDITION COULD HAVE BEEN MADE IN ITS HANDS. THE ASSESSEE RELIED ON A NU MBER OF DECISIONS PROMINENT BEING IN THE CASE OF CIT VS. STELLAR INVESTMENT LTD. 251 ITR 263 (SC) CIT VS. DIVINE LEASING & FINANCE LTD. (SC) AND CIT VS. LOVELY EXPORTS P. LTD. 216 CTR 195 (SC). THE LD. CIT( A) CONSIDERED THE ASSESSMENT ORDER THE INFORMATION AVAILABLE IN TH E ASSESSMENT RECORD AND THE SUBMISSIONS OF THE ASSESSEE. IT WAS MENTIO NED THAT THE AO HAD ITA NOS. 1995 & 1996(DEL)/2009 5 ISSUED NOTICES TO THE THREE PARTIES WHICH WER E COMPLIED WITH ON 10.11.2007/12.11.2007. SUCH COMPLIANCE LETTERS WERE FOUND IN THE ASSESSMENT FOLDER. THESE LETTERS SHOW THAT ALL THE THREE PERSONS ARE ASSESSED TO TAX. THE RELIABLE AND THE CONVENIENC E HAVE CONFIRMED THE SUBSCRIPTIONS TO SHARE CAPITAL OF THE ASSESSEE COMPANY. FURTHER M/S RANI ENTERPRISES EXPLAINED THAT IT HAS NOT DEALT W ITH IN THE SHARES OF THE ASSESSEE COMPANY BUT THE PAYMENT WAS IN RESPEC T OF LOAN EARLIER TAKEN BY IT. THE LD. CIT(A) ALSO CONSIDERED THE STA TEMENT OF SHRI P.K. JINDAL RECORDED ON 15.4.2004 BY THE ADDITIONAL COMMISS IONER OF INCOME-TAX (INV.). HE REPRODUCED ANSWER TO QUESTION NOS. 4 TO 9. THE ANSWERS CONTAIN THE DETAILS OF THE COMPANIES IN WHICH HE IS DIRECTOR HE IS DIRECTOR AND OPERATED THE BANK ACCOUNT HE IS PROPRIETOR MODES OPERANDI FOLLOWED BY THESE COMPANIES IN PROVIDING ACCOMMODATION ENT RIES AND THE CHARGES RECEIVED BY HIM FOR SUCH SERVICES. HE WAS OF THE VIEW THAT THE STATEMENT WAS GENERAL IN NATURE AND IT DID NOT SPECIFICALL Y MENTION THAT THE ASSESSEE RECEIVED ACCOMMODATION ENTRIES FROM ANY OF THE AFORESAID THREE CONCERNS CONTROLLED BY HIM. IN THE CASE OF M/ S RANI ENTERPRISES THERE WAS NO SUBSCRIPTION TO THE SHARE CAPITAL BUT I T WAS PART RETURN OF THE LOAN ADVANCED BY THE ASSESSEE EARLIER. LOOKIN G TO THESE FACTS AND THE RATIO OF THE CASES MENTIONED ABOVE IT WAS HELD THAT THERE WAS NO CASE ITA NOS. 1995 & 1996(DEL)/2009 6 FOR MAKING ANY ADDITION TO THE INCOME OF THE ASSESSEE. AGGRIEVED BY THIS ORDER THE REVENUE IS IN APPEAL BEFORE US. 3. BEFORE US THE LD. DR REFERRED TO THE INFORMAT ION IN POSSESSION OF THE AO AND ENQUIRIES MADE BY HIM ON THE INFORMAT ION. IT WAS SUBMITTED THAT IN ALL THE CASES CASH WAS DEPOSITED IN THE BANK ACCOUNTS OF THE PAYERS BEFORE ISSUING CHEQUE TO THE ASSESSEE. THERE WAS NO COMPLIANCE BY ANY OF THE THREE PARTIES TO NOTICES ISSUED U/S 133(6) AND NONE OF THEM APPEARED BEFORE THE AO. HOWEVER THE LD. CIT(A) HELD THAT ALL THE THREE PARTIES RESPONDED TO NOTICES U/S 133(6). THE FACTS ON RECORD SHOW THAT THE SOURCE OF MONEY IN THE HANDS OF THE THREE PARTI ES HAS NOT BEEN SATISFACTORILY EXPLAINED WHICH IS NECESSARY FOR JUDGING THE CAPACITY OF THE CREDITOR. THEREFORE IT WAS AGITATED THAT EITHER THE ADDITIONS MADE BY THE AO MAY BE CONFIRMED OR IN THE ALTERNATIV E THE MATTER MAY BE RESTORED TO THE FILE OF THE AO SO THAT ALL THE PAR TIES COULD BE EXAMINED WITH A VIEW TO ARRIVE AT AN APPROPRIATE CONCLU SION IN THE MATTER. 3.1 IN REPLY THE LD. COUNSEL SUBMITTED THAT THE STATEMENT OF SHRI P.K. JINDAL WAS NOT RECORDED IN THE PRESENCE OF THE ASSESSEE. NO OPPORTUNITY WAS GIVEN TO IT TO CROSS-EXAMINE SHRI JINDAL. RE LIANCE CANNOT BE PLACED ITA NOS. 1995 & 1996(DEL)/2009 7 ON THE UNTESTED STATEMENT TO THE DETRIMENT OF THE ASSESSEE. IT WAS ALSO MENTIONED THAT ALTHOUGH SHRI JINDAL WAS SUMMONED FOR CROSS- EXAMINATION HE DID NOT APPEAR BEFORE THE AO. IN ANY CASE THERE IS NOTHING IN THE STATEMENT OF SHRI JINDAL WHICH COULD BE CONSTRUED AGAINST THE ASSESSEE. IT HAS NOWHERE BEEN STATED B Y HIM THAT THE AFORESAID THREE ENTRIES WERE IN THE NATURE OF ACCOMMODATI ON ENTRIES. THEREFORE IT WAS ARGUED THAT NOTHING COULD BE ADDED TO TH E INCOME OF THE ASSESSEE ON THE BASIS OF LEGALLY VALID EVIDENCE ON RE CORD. 3.2 IT WAS FURTHER SUBMITTED THAT NO ADDITION COULD HAVE BEEN MADE ON ANY ACCOUNT IN RESPECT OF MONEY RECEIVED FRO M M/S RANI ENTERPRISES AS IT WAS ONLY A PART-RETURN OF THE LOAN ADVA NCED BY THE ASSESSEE TO IT EARLIER. THUS THIS ADDITION HAS TO BE DELETED IN ANY CASE. IN REGARD TO THE OTHER ENTRIES IT WAS SUBMITTED IN THE AL TERNATIVE THAT IF FURTHER ENQUIRIES BY WAY OF CROSS-EXAMINATION WERE REQ UIRED THE MATTER MAY BE RESTORED TO THE FILE OF THE AO. 3.3 IN THE COURSE OF HEARING BEFORE US IT WAS ALSO GATHERED THAT SHARES OF FACE VALUE OF RS. 100/- WERE ALLOTT ED TO THE RELIABLE AND THE CONVENIENCE AT A PREMIUM OF RS. 300/-. THE ASS ESSEE DID NOT FILE THE ITA NOS. 1995 & 1996(DEL)/2009 8 BALANCE-SHEET OF THIS YEAR SO THAT WE COULD EXA MINE WHETHER THE PREMIUM WAS JUSTIFIED LOOKING TO FINANCIAL POSIT ION OF THE ASSESSEE COMPANY. IT WAS ALSO GATHERED THAT THE SHARES WERE SUBSEQUENTLY SOLD TO SHRI ASHOK KUMAR GUPTA BY THE RELIABLE AND THE CONVENIENCE BUT THE LD. COUNSEL COULD NOT FURNISH THE RATE AT WHIC H THE SHARES WERE SOLD. SUCH AN INFORMATION COULD BE IMPORTANT IN DECID ING WHETHER THE SHARES OF THE ASSESSEE COMPANY WERE INTRINSICALLY STRO NG ENOUGH TO BE SUBSCRIBED AT RS. 400/- PER SHARE OR THEREABOUT. 4. WE HAVE CONSIDERED THE FACTS OF THE CASE AND RIVAL SUBMISSIONS. WE MAY DEAL WITH THE CASE OF M/S RANI ENTERP RISES. FROM THE COPY OF THE CONFIRMED ACCOUNT SIGNED BY SHRI ASHOK KUM AR GUPTA IT IS SEEN THAT THE ASSESSEE ADVANCED TWO SUM OF RS. 6.0 0 LAKH AND RS. 12.00 LAKH TO IT ON 7.1.2002 BY CHEQUE NOS. 723399 AND 723 400 RESPECTIVELY. A SUM OF RS. 5.00 LAKH WAS RETURNED BY THAT PA RTY BY WAY OF CHEQUE ON 10.1.2002. THUS ALL THE TRANSACTIONS ARE BY WAY OF CHEQUES AND NONE OF THEM IS BY WAY OF CASH. HOWEVER IT IS ALSO SEEN THAT A SUM OF RS. 5.00 LAKH WAS DEPOSITED IN ITS ACCOUNT BY CASH AS RIGHTLY ALLEGED BY THE LD. DR. THE TRANSACTIONS WITH THE ASSESSEE ALSO GET CONFIRMED WHEN IT IS SEEN FROM THE BANK ACCOUNT OF THAT PARTY THAT A SUM OF RS. 5.00 LAKH ITA NOS. 1995 & 1996(DEL)/2009 9 WAS DEBITED TO ITS ACCOUNT BY ITS BANKER ON 1 0.1.2002 IN LIEU OF CHEQUE NO. 162996. THE CHEQUES ISSUED BY THE ASSESSEE OF RS. 6.00 LAKH AND RS. 12.00 LAKH ARE ALSO FOUND CREDITED IN THIS ACC OUNT ON 7.1.2002. A SUM OF RS. 20.00 LAKH WAS WITHDRAWN FROM THIS AC COUNT ON 7.1.2002. THE ACCOUNT HAD A LARGE NUMBER OF ENTRIES BY WAY OF CASH DEPOSITS AND CASH WITHDRAWALS APART FROM TRANSFER ENTRIES WHI CH MEAN THAT THE MONEY WAS TRANSFERRED TO SOME OTHER ACCOUNT IN THE SA ME BANK. OBVIOUSLY THE ACCOUNT DOES GIVE A POSITIVE IMPRESSION THAT IT IS NOT FOR ANY BUSINESS PURPOSE. HOWEVER THE FACT ALSO REMAINS THAT THE ASSESSEE HAD ADVANCED RS. 18.00 LAKH BY WAY OF TWO CHEQUE S TO THIS PARTY. THESE CHEQUES WERE DEPOSITED IN THE ACCOUNT AND THEREAFTER A SUM OF RS. 20.00 LAKH WAS WITHDRAWN FROM THE ACCOUNT. THEREFORE WHATEVER MAY BE THE PURPOSE OF MAINTAINING THIS ACCOUNT THE CONTROLLER OF THE ACCOUNT WAS IN POSSESSION OF SUFFICIENT MONEY TO DEPOSIT RS. 5.00 LAKH IN CASH ON 10.1.2002. IN OTHER WORDS EVEN IF THIS ACCOUN T IS CONTROLLED BY SHRI P.K. JINDAL HE HAD SUFFICIENT MONEY IN HIS HAN D ORIGINATING FROM THE ASSESSEE TO MAKE A DEPOSIT OF RS. 5.00 LAKH FOR THE PURPOSE OF TRANSMITTING THE SAME TO THE ASSESSEE. IN TH ESE CIRCUMSTANCES WE DO NOT FIND ANY JUSTIFICATION IN ADDING THE AFORE SAID SUM OF RS. 5.00 LAKH IN ITA NOS. 1995 & 1996(DEL)/2009 10 THE HANDS OF THE ASSESSEE U/S 68 OF THE ACT. ACC ORDINGLY THIS ADDITION IS DELETED. 4.1 COMING TO THE SUBSCRIPTION TO SHARES BY THE RELIABLE AND THE CONVENIENCE IT IS FOUND THAT THE CONFIRMATION L ETTERS HAVE BEEN SIGNED BY THE SAME PERSON WHOSE STATEMENT WAS RECORDE D BY THE ADDITIONAL DIRECTOR ON 15.4.2004. THE LD. CIT(APPEALS) HAS MENTIONED THAT THESE CONFIRMATIONS AND OTHER DETAILS WERE FILED IN RESPONSE TO NOTICES U/S 133(6) ISSUED TO THEM ON 5.11.2007. ALTHOUGH IT IS MENTIONED BY THE LD. CIT(APPEALS) THAT THESE PARTIES RESPONDED ON 1 0.1.2007 BEING THE DATE OF LETTERS THE FACT IS THAT THESE LETTERS WERE POSTED BY WAY OF SPEED POST ON 15.11.2007 AT 4.04 P.M. THE AO HAS ME NTIONED THAT NO RESPONSE WAS RECEIVED FROM THESE PERSONS WHIL E THE LD. CIT(APPEALS) HAS MENTIONED THAT THESE LETTERS WERE AVAILABLE IN CASE RECORD. LOOKING TO THE DATES IT IS NOT CLEAR TO US TH AT THESE LETTERS HAD BEEN PLACED IN THE ASSESSMENT RECORD ON OR BEFORE T HE DATE OF PASSING THE ORDER. FROM THE TENOR OF THE ASSESSMENT ORDER IT CAN BE SAID THAT THESE LETTERS WERE NOT AVAILABLE BEFORE THE AO WHE N HE PASSED THE ASSESSMENT ORDER. IN ANY CASE ONE THING BECO MES CLEAR TO US THAT SHRI P.K. JINDAL HAS BEEN TAKING CONTRARY STANDS ONE WHILE MAKING DEPOSITION ON 15.4.2004 AND THE OTHER WHILE FORWA RDING CONFIRMATION ITA NOS. 1995 & 1996(DEL)/2009 11 LETTERS POSTED ON 15.11.2007. THEREFORE WE ARE OF THE VIEW THAT THE MATTER REQUIRES FURTHER ENQUIRY TO ESTABLISH T RUTHFULNESS OF THE STATEMENT OR THE CONFIRMATION LETTERS. SUCH AN ENQUIRY MAY INVOLVE HIS EXAMINATION AND ALSO JUSTIFICATION OF SUBSCRIPTION TO SHA RES AT RS. 400/- PER SHARE. HOWEVER WE WILL REFRAIN FROM PUTTING ANY LIM IT OR GIVING ANY DIRECTION IN REGARD TO THE ENQUIRY. FURTHER JUSTICE DEMANDS THAT BOTH THE PARTIES MAY BE ALLOWED TO BRING BEST EVIDENCE ON RECORD TO SUPPORT THE RESPECTIVE CASES. WITH THESE REMARKS WE RESTORE THE MATT ER TO THE FILE OF THE AO WITH A DIRECTION TO EXAMINE THE ISSUE OF SUBSCR IPTION BY THE AFORESAID TWO COMPANIES DE-NOVO AFTER MAKING APPROPRIATE ENQUIRY AND AFTER GIVING PROPER OPPORTUNITY OF BEING HEARD TO THE ASSESSEE. 4.2 THE RESULT OF AFORESAID DISCUSSION IS THAT GROUND NO. 2 OF THE REVENUE IS TREATED AS PARTLY ALLOWED FOR STATI STICAL PURPOSES. ITA NO. 1996(DEL)/2009-A.Y. 2003-04 5. THE DETAILS OF AMOUNT RECEIVED IN THIS YEAR ARE AS UNDER:- SL. NO. NAME OF THE PARTY AMOUNT (RS.) DATE (I) M/S GAURAV HOLDINGS LTD. 4 00 000/- 9.12.2002 (II) M/S CONVENIENCE CONSTRUCTION PVT. LTD. 4 00 000/- 9.12.2002 (III) M/S RANI ENTERPRISES 6 00 000/- 7.5.2002/14. 5.2002 (IV) M/S SHILPA HOLDINGS LTD. 4 00 000/- 9.12.2002 ITA NOS. 1995 & 1996(DEL)/2009 12 5.1 THE CASE OF THE RIVAL PARTIES WAS SAME AS IN ITA NO. 1995(DEL)/2009 (SUPRA). RELYING ON THAT ORDER THE ADDITION OF RS. 6.00 LAKH IN RESPECT OF M/S RANI ENTERPRISES IS DEL ETED. THE MATTER REGARDING ADDITION IN RESPECT OF GAURAV HOLDINGS LTD. THE CONVENIENCE AND SHILPA HOLDINGS LTD. IS RESTORED TO THE FILE OF THE AO FOR DECIDING THE MATTER AFRESH AFTER MAKING FURTHER ENQUIRY AND AFTER GIVING THE ASSESSEE A REASONABLE OPPORTUNITY OF BEING HEARD. 6. IN THE RESULT BOTH THE APPEALS ARE TREATE D AS PARTLY ALLOWED FOR STATISTICAL PURPOSES. 7. THIS ORDER WAS PRONOUNCED IN THE OPEN COURT ON 30 APRIL 2010. SD/- SD/- (I.P. BANSAL) (K.G.BANSAL) JUDICIAL MEMBER ACCOUNTANT MEMBER DATE OF ORDER: 30 .04.2010. SP SATIA COPY OF THE ORDER FORWARDED TO:- 1. M/S MANGAL KAMNA HIRE PURCHASE (P) LTD. NEW D ELHI. 2. ITO WARD 6(2) NEW DELHI. 3. CIT(A) 4. CIT NEW DELHI. 5. DR ITAT NEW DELHI. ASSISTANT REGISTRA R.