Shri Satish Arora, Gwalior v. I.T.O., Range-1(2), Gwalior

ITA 421/AGR/2010 | 2001-2002
Pronouncement Date: 14-01-2011 | Result: Dismissed

Appeal Details

RSA Number 42120314 RSA 2010
Assessee PAN AEDPA9393M
Bench Agra
Appeal Number ITA 421/AGR/2010
Duration Of Justice 2 month(s) 17 day(s)
Appellant Shri Satish Arora, Gwalior
Respondent I.T.O., Range-1(2), Gwalior
Appeal Type Income Tax Appeal
Pronouncement Date 14-01-2011
Appeal Filed By Assessee
Order Result Dismissed
Bench Allotted SMC
Tribunal Order Date 14-01-2011
Date Of Final Hearing 05-01-2011
Next Hearing Date 05-01-2011
Assessment Year 2001-2002
Appeal Filed On 28-10-2010
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL AGRA (SMC) BENCH AGRA BEFORE SHRI P.K. BANSAL ACCOUNTANT MEMBER ITA NO. 421/AGR./2010 ASSTT. YEAR : 2001-02 SHRI SATISH ARORA VS. INCOME-TAX OFFICER SHABD PRATAP ASHRAM RANGE 1(2) GWALIOR. GWALIOR (PAN: AEDPA 9393M) (APPELLANT) (RESPONDENT) FOR APPELLANT : SHRI K.C. AGARWAL ADVOCATE FOR RESPONDENT : SHRI VINOD KUMAR JR. D.R. ORDER THIS APPEAL HAS BEEN FILED BY THE ASSESSEE DELAYE D BY 9 DAYS WHICH IS DULY CONDONED AGAINST THE ORDER DATED 18.08.2010 OF THE LEARNED C IT(A) BY TAKING VARIOUS GROUNDS. GROUND NO. 5 WAS NOT PRESSED WHILE GROUND NO. 6 IS GENERAL IN NATURE. THE EFFECTIVE GROUNDS TAKEN BY THE ASSESSEE THEREFORE REMAIN AS UNDER : 1.1 ON THE FACTS AND IN THE CIRCUMSTANCES OF THE C ASE THE LD. ASSESSING OFFICER ERRED IN LAW ISSUING NOTICE U/S. 148 OF THE I.T. AC T WITHOUT HAVING ANY CREDIBLE AND RELIABLE MATERIAL LEADING HIM TO REASONS TO BELIEVE THAT ASSESSEES INCOME HAS ESCAPED ASSESSMENT AND LD. COMMISSIONER OF INCOME T AX (APPEALS) GWALIOR ALSO NOT CONSIDERED SUCH FACT IN HER APPEAL ORDER. 1.2 THE LD. ASSESSING OFFICER ERRED IN LAW AND ON F ACTS IN ISSUING NOTICE U/S. 148 ON THE BASIS OF SUSPICION SURMISES AND CONJECT URES AND CONSEQUENTLY THE ASSESSMENT FRAMED IS NULL AND VOID AND LD. COMMISSI ONER OF INCOME TAX (APPEALS) GWALIOR ALSO NOT CONSIDERED SUCH FACT IN HER APPEAL ORDER. 1.3 THAT THE LD. ASSESSING OFFICER ERRED IN LAW MAK ING ENQUIRIES AND INVESTIGATION REGARDING INCOME SHOWN BY THE APPELLA NT AND HAD NO RELIABLE MATERIAL AND REASONS TO BELIEVE THAT INCOME OF THE ASSESSEE HAS ESCAPED ASSESSMENT. THEREBY ASSESSMENT FRAMED IS BAD IN LAW . 2. THAT THE LD. ASSESSING OFFICER ERRED IN ESTIMATI NG THE INCOME OF THE BUSES WITHOUT ANY BASIS AND HE ALSO NOT DISCLOSE THE BASI S OF THE ESTIMATION OF INCOME OF THE BUSES AND LD. COMMISSIONER OF INCOME TAX (APPEA LS) GWALIOR ALSO SUSTAINED 2 PARTLY ADDITION IN THE APPEAL ORDER. THEREFORE THE ADDITION MADE ON ESTIMATION BASIS DESERVES TO BE DELETED. 3. THAT THE LD. ASSESSING OFFICER ERRED IN LAW IN P ASSING NON-SPEAKING ORDER REGARDING ESTIMATION OF INCOME AND LD. COMMISSIONER OF INCOME TAX (APPEALS) GWALIOR ALSO NOT CONSIDERED SUCH FACT IN HER APPEAL ORDER. THEREFORE THE ADDITION IS AGAINST THE LAW AND DESERVES TO BE DELE TED. 4. THAT THE LD. ASSESSING OFFICER ERRED IN LAW IN M AKING ALL THE ADDITIONS WHICH ARE NOT RELATED WITH THE REASSESSMENT PROCEED INGS AND LD. COMMISSIONER OF INCOME TAX (APPEALS) GWALIOR ALSO NOT CONSIDERED SUCH FACT IN HER APPEAL ORDER. THEREFORE ALL THE ADDITIONS ARE AGAINST THE LAW AND DESERVE TO BE DELETED. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E IS CARRYING ON THE BUSINESS OF BUS PLYING. HE DID NOT MAINTAIN REGULAR BOOKS OF ACCOUNT. HE SU BMITTED THE RETURN DECLARING AN INCOME OF RS.97 363/- WHICH INCLUDES RS.92050/- DECLARED AS BUSINESS INCOME AFTER CLAIMING DEPRECIATION OF RS.1 92 950/-. THE RETURN WAS PROCESSED U/S. 143 (1) ON 28.03.2002. SUBSEQUENTLY THE ASSESSING OFFICER NOTED THAT THE ASSESSEE HAS NOT E NCLOSED PROFIT AND LOSS ACCOUNT AND INCOME & EXPENDITURE ACCOUNT ALONGWITH THE RETURN. THE ASSES SEE HAS GROSS RECEIPTS DURING THE ASSESSMENT YEAR AT RS.16 87 567/- ON WHICH HE HAS CLAIMED DEP RECIATION OF RS.1 92 950/-. THE ASSESSING OFFICER THUS NOTED THAT AFTER DEDUCTING THE DEPRE CIATION THE INCOME EARNED WILL BE RS.14 94 617/- WHILE THE ASSESSEE HAS DISCLOSED INC OME AT RS.92 050/-. HE THEREFORE INITIATED THE PROCEEDINGS U/S. 147 OF THE INCOME-TAX ACT FOR ESCAPEMENT OF INCOME OF RS.14 02 567/- (RS.14 94 617 92050) BY ISSUING A NOTICE U/S. 148 OF THE ACT AFTER RECORDING REASONS ON 22.12.2006 AND AFTER GETTING THE REQUISITE SANCTION U/S. 151(1) FROM THE JOINT COMMISSIONER OF INCOME-TAX RANGE-I GWALIOR. THE NOTICE ISSUED U/S . 148 DATED 28.12.2006 WAS SERVED ON THE ASSESSEE ON 10.01.2007. THE ASSESSEE OBJECTED THE I NITIATION OF THE RE-ASSESSMENT PROCEEDINGS BUT WHEN THE OBJECTIONS WERE HEARD THE LEARNED AR FOR THE ASSESSEE WAS SATISFIED WITH THE INITIATION OF RE-ASSESSMENT PROCEEDINGS. THE ASSESS ING OFFICER NOTED THAT THE ASSESSEE WAS PLYING FOUR BUSES OUT OF WHICH ONE BUS NO. MP07- F 0826 WA S RUNNING UNDER THE CONTRACT ENTERED INTO 3 WITH M.P. STATE ROAD TRANSPORT CORPORATION ON THE R OUTE GWALIOR TO INDORE TO AND FRO. THE ASSESSEE HAS DULY SUBMITTED THE DETAILS IN RESPECT OF RECEIPT AND EXPENDITURE BUT DID NOT PRODUCE ANY EVIDENCE SO FAR IT RELATES TO THE INCURRENCE OF THE EXPENDITURE ESTIMATED BY THE ASSESSEE. IN RESPECT OF OTHER THREE BUSES THE ASSESSEE POINTED OUT THAT THE INCOME HAS BEEN SHOWN ON ESTIMATE BASIS AND HE IS NOT MAINTAINING ANY RECORD FOR THE SAME. THE ASSESSING OFFICER ALSO NOTED THAT DURING THE ASSESSMENT YEAR 1999-2000 THE ASSESSEE HAS SHOWN THE ASSESSABLE INCOME AT RS.1 83 362/- AND THEREFORE AS PER PROVISIONS OF SECTION 44A THE ASSESSEE WAS BOUND TO MAINTAIN THE REGULAR BOOKS OF ACCOUNT. THE ASSESSIN G OFFICER ULTIMATELY ESTIMATED THE INCOME FROM EACH OF THE BUSES AS UNDER :- MP07-5888 : RS. 80 000/- MP08-D0687 : RS.1 10 000/- MP07-F-0554 : RS.1 25 000/- MP07-F-0826 : RS.3 37 500/- ULTIMATELY THE INCOME OF THE ASSESSEE AFTER DEDUCT ING THE DEPRECIATION AT RS.1 92 950/- WAS ESTIMATED FROM PLYING OF THE BUSES AT RS.4 59 550/- AND AFTER ADDING THE INTEREST INCOME AS SHOWN BY THE ASSESSEE AT RS.5313/- THE TOTAL INCOM E WAS COMPUTED AT RS.4 64 860/-. 3. THE ASSESSEE WENT IN APPEAL BEFORE THE LD. CIT(A ). BEFORE THE LEARNED CIT(A) THE ASSESSEE CHALLENGED THE INITIATION OF PROCEEDINGS U /S. 147 AND ALSO THE ESTIMATION OF THE INCOME. THE CIT(A) AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESSEE CONFIRMED THE VALIDITY OF THE INITIATION OF PROCEEDINGS U/S. 147 AND REDUCED THE ESTIMATION OF INCOME AS UNDER : MP07-5888 : RS. 60 000/- MP08-D0687 : RS.1 00 000/- MP07-F-0554 : RS.55 000/- MP07-F-0826 : RS.1 68 760/- ---------------- RS.3 83 760/- --------------- 4 THE INCOME WAS ESTIMATED EXCLUDING THE DEPRECIATION AFTER CONSIDERING THE INCOME EARNED BY THE ASSESSEE FROM EACH OF THE BUSES IN THE EARLIER YEAR . THUS THE APPEAL OF THE ASSESSEE WAS PARTLY ALLOWED BY HIM. 4. BEFORE US THE LEARNED AR VEHEMENTLY CONTENDED T HAT THE INITIATION OF PROCEEDINGS U/S. 147 IS INVALID. THE ASSESSING OFFICER HAS ESTIMATED THE INCOME WITHOUT ALLOWING ANY EXPENDITURE INCURRED BY THE ASSESSEE EXCEPT THE DEPRECIATION. T HIS CANNOT BE ANY BASIS FOR COMPUTATION OF THE INCOME. ON A QUERY FROM THE BENCH LEARNED AR AGREE D THAT THE ASSESSEE HAS NEITHER MAINTAINED REGULAR ACCOUNTS NOR ENCLOSED PROFIT AND LOSS ACCOU NT. ON MERIT HE VEHEMENTLY CONTENDED THAT THE ESTIMATION OF THE INCOME BY THE ASSESSING OFFIC ER AND AS CONFIRMED BY THE CIT(A) IS AT A VERY HIGH FIGURE. THE ESTIMATION IN THE ABSENCE OF BOOKS OF ACCOUNT HAS TO BE BASED ON THE MATERIAL AVAILABLE ON RECORD. THERE WAS NO MATERIAL AVAILABLE ON RECORD TO SUPPORT THE ESTIMATION MADE BY THE REVENUE AUTHORITIES. THEREFORE THE EST IMATION OF THE INCOME IS NOT CORRECT AND THE ESTIMATION OF INCOME AS RETURNED BY THE ASSESSEE MU ST HAVE BEEN ACCEPTED. 5. THE LEARNED DR ON THE OTHER HAND CONTENDED THA T THE REASONS RECORDED WERE BONA FIDE. THE ASSESSEE SINCE WAS HAVING INCOME IN THE EARLIER YEAR MORE THAN RS.1 00 000/- THEREFORE THE ASSESSEE WAS REQUIRED TO MAINTAIN REGULAR BOOKS OF ACCOUNT U/S. 44AA OF THE ACT AND PREPARE THE PROFIT AND LOSS ACCOUNT AND THE BALANCE SHEET. THE ASSESSEE IN THIS CASE HAS NOT ENCLOSED PROFIT AND LOSS ACCOUNT AND BALANCE SHEET ALONGWITH THE RE TURN FILED BY HIM. THE ASSESSING OFFICER IS THEREFORE RIGHT TO REOPEN THE ASSESSMENT AS IN AB SENCE OF PROFIT AND LOSS ACCOUNT THE ASSESSING OFFICER WAS NOT ABLE TO ANALYZE VARIOUS EXPENDITURE INCURRED BY THE ASSESSEE. ON MERIT HE SUBMITTED THAT THE INCOME FROM EACH OF THE BUSES HA S BEEN ESTIMATED BY THE ASSESSING OFFICER ON 5 THE BASIS OF THE INCOME AS HAS BEEN RETURNED BY THE ASSESSEE IN THE EARLIER YEAR. THEREFORE IT CANNOT BE SAID THAT THE INCOME FROM EACH OF THE BUS ES HAS NOT BEEN ESTIMATED ON THE BASIS OF THE MATERIAL ON RECORD. 6. I HAVE CAREFULLY CONSIDERED THE RIVAL SUBMISSION S AND GONE THROUGH THE RESPECTIVE ORDERS OF THE AUTHORITIES BELOW. I NOTED THAT THERE ARE ON LY TWO ISSUES INVOLVED IN THIS APPEAL I.E. ONE RELATING TO INITIATION OF PROCEEDINGS U/S. 147 OF T HE INCOME-TAX ACT AND THE OTHER RELATES TO THE ESTIMATION OF INCOME FROM PLYING OF BUSES BY THE AS SESSEE. 7. SO FAR AS THE FIRST ISSUE RELATING TO INITIATION OF PROCEEDINGS U/S. 147 IS CONCERNED I HAVE GONE THROUGH THE REASONS RECORDED BY THE ASSESSING OFFICER. I NOTED FROM THE FACTS OF THE CASE THAT THE ASSESSEE HAS TO MAINTAIN REGULAR BOOKS OF ACCOUNT U/S. 44AA OF THE INCOME TAX ACT AND PREPARE THE PROFIT AND LOSS ACCOUNT BUT THE ASSESS EE IN THIS CASE DID NOT MAINTAIN THE REGULAR BOOKS OF ACCOUNT. EVEN THE PROFIT AND LOSS ACCOUNT HAS NOT BEEN ENCLOSED ALONG WITH THE INCOME TAX RETURN. UNDER THESE CIRCUMSTANCES IN MY OPINIO N THE ASSESSING OFFICER HAS BONA FIDE REASON TO BELIEVE THAT THE INCOME CHARGEABLE TO TAX FOR TH E IMPUGNED ASSESSMENT YEAR HAS ESCAPED ASSESSMENT. AT THE TIME OF INITIATION OF THE PROCEE DINGS THE BELIEF OF THE ASSESSING OFFICER SHOULD BE A BONA FIDE BELIEF. THE TRIBUNAL CANNOT G O TO THE SUFFICIENCY OF THE REASONS. THERE IS MATERIAL ON RECORD WHICH HAS NOT BEEN DENIED BY THE LEARNED AR THAT THE ASSESSEE HAS NOT ENCLOSED PROFIT AND LOSS ACCOUNT ALONG WITH THE INC OME-TAX RETURN WHICH MAY CONTAIN THE DETAILS OF VARIOUS EXPENDITURES ON THE BASIS OF THE BOOKS M AINTAINED BY THE ASSESSEE AND THOSE CLAIMED BY THE ASSESSEE DURING THE YEAR. I THEREFORE HOLD THAT THE NOTICE U/S. 148 HAS RIGHTLY BEEN ISSUED AND THERE IS NO ILLEGALITY IN INITIATING THE PROCEE DINGS U/S. 147 OF THE INCOME-TAX ACT. 6 8. SO FAR AS THE OTHER ISSUE RELATING TO ESTIMATION OF INCOME IS CONCERNED I DO AGREE THAT THE INCOME IN THE ABSENCE OF BOOKS OF ACCOUNT REGULARLY MAINTAINED BY THE ASSESSEE HAS TO BE ESTIMATED ON THE BASIS OF THE MATERIAL AVAILABLE ON RECORD. I NOTED THAT THE ASSESSEE WAS PLYING FOUR BUSES BEARING NO. MP07-5888 MP08-D-0687 MP07 -F-0554 AND MP07-F-0826. 9. SO FAR AS THE ESTIMATION OF INCOME FROM BUS NO. MP07-F-0554 IS CONCERNED I NOTED THAT THE CIT(A) HAS DIRECTED THE ASSESSING OFFICER TO ES TIMATE THE INCOME FROM THIS BUS AT RS.55 000/- AS HAS BEEN ESTIMATED BY THE ASSESSEE. THE ASSESSING OFFICER FROM THIS BUS HAS ESTIMATED INCOME AT RS.1 25 000/-. THE ASSESSEE WAS ALLOWED A RELIEF OF RS.70 000/-. THEREFORE THERE CANNOT BE ANY GRIEVANCE TO THE ASSESSEE SO FA R AS THE ESTIMATION OF INCOME ON THIS BUS IS CONCERNED. 10. IN RESPECT OF THE BUS NO. MP07-5888 I NOTED TH AT THE ASSESSEE HAS DECLARED INCOME FROM THIS BUS IN THE ASSESSMENT YEAR 1997-98 1999-2000 AND 2000-01 AT RS.50 000/- BUT FOR THE ASSESSMENT YEAR 1998-99 HE HIMSELF HAS DECLARED TH E INCOME AT RS.60 000/-. EVEN DURING THE ASSESSMENT YEAR 2002-03 FOR THE MONTH OF APRIL INC OME HAS BEEN DECLARED BY THE ASSESSEE AT RS.5000/-. THE ASSESSING OFFICER HAS ADMITTED THE I NCOME FROM THIS BUS AT RS.80 000/- BUT THE CIT(A) REDUCED IT TO RS.60 000/- WHILE THE ASSESSEE HAS RETURNED THE INCOME FROM THIS BUS AT RS.50 000/-. THE CIT(A) WAS VERY FAIR IN ESTIMATING THE INCOME AT RS.60 000/- ESPECIALLY WHEN THE INCOME FROM THIS VERY BUS WAS ESTIMATED IN THE ASSESSMENT YEAR 1998-99 AT RS. 60 000/- AND FOR ONE MONTH IN ASSESSMENT YEAR 2002-03 HAS BEEN ESTIMATED TO RS.5000/-. IN MY OPINION THE INCOME OVER THE PERIOD CANNOT REMAIN CONSTANT. SINC E IN ASSESSMENT YEAR 1998-99 THE ASSESSEE HIMSELF HAS ESTIMATED INCOME OF RS.60 000/- AND IN ASSESSMENT YEAR 2001-02 THE INCOME FROM THIS BUS IS BOUND TO BE MORE DUE TO INCREASE IN THE FARE ON ACCOUNT OF INFLATION EFFECT. BUT SINCE 7 THE REVENUE IS NOT IN APPEAL I THEREFORE CONFIRM THE ESTIMATION HELD BY THE CIT(A) AT RS.60000/- FROM THIS BUS. 11. NOW COMING TO THE ESTIMATION OF THE INCOME FROM BUS NO. MP08-D-0687 I NOTED THAT THE ASSESSEE ESTIMATED INCOME FROM THIS BUS AT RS.6 0 000/- WHILE THE ASSESSING OFFICER HAS ESTIMATED THE INCOME AT RS.1 10 000/- AND THE CIT(A ) REDUCED IT TO RS.100000/-. THE ASSESSEE HIMSELF IN THE ASSESSMENT YEAR 1997-98 1998-99 AND 1999-2000 HAS ESTIMATED THE INCOME FROM THE SAME VERY BUS AT RS.1 10 000/ RS.1 25 000/- AN D RS.1 00 000/- BUT DURING THE YEAR UNDER CONSIDERATION HE ESTIMATED THE INCOME AT RS.60 000/ -. THEREFORE THE ONUS IS ON THE ASSESSEE TO GIVE REASON WHY THE ESTIMATION OF INCOME FROM THIS BUS GOT REDUCED. IF THE BUS HAS PLIED SAME KILOMETERS AS IN THE EARLIER YEARS THE ESTIMATION OF INCOME FROM THIS BUS IN MY OPINION MUST BE HIGHER THAN THE EARLIER YEAR AS OVER THE PERIOD T HE PASSENGER FARE HAS INCREASED DUE TO INFLATION EFFECT. THE CIT(A) I NOTED HAS TAKEN AVERAGE OF T HE LAST FOUR YEARS AND ON THAT BASIS HAS REDUCED THE ESTIMATE AT RS.100000/-. THE ESTIMATION WORKED OUT BY THE CIT(A) IN MY OPINION IS JUSTIFIED AND FAIR AND DOES NOT REQUIRE MY INTERFERENCE. I T HEREFORE CONFIRM THE ESTIMATION OF INCOME FROM THIS BUS AS REDUCED BY THE CIT(A). 12. SO FAR AS ESTIMATION OF INCOME FROM BUS NO. MP0 7-F-0826 IS CONCERNED THIS BUS HAS BEEN PLIED BY THE ASSESSEE UNDER CONTRACT WITH MPSR TC. THE ASSESSEE HAS RECEIVED GROSS AMOUNT OF RS.16 87 567/- AS PER TDS CERTIFICATE TO ESTIMATE THE NET INCOME FROM THIS BUS AT RS.1 20 000/-. THE EXPENSES AS CLAIMED BY THE ASSES SEE WERE BASED ON ESTIMATION BUT THE ASSESSEE DID NOT PRODUCE ANY EVIDENCE NEITHER BEFOR E THE AUTHORITIES BELOW NOR BEFORE ME. THE ASSESSING OFFICER ESTIMATED THE NET INCOME BY APPLY ING A GROSS PROFIT RATE OF 20% WHILE THE ASSESSEE HAS DECLARED NET INCOME @ 7.11%. THE CIT(A ) REDUCED THE NET PROFIT @ 10% KEEPING 8 IN VIEW THE INCOME SHOWN BY THE ASSESSEE FROM THE S AME BUS IN THE EARLIER YEAR. BEFORE US EVEN THOUGH LD. AR APPEARED AND AT PAGE 1 OF THE PAPER B OOK SUBMITTED THE DETAILS OF THE INCOME SHOWN FROM THIS VERY BUS AT RS.1 20 000/- IN THE AS SESSMENT YEAR 2002-03 AND 2003-04 BUT DID NOT POINT OUT HOW MUCH GROSS AMOUNT WAS RECEIVED BY THE ASSESSEE FROM THE PLYING OF THIS BUS SO THAT IT COULD BE WORKED OUT AT WHAT RATE THE NET IN COME HAS BEEN SHOWN FROM THIS BUS BY THE ASSESSEE. AS HAS BEEN OBSERVED BY ME IN RESPECT OF OTHER BUSES THE NET INCOME FROM ANY BUS IN MY OPINION CANNOT REMAIN CONSTANT OVER THE PERIOD. IN MY OPINION ONUS IS ON THE ASSESSEE TO PROVE IN THE ABSENCE OF BOOKS OF ACCOUNT HOW HE EST IMATED THE INCOME AT RS.1 20 000/-. THE ASSESSEE HAS NOT COME FORWARD. EVEN NO EVIDENCE WAS BROUGHT ON RECORD TO PROVE THE GENUINENESS OF THE ESTIMATION WORKED OUT BY THE ASS ESSEE. UNDER THESE FACTS AND CIRCUMSTANCES IN MY OPINION NO INTERFERENCE IS CALLED FOR IN THE ESTIMATION OF THE INCOME FROM THIS BUS AT RS.1 68 760/- BY THE LEARNED CIT(A). I ACCORDINGLY CONFIRM THE ESTIMATION MADE BY THE CIT(A). 13. IN THE RESULT I CONFIRM THE ORDER OF THE CIT(A ) AND DISMISS THE APPEAL OF THE ASSESSEE. ORDER PRONOUNCED IN THE OPEN COURT ON 14.01.11. SD/- (P.K. BANSAL) ACCOUNTANT MEMBER DATED: 14 TH JANUARY 2011 *AKS/- COPY OF THE ORDER FORWARDED TO : 1. APPELLANT 2. RESPONDENT 3. CIT(A) BY ORDER 4. CIT CONCERNED 5. DR ITAT AGRA 6. GUARD FILE ASSISTANT REGISTRAR TRUE COPY