The Asstt.Commissioner of Income-tax,, Amritsar. v. Shri. Kamlesh Gupta,, Amritsar.

ITA 233/ASR/2012 | 2001-2002
Pronouncement Date: 22-04-2014 | Result: Dismissed

Appeal Details

RSA Number 23320914 RSA 2012
Assessee PAN ABCPG9834H
Bench Amritsar
Appeal Number ITA 233/ASR/2012
Duration Of Justice 1 year(s) 10 month(s) 24 day(s)
Appellant The Asstt.Commissioner of Income-tax,, Amritsar.
Respondent Shri. Kamlesh Gupta,, Amritsar.
Appeal Type Income Tax Appeal
Pronouncement Date 22-04-2014
Appeal Filed By Department
Order Result Dismissed
Bench Allotted DB
Tribunal Order Date 22-04-2014
Date Of Final Hearing 08-04-2014
Next Hearing Date 08-04-2014
Assessment Year 2001-2002
Appeal Filed On 28-05-2012
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH; AMRITSAR. BEFORE SH. H.S. SIDHU JUDICIAL MEMBER AND SH. B.P.JAIN ACCOUNTANT MEMBER I.T.A. NOS.232 (ASR)/2012 ASSESSMENT YEAR:2001-02 PAN :ABCPG9834H ASSTT. COMMR. OF INCOME TAX VS. SMT. RANI GUPTA CIRCLE-V AMRITSAR. C/O SH. ANIL PURI ADVOCATE ANAND AVENUE AMRITSAR. (APPELLANT) (RESPONDENT) C.O. NOS.19 (ASR)/2012 (ARISING OUT OF I.T.A. NO.232(ASR)/2012) ASSESSMENT YEAR:2001-02 PAN :ABCPG9834H SMT. RANI GUPTA VS. ASSTT. COMMR. OF INCOME TAX C/O SH. ANIL PURI ADVOCATE CIRCLE-V AMRITSAR. ANAND AVENUE AMRITSAR. (APPELLANT) (RESPONDENT) I.T.A. NOS.233(ASR)/2012 ASSESSMENT YEAR:2001-02 PAN :ABCPG9838M ASSTT. COMMR. OF INCOME TAX VS. SH. KAMLESH GUPTA CIRCLE-V AMRITSAR. C/O SH. ANIL PURI ADVOCATE ANAND AVENUE AMRITSAR. (APPELLANT) (RESPONDENT) ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 2 C.O. NOS.19 (ASR)/2012 (ARISING OUT OF I.T.A. NO.232(ASR)/2012) ASSESSMENT YEAR:2001-02 PAN :ABCPG9838M SH. KAMLESH GUPTA VS. ASSTT. COMMR. OF INCOME TA X C/O SH. ANIL PURI ADVOCATE CIRCLE-V AMRITSAR. ANAND AVENUE AMRITSAR. (APPELLANT) (RESPONDENT) DEPARTMENT BY: SH.TARSEM LAL DR ASSESSEE BY: SH. ANIL PURI ADVOCATE DATE OF HEARING: 08/04/2014 DATE OF PRONOUNCEMENT:22/04/2014 ORDER PER BENCH ; THESE TWO APPEALS OF THE REVENUE ARISE FROM TWO D IFFERENT ORDERS OF THE CIT(A) AMRITSAR EACH DATED 21.03.2012 FOR THE ASSESSMENT YEAR 2001- 02 I.E. SMT. RANI GUPTA & SH. KAMLESH GUPTA. THE RE SPECTIVE ASSESSEES HAVE ALSO FILED CROSS OBJECTIONS. SINCE THE APPEALS OF THE BOTH THE ASSESSES ARE HAVING IDENTICAL ISSUES ACCORDINGLY WE ARE PR OCEEDING TO DECIDE THESE APPEALS BY THIS CONSOLIDATED ORDER FOR THE SAKE OF CONVENIENCE. ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 3 2. THE REVENUE IN ITA NO.232(ASR)/2012 (IN SMT. RAN I GUPTA) HAS RAISED FOLLOWING GROUNDS OF APPEAL: 1. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE THE LD. CIT(A) HAS ERRED IN DIRECTING THE AO TO TAX THE INT EREST INCOME ON NTPC BONDS ON ACCRUAL BASIS FROM YEAR TO YEAR AN D NOT IN THE YEAR OF REDEMPTION. 2. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF TH E CASE THE LD. CIT(A) HAS ERRED TO GIVE HIS FINDING HOW TO CHARGE THE TAX ON INTEREST INCOME OF EARLIER ASSESSMENT YEARS EVEN T HOUGH THE SAME IS FOUND TO HAVE ESCAPED ASSESSMENT. 3. THAT WHILE GIVING EFFECT TO THE LD. CIT(A)S ORD ER NO REMEDIAL ACTION IS POSSIBLE AT THIS STAGE TO TAX INTEREST IN COME FOR THREE ASSESSMENT YEARS EVEN THOUGH THE SAME IS FOUND TO HAVE ESCAPED ASSESSMENT. 4. THAT THE ORDER OF THE LD. CIT(A) BE VACATED AND THAT OF THE AO BE RESTORED.. 5. THAT THE APPELLANT CRAVES LEAVE TO ADD AMEND OR WITHDRAW ANY GROUND OF APPEAL BEFORE OR AT THE TIME OF HEARING O F THE APPEAL. 3. THE REVENUE IN ITA NO.233(ASR)/2012 (IN SH. KAM LESH GUPTA) HAS RAISED FOLLOWING GROUNDS OF APPEAL: 1. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE THE LD. CIT(A) HAS ERRED IN DIRECTING THE AO TO TAX THE INT EREST INCOME ON NTPC BONDS ON ACCRUAL BASIS FROM YEAR TO YEAR AN D NOT IN THE YEAR OF REDEMPTION. 2. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF TH E CASE THE LD. CIT(A) HAS ERRED TO GIVE HIS FINDING HOW TO CHARGE THE TAX ON INTEREST INCOME OF EARLIER ASSESSMENT YEARS EVEN T HOUGH THE SAME IS FOUND TO HAVE ESCAPED ASSESSMENT. ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 4 3. THAT WHILE GIVING EFFECT TO THE LD. CIT(A)S ORD ER NO REMEDIAL ACTION IS POSSIBLE AT THIS STAGE TO TAX INTEREST IN COME FOR THREE ASSESSMENT YEARS EVEN THOUGH THE SAME IS FOUND TO HAVE ESCAPED ASSESSMENT. 4. THAT THE ORDER OF THE LD. CIT(A) BE VACATED AND THAT OF THE AO BE RESTORED.. 5. THAT THE APPELLANT CRAVES LEAVE TO ADD AMEND OR WITHDRAW ANY GROUND OF APPEAL BEFORE OR AT THE TIME OF HEARING O F THE APPEAL. 4. THE ASSESSEE IN C.O. NO.19(ASR)/2012 HAS RAISED FOLLOWING GROUNDS: 1. THAT THE LD. CIT(A) ERRED BOTH IN LAW AS WELL A S IN RESPECT OF THE FACTS OF THE CASE WHILE HOLDING THAT THE SURPLU S REALIZED ON ENCASHMENT OF THE NTPC BONDS WERE NOT LIABLE TO BE TAX AS LONG TERM CAPITAL GAIN. 2. HE FURTHER ERRED TO APPRECIATE THAT THE APPELLAN T WAS ENTITLED TO TAX BENEFITS UNDER SECTION 48 AND 112 OF THE INCOM E TAX ACT 1961 AS CATEGORICALLY COMMITTED IN THE OFFER DOCUME NT AND THE AO WAS BOUND UNDER DOCTRINE OF PROMISSORY ESTOPPEL S TO TREAT THE ACCRETION ON THE SAID BONDS AS CAPITAL GAINS AN D NOT AS INTEREST INCOME. 3. HE WAS FURTHER WRONG IN HOLDING THAT THE APPELLA NT HAS DIRECTLY PURCHASED NTPC BONDS 1993 FOR THE PURPOSE OF EAR NING PROFIT/INTEREST/REDEMPTION MONEY ETC. FROM YEAR TO YEAR AND AS SUCH RETAINED THE SAME TILL THE MATURITY PERIOD AND HAS NOT TRANSACTED ANY SHARE DEALINGS FOR EARNING CAPITAL GAIN THEREFROM SO THE PROVISIONS OF SECTION 45 46A 48 AND 112 AR E NOT APPLICABLE IN THE CASE OF THE APPELLANT. 4. THAT ALL THE COMMENTS PASSED BY THE CIT(A) ARE C ONTRARY TO THE DIRECTIONS OF THE ITAT AMRITSAR VIDE ITS LEARNED O RDER DATED 05.04.2007 WHILE PARTLY ALLOWING THE APPEAL. 5. THE ASSESSEE IN C.O. NO.18(ASR)/2012 HAS RAISED FOLLOWING GROUNDS: ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 5 1. THAT THE LD. CIT(A) ERRED BOTH IN LAW AS WELL A S IN RESPECT OF THE FACTS OF THE CASE WHILE HOLDING THAT THE SURPLU S REALIZED ON ENCASHMENT OF THE NTPC BONDS WERE NOT LIABLE TO BE TAX AS LONG TERM CAPITAL GAIN. 2. HE FURTHER ERRED TO APPRECIATE THAT THE APPELLAN T WAS ENTITLED TO TAX BENEFITS UNDER SECTION 48 AND 112 OF THE INCOM E TAX ACT 1961 AS CATEGORICALLY COMMITTED IN THE OFFER DOCUME NT AND THE AO WAS BOUND UNDER DOCTRINE OF PROMISSORY ESTOPPEL TO TREAT THE ACCRETION ON THE SAID BONDS AS CAPITAL GAINS AN D NOT AS INTEREST INCOME. 3. HE WAS FURTHER WRONG IN HOLDING THAT THE APPELLA NT HAS DIRECTLY PURCHASED NTPC BONDS 1993 FOR THE PURPOSE OF EAR NING PROFIT/INTEREST/REDEMPTION MONEY ETC. FROM YEAR TO YEAR AND AS SUCH RETAINED THE SAME TILL THE MATURITY PERIOD AND HAS NOT TRANSACTED ANY SHARE DEALINGS FOR EARNING CAPITAL GAIN THEREFROM SO THE PROVISIONS OF SECTION 45 46A 48 AND 112 AR E NOT APPLICABLE IN THE CASE OF THE APPELLANT. 4. THAT ALL THE COMMENTS PASSED BY THE CIT(A) ARE C ONTRARY TO THE DIRECTIONS OF THE ITAT AMRITSAR VIDE ITS LEARNED O RDER DATED 05.04.2007 WHILE PARTLY ALLOWING THE APPEAL. 6. FIRST OF ALL WE TAKE UP APPEAL OF THE REVENUE I N ITA NO.232(ASR)/2012 AND C.O. OF THE ASSESSEE BEARING NO.19(ASR)/2012 AND OUR DECISION (IN THE CASE OF SMT. RANI GUPTA) HEREI NBELOW SHALL BE IDENTICALLY APPLICABLE IN THE CASE OF REVENUES APP EAL IN ITA NO.233(ASR)/2012 AND C.O. NO.18(ASR)/2012 (IN THE C ASE OF SH. KAMLESH GUPTA) AS MENTIONED HEREINABOVE. ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 6 7. THE BRIEF FACTS OF THE CASE IN THE CASE OF SMT. RANI GUPTA ARE THAT THE ASSESSEE HAS DECLARED LONG TERM CAPITAL GAIN (NET) OF RS.24 36 000/- ON REDEMPTION OF 1200 BONDS OF NATIO NAL THERMAL POWER CORPORATION (NTPC). THE ASSESSEE HAS PAID TAX @ 10% ON NET L.T.C.G OF RS.19 12 486/- AFTER ADDING LTCG OF RS.10075/- TO A ND AFTER DEDUCTING BROUGHT FORWARD LTC LOSS OF RS.5 33 589/- FROM THE LTCG OF RS.24 36 000/- FROM NTPC BONDS. THE ASSESSEE HAS ME NTIONED IN THE NOTE BELOW THE COMPUTATION OF INCOME THAT THE ASSESSEE R ECEIVED RS.36 36 000/- ON REDEMPTION OF 1200 NPTC BONDS WHICH WERE PURCHAS ED ON 14.12.1993 FOR RS.12 00 000/-. HOWEVER THE ASSESSEE HAD CLAIM ED CREDIT FOR THE TDS OF RS.56840/- RS.181888/- AND RS.34104/- DEDUCTED BY THE N.T.P.C. ON REDEMPTION OF THESE BONDS. A PERUSAL OF FORM 16A IS SUED BY THE NTPC AND ATTACHED WITH THE RETURN SHOWS THAT THE NTPC HAS TR EATED THE DIFFERENCE BETWEEN REDEMPTION PRICE AND PRINCIPAL AMOUNT AS IN TEREST AND T.D.S. @ 11.2% HAS BEEN DEDUCTED ON THE INTEREST INCOME OF R S.5 07 500/- RS.16 24 000/- AND RS.3 04 500/-. 7.1. THE AO THEREAFTER ISSUED A QUESTIONER WHICH WA S REPLIED AND AFTER CONSIDERING THE REPLY AND CIRCUMSTANCES OF THE CASE THE AO TREATED THE DIFFERENCE BETWEEN MATURITY VALUE AND SUBSCRIPTION PRICE OF THE 1200 BONDS NTPC AMOUNTING TO RS.24 36 000/- AS INTEREST INCOME IN THE HANDS OF THE ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 7 ASSESSEE HOLDING THESE BONDS AS INVESTOR. THE MATTE R TRAVELED TO THE I.T.A.T. AND THE ITAT AMRITSAR BENCH VIDE ITS ORDER DATED 0 5.04.2007 SET ASIDE THE ISSUE TO THE FILE OF THE LD. CIT(A) TO DECIDE THE S AME AFRESH. THE ORDER OF THE ITAT DATED 5.4.2007 IS REPRODUCED IN THE ORDER OF T HE LD. CIT (A) AT PAGES 1 TO 7 AND WE ARE NOT REPRODUCING THE SAME TO AVOID REPETITION. THE LD. CIT(A) FOLLOWING THE DIRECTIONS OF THE ITAT AMRITS AR BENCH OBSERVED THAT THE ACCRUED INTEREST INCOME SHOULD BE ASSESSED YEAR -WISE WITH THE RIDER THAT SINCE IT HAS BEEN HELD TO BE ASSESSED AS INTEREST I NCOME UNDER THE HEAD INCOME FROM OTHER SOURCES THEREFORE THE ASSESSE E IS ENTITLED TO RELIEF UNDER SECTION 80-L(1)(II) OF THE I.T. ACT 1961 AND THE CAPITAL GAIN TAXATION DOES NOT ARISE IN THE PRESENT CASE. 8. THE LD. DR MR. TARSEM LAL RELIED UPON THE ORDE R OF THE ASSESSING OFFICER. 9. THE LD. COUNSEL FOR THE ASSESSEE MR. ANIL PURI ADVOCATE ARGUED THAT THE CBDTS CIRCULAR NO.2 OF 2002 DATED 15.02.2002 C ANNOT BE RELIED UPON RETROSPECTIVELY EVEN ON MATURITY AND NTPC HAS DEDUC TED TAX AT SOURCE. HE RELIED UPON THE DECISION OF ITAT KOLKATA BENCH IN THE CASE OF BELVEDERE ESTATES TENANTS ASSOCIATIONS VS. INCOME TAX OFFICER (2012) 139 ITD 675 WHEREIN IT HAS BEEN HELD THAT IN THE SAID TENANT AS SOCIATION THE ALLEGATION THAT MEMBERS HAVE DEDUCTED AT SOURCE FROM PAYMENTS TO THE ASSESSEE AND FOR ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 8 THIS REASON THE RECEIPT IS TO BE TAKEN ON TAXABLE RECEIPT IT IS ONLY ELEMENTARY THAT CONDUCT ON THE PART OF THE PERSON MAKING PAYME NT CANNOT DETERMINE CHARACTER OF RECEIPT IN THE HAND OF RECIPIENT. THE LD. COUNSEL FURTHER RELIED UPON VARIOUS LETTERS DATED 22.01.2004 AND LETTER F ROM NTPC DATED 21.06.2004 AND ARGUED THAT THE SCHEMES REFERRED TO IN SECTIONS 48 112 AND 80L(1)(II) OF THE ACT ARE AVAILABLE TO THE BOND-HO LDERS AND THE LD. CIT(A) HAS IGNORED THE SAME. THEREFORE THE LD. COUNSEL FO R THE ASSESSEE ARGUED THAT IT IS A LONG TERM CAPITAL GAIN AS CLAIMED BY THE AS SESSEE AND THE ORDER OF THE LD. CIT(A) SHOULD BE REVERSED. 10. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. ON PERUSAL OF THE CIRCULAR DATED 15/02/2002 OF CBDT AND VARIOUS LETTERS OF N.T.P.C. DATED 21.06.2004 AND REPLIES OF THE ASSES SEE AND THE DECISION OF THE ITAT KOLKTA BENCH IN THE CASE OF BELVEDERE ES TATES TENANTS ASSOCIATIONS VS. INCOME TAX OFFICER (2012) 139 ITD 675 AND THE ARGUMENTS MADE BY THE LD. COUNSEL FOR THE ASSESSEE AND THE LD . DR AND ON PERUSAL OF RECORDS WE FIND THAT THE ORDER OF THE LD. CIT(A) I S WELL REASONED ONE AND WE FIND NO INFIRMITY IN HIS ORDER ESPECIALLY THE FIND INGS WITH REGARD TO CBDTS CIRCULAR NO.2 OF 2002 (SUPRA) WHICH HAS ALREADY BE EN DEALT WITH BY THE ITAT AMRITSAR BENCH IN THE FIRST ROUND AND WHICH H AS BEEN FOUND DISTINGUISHABLE IN THE FACTS OF THE CASE AND THERE IS NO REFERENCE TO THE ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 9 BOARDS CIRCULAR OR ANY OTHER EARLIER CIRCULAR W HILE DEALING WITH THE DECISION OF THE ITAT BOMBAY BENCH IN THE CASE OF M RS. PERVIZ WANG CHUK BASI VS. JCIT (2006) 102 ITD 123 (MUM). WE CONCUR WITH THE VIEWS OF THE LD. CIT(A) IN PARA 5 OF HIS ORDER THAT THE ASSESSE E HAS NOT FURNISHED RBIS GUIDELINES SPECIFICALLY STATING THAT THE N.T.P.C. B ONDS 1993 IN QUESTION TO BE TREATED AS BONDS AND NOT AS INVESTMENT. THE ASSE SSEE HAS DIRECTLY PURCHASED 1200 BONDS 1993 AND RETAINED THEM UP TIL L THE DATE OF THEIR MATURITY. THE ASSESSEE IS NOT REGULAR DEALER IN SH ARES/SECURITIES/BONDS AND THE SAID HOLDING HAS NEVER BEEN REFLECTED IN STOCK- IN-TRADE IN THE BALANCE SHEET WHICH REMAINED WITH THE ASSESSEE TILL THE MA TURITY PERIOD AND WHICH HAS NEVER VISUALIZED ANY CHANGE IN HANDS.. THE BOND S SO DIRECTLY PURCHASED FOR EARNING INTEREST FROM YEAR TO YEAR AND ACCORDIN GLY THE PROVISIONS OF SECTION 45 46A 48 AND 112 ARE NOT APPLICABLE IN T HE PRESENT FACTS AND CIRCUMSTANCES OF THE CASE. 10.1. WE ALSO CONCUR WITH THE VIEWS OF THE LD. CIT( A) THAT AFTER APPRAISAL OF THE DELHI STOCK EXCHANGES LETTER AND LETTER FRO M DY. GENERAL MANAGER (FIN) NTPC NEW DELHI THIS ISSUE HAS NOW BECOME W ELL SETTLED. THE ONLY QUESTION AND DISPUTED POINT NOW LEFT TO BE DECIDED IS AS TO WHETHER ON THESE ENLISTED NTPC BONDS 1993 THE INCOME ACCRUES CAN B E TREATED AS CAPITAL GAIN OR YEAR-WISE ACCRUED INTEREST INCOME. SINCE A T NO STAGE THERE ARISES ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 10 ANY TRANSFER OF THESE NTPC BONDS 1993 FROM THE ASS ESSEES HANDS TO ANY OTHER HAND BUT RATHER THE SAME REMAINED IN THE CUST ODY OF THE ASSESSEE THROUGHOUT THEIR MATURITY PERIOD SO IT CAN SAFELY BE HELD THAT CAPITAL GAIN TAXATION BY INVOKING COST INFLATION INDEXATION THER EON DOES NOT ARISE AS HAS BEEN DECLARED/CLAIMED BY THE ASSESSEE. THE ACCRUED INTEREST INCOME SHOULD BE ASSESSED YEAR-WISE WITH THE RIDER THAT SINCE IT HAS BEEN HELD TO BE ASSESSED AS INTEREST INCOME UNDER THE HEAD INCOME FROM OTHE R SOURCES SO THE ASSESSEE IS DULY ENTITLED TO RELIEF BY GRANTING DED UCTION UNDER SECTION 80- L(1)(II) OF THE I.T.ACT 1961 THEREON AS PER PROVIS ION OF LAW EXISTING AND APPLICABLE FROM TIME TO TIME AS THE CASE MAY BE. A CCORDINGLY IN THE FACTS AND CIRCUMSTANCES OF THE CASE WE FIND NO INFIRMITY IN THE ORDER OF THE LD. CIT(A) AND THE SAME IS UPHELD. THUS ALL THE GROUND S OF THE REVENUE AND C.O. OF THE ASSESSEE ARE DISMISSED. 11. NOW WE TAKE UP APPEAL OF THE REVENUE IN ITA NO .233(ASR)/2012 AND C.O. NO.18(ASR)/2012 OF THE ASSESSEE. SINCE THE FAC TS IN THE PRESENT CASE ARE IDENTICAL TO THE FACTS IN REVENUES APPEAL IN ITA NO.232(ASR)/2012 AND C.O. NO.19(ASR)/2012 IN THE CASE OF SMT. RANI GUPT A AS MENTIONED HEREINABOVE THEREFORE OUR ORDER IN ITA NO.232(ASR )/2012 AND C.O.NO.19(ASR)/2012 SHALL BE IDENTICALLY APPLICABLE TO THE FACTS OF THE ITA NOS. 232 & 233(ASR)/2012 C.O.NOS. 19 & 18(ASR)/2012 11 PRESENT CASE. ACCORDINGLY ALL THE GROUNDS OF THE R EVENUE IN ITA NO.233(ASR)/2012 AND C.O.NO.18(ASR)/2012 ARE DISMIS SED. 12. IN THE RESULT BOTH THE APPEALS OF THE REVENUE IN ITA NOS. 232 & 233 (ASR)/2012 AND C.O.NOS. 19 & 18(ASR)/2012 OF THE AS SESSES ARE DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 22ND APRIL 2014. SD/- SD/- (H.S. SIDHU) (B.P. JAIN) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 22ND APRIL 2014 /SKR/ COPY OF THE ORDER FORWARDED TO: 1. THE ASSESSEE: 2. THE 3. THE CIT(A) 4. THE CIT 5. THE SR DR ITAT AMRITSAR. TRUE COPY BY ORDER (ASSISTANT REGISTRAR) INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH: AMRITSAR