Sri.K.P.Indrapalan, Mavlikkara v. ACIT, Thiruvalla

ITA 64/COCH/2013 | 2009-2010
Pronouncement Date: 04-10-2013

Appeal Details

RSA Number 6421914 RSA 2013
Assessee PAN AHUPP0635R
Bench Cochin
Appeal Number ITA 64/COCH/2013
Duration Of Justice 7 month(s) 28 day(s)
Appellant Sri.K.P.Indrapalan, Mavlikkara
Respondent ACIT, Thiruvalla
Appeal Type Income Tax Appeal
Pronouncement Date 04-10-2013
Appeal Filed By Assessee
Bench Allotted DB
Tribunal Order Date 04-10-2013
Assessment Year 2009-2010
Appeal Filed On 06-02-2013
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH COCHIN BEFORE S/SHRI N.R.S.GANESAN JM AND B.R.BASKAR AN AM I.T.A. NO.64/COCH/2013 ASSESSMENT YEAR : 2009-10 SHRI K.P. INDRABALAN INDRAPRASTHAM CHARUMMOODU MAVELIKARA. [PAN: AHUPP 0635R] VS. THE ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE-1 THIRUVALLA. (ASSESSEE -APPELLANT) (REVENUE-R ESPONDENT) I.T.A. NO.12/COCH/2013 ASSESSMENT YEAR : 2009-10 THE ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE-1 THIRUVALLA. VS. SHRI K.P. INDRABALAN INDRAPRASTHAM CHARUMMOODU MAVELIKARA. [PAN: AHUPP 0635R] (REVENUE-APPELLANT) (ASSESSEE-R ESPONDENT) REVENUE BY SMT. S. VIJAYAPRABHA JR. DR ASSESSEE BY SHRI J. KRISHNAN CA DATE OF HEARING 22/07/2013 DATE OF PRONOUNCEMENT 04/10/2013 O R D E R PER B.R.BASKARAN ACCOUNTANT MEMBER: THESE CROSS APPEALS ARE DIRECTED AGAINST THE O RDER DATED 30-11-2012 PASSED BY THE LD. CIT(A) TRIVANDRUM AND THEY RELATE TO THE ASSES SMENT YEAR 2009-10. THE APPEAL FILED BY THE ASSESSEE IS BARRED BY LIMITATION BY 2 DAYS. HAVING REGARD TO THE SUBMISSIONS MADE IN THE PETITION FILED BEFORE US W E CONDONE THE DELAY AND ADMIT THE APPEAL. I.T.A. NOS.64 & 12/COCH/2013 2 2. THE ASSESSMENT IN THE HANDS OF THE ASSESSEE WAS COMPLETED BY THE ASSESSING OFFICER U/S. 143(3) OF THE ACT WHEREIN THE ASSESSI NG OFFICER MADE FOLLOWING ADDITIONS: (A) DISALLOWANCE OF INTEREST CLAIM : RS. 7 73 408 /-. (B) ADDITION TOWARDS RENTAL INCOME FROM HOTEL INDR APRASTHA CHARUMMOODU : RS.1 77 500/-. (C) ADDITION TOWARDS RENTAL INCOME FROM HOTEL INDR APRATHA KADAPRA : RS. 5 80 300/-. (D) ADDITION TOWARDS SALE OF LIQUOR : RS. 10 67 70 7/-. 3. IN THE APPEAL FILED BY THE ASSESSEE THE LD. CIT (A) DELETED THE ADDITIONS RELATING TO THE LIQUOR SALES. HE GAVE PARTIAL RELIEF IN RES PECT OF DISALLOWANCE OF INTEREST AND ADDITION RELATING TO THE INCOME OF HOTEL INDRAPRAST HA KADAPRA. HE CONFIRMED THE ADDITION RELATING TO THE RENTAL INCOME FROM CHARUMM OOU HOTEL. AGGRIEVED BOTH THE PARTIES ARE IN APPEAL BEFORE US. 4. THE FIRST ISSUE RELATES TO THE DISALLOWANCE OF A PORTION OF INTEREST CLAIM MADE BY THE ASSESSEE WHICH WAS PARTIALLY DELETED BY THE LD CIT(A). BOTH THE PARTIES ARE CONTESTING THE DECISION RENDERED BY LD CIT(A) ON TH IS ISSUE. THE ASSESSING OFFICER NOTICED THAT THE INTEREST EXPENDITURE CLAIMED BY TH E ASSESSEE INCLUDED INTEREST PAYMENT OF RS. 7 73 408/- ON HDFC HOUSING LOAN. THE ASSESS ING OFFICER TOOK THE VIEW THAT THE INTEREST PAID ON HOUSING LOAN TAKEN BY THE ASSESSEE IS NOT RELATED TO HIS BUSINESS ACTIVITY AND ACCORDINGLY DISALLOWED THE SAME. THE LD. CIT(A) HELD THAT UNDER THE PROVISIONS OF SEC. 36(1)(III) OF THE ACT THE INTER EST PAYABLE ON BORROWED FUNDS IS ALLOWABLE AS DEDUCTION IF SAID LOAN IS USED FOR TH E PURPOSE OF BUSINESS I.E. THE USER OF LOAN FUNDS IS THE CRITERIA FOR ALLOWING INTEREST CL AIM. THE LD. CIT(A) NOTICED THAT THE ASSESSEE HAS TAKEN A LOAN OF RS.1.70 CRORES FROM HD FC BANK AS HOUSING LOAN. FROM THE BALANCE SHEET OF THE ASSESSEE AS ON 31-03-2008 THE LD. CIT(A) NOTICED THAT THE ASSESSEE HAS USED A SUM OF RS. 1.44 CRORES FOR MAK ING INVESTMENTS IN PERSONAL ASSETS. ACCORDINGLY THE LD. CIT(A) HELD THAT THE ASSESSEE HAS USED A SUM OF RS.26.00 LAKHS ONLY OUT OF THE BORROWED AMOUNT OF RS.1.70 CRORES FOR THE PURPOSES OF BUSINESS. ACCORDINGLY THE LD CIT(A) HELD THAT THE PROPORTION ATE INTEREST RELATABLE TO RS.26.00 I.T.A. NOS.64 & 12/COCH/2013 3 LAKHS IS ALLOWABLE AS DEDUCTION. THE LD CIT(A) WOR KED OUT THE PROPORTIONATE INTEREST AT RS.2 76 217/- AND DELETED THE SAME. ACCORDINGLY H E SUSTAINED THE ADDITION TO THE EXTENT OF RS. 4 97 191/-. 4.1 WE HAVE HEARD THE RIVAL CONTENTIONS AND CAREFU LLY PERUSED THE RECORD. WE NOTICE THAT THE LD. CIT(A) HAS GRANTED PARTIAL RELIEF BY CONSIDERING THE BALANCE SHEET OF THE ASSESSEE AS ON 31-03-2008. FROM THE ASSESSMENT OR DER WE NOTICE THAT THE ASSESSING OFFICER DID NOT CONSIDER THE SAID BALANCE SHEET. T HE ASSESSMENT YEAR UNDER CONSIDERATION IS ASST. YEAR 2009-10 AND HENCE THERE MIGHT NOT HAVE BEEN ANY OCCASION FOR THE AO TO CONSIDER THE BALANCE SHEET OF THE IMM EDIATELY PRECEDING YEAR. BEFORE US ALSO BOTH THE PARTIES DID NOT FURNISH THE BALANCE SHEET OF THE ASSESSEE AS ON 31-03- 2008. HENCE WE ARE ALSO NOT IN A POSITION TO APPRE CIATE THE LOGIC OF THE LD. CIT(A) IN GRANTING PARTIAL RELIEF TO THE ASSESSEE. 4.2 THE LD. CIT(A) HAS TAKEN THE VIEW THAT THE INTEREST PAYABLE ON THE LOAN TAKEN IN ANY FORM SHALL BE ALLOWABLE PROVIDED THE SAID LOAN FUNDS ARE USED FOR THE PURPOSES OF BUSINESS OF THE ASSESSEE. WE NOTICE THAT THE PROV ISIONS OF SEC. 36(1)(III) GRANTS DEDUCTION OF INTEREST AMOUNT PAID IN RESPECT OF CAP ITAL BORROWED FOR THE PURPOSES OF BUSINESS. ACCORDING TO THE LD CIT(A) A PORTION OF HDFC LOAN HAS BEEN USED FOR BUSINESS PURPOSES AND HENCE THE SAME SHOULD BE CONS IDERED AS BORROWAL FOR THE PURPOSE OF BUSINESS. WE FIND FORCE IN THE SAID VI EW OF THE LD CIT(A). IF HE ASSESSEE HAS USED A LOAN FOR THE PURPOSE OF BUSINESS IN OUR VIEW ALSO THAT PORTION OF LOAN WHICH WAS USED FOR BUSINESS PURPOSE MAY BE TREATED AS CAPITAL BORROWED FOR THE PURPOSES OF BUSINESS. IN THE INSTANT CASE THE LD CIT(A) HAS GIVEN A FINDING THAT A SUM OF RS.26.00 LAKHS WAS USED BY THE ASSESSEE FOR THE PURPOSE OF HIS BUSINESS ON THE BASIS OF BALANCE SHEET OF THE ASSESSEE AS AT 31.3.2008. HOWEVER IN OUR VIEW THE ASSESSEE HAS TO PROVE ABOUT THE UTILISATION OF LOAN FUNDS FO R BUSINESS PURPOSES BY ESTABLISHING NEXUS BETWEEN THE BORROWED FUNDS AND ITS USER FOR B USINESS. HENCE IT MAY NOT BE CORRECT TO DETERMINE THE SAME BY LOOKING AT THE BAL ANCE SHEET FIGURES. HENCE THE AMOUNT OF RS.26.00 LAKHS DETERMINED BY LD CIT(A) HA S TO BE TESTED WITH REFERENCE TO THE ACTUAL USER OF THE HDFC HOUSING LOAN. WE NOTIC E THE AO DID NOT EXAMINE THE ISSUE I.T.A. NOS.64 & 12/COCH/2013 4 RELATING TO THE UTILISATION OF LOAN FUNDS; INSTEAD HE WAS CARRIED AWAY BY THE NOMENCLATURE OF LOAN. UNDER THESE CIRCUMSTANCES IN OUR VIEW THIS ISSUE REQUIRES A FRESH EXAMINATION AT THE END OF THE ASSESSING OFFIC ER. ACCORDINGLY WE SET ASIDE THE ORDER OF THE LD. CIT(A) ON THIS ISSUE AND RESTORE T HE SAME TO THE FILE OF THE ASSESSING OFFICER WITH A DIRECTION TO EXAMINE THE ISSUE AFRES H AND TAKE APPROPRIATE ACTION IN ACCORDANCE WITH LAW AFTER AFFORDING NECESSARY OPPOR TUNITY OF BEING HEARD TO THE ASSESSEE. 5. THE NEXT ISSUE RELATES TO THE ADDITION TOWARDS R ENTAL INCOME FROM THE TWO HOTELS OWNED BY THE ASSESSEE. THE ASSESSING OFFICER NOTIC ED THAT THE ROOM RENT RECEIVED BY THE ASSESSEE FROM HOTEL INDRAPRASTHA CHARUMMOODU W ORKED OUT ONLY TO 2.3% OF THE OCCUPANCY CAPACITY OF THE HOTEL. THE ASSESSING O FFICER CONSIDERED IT TO BE VERY LOW AND ACCORDINGLY ESTIMATED THE RENTAL INCOME AT 20% OF THE OCCUPANCY CAPACITY AND IT RESULTED IN AN ADDITION OF RS. 1 77 500/-. LIKEWIS E IN THE CASE OF HOTEL INDRAPRASTHA KADAPRA THE RENTAL INCOME DECLARED BY THE ASSESSEE WORKED OUT TO 9.3% OF THE OCCUPANCY CAPACITY. THE ASSESSING OFFICER ESTIMATE D THE RENTAL INCOME AT 25% OF THE CAPACITY AND IT RESULTED IN ADDITION OF RS. 5 80 30 5/-. THE LD. CIT(A) IN THE APPELLATE PROCEEDINGS FIXED THE ESTIMATE UNIFORMLY AT 20% FO R BOTH THE HOTELS. THUS THE LD CIT(A) CONFIRMED THE ADDITION IN RESPECT OF CHARUMM OODU HOTEL AND GAVE PARTIAL RELIEF OF 5% OF THE CAPACITY IN RESPECT OF KADAPRA HOTEL. THE ASSESSEE IS AGGRIEVED BY THE DECISION OF THE LD. CIT(A) IN CONFIRMING THE ADDITI ONS IN RESPECT OF BOTH THE HOTELS. THE REVENUE IS AGGRIEVED BY THE DECISION OF THE LD. CIT (A) IN GRANTING PARTIAL RELIEF IN RESPECT OF HOTEL INDRAPRASTHA KADAPRA. 5.1. BEFORE US THE LD. COUNSEL FOR THE ASSESSEE SUB MITTED THAT THE ASSESSEE COULD NOT GET HIGHER OCCUPANCY RATE SINCE BOTH THE HOTELS AR E LOCATED IN VILLAGES. HE FURTHER SUBMITTED THAT THE ASSESSEE WAS INTERESTED IN RUNNI NG A BAR AND SINCE THE BAR LICENSE WAS GRANTED ONLY TO TWO/THREE STAR RATED HOTELS TH E ASSESSEE WAS CONSTRAINED TO CONSTRUCT THE HOTELS IN RURAL AREAS WHICH WAS THE CAUSE FOR LOW OCCUPANCY RATE. ACCORDINGLY HE SUBMITTED THAT THE LD. CIT(A) WAS NO T JUSTIFIED IN CONFIRMING THE IMPUGNED ADDITIONS WITHOUT APPRECIATING THE FACTUAL ASPECTS MENTIONED ABOVE. I.T.A. NOS.64 & 12/COCH/2013 5 5.2 ON THE CONTRARY THE LD. DR SUBMITTED THAT THE OCCUPANCY RATE SHOWN BY THE ASSESSEE WAS VERY MUCH LOW AND A BUSINESS MAN CANNO T SURVIVE WITH SUCH A LOW OCCUPANCY RATES. HENCE THE ASSESSING OFFICER WAS C ONSTRAINED TO ESTIMATE THE OCCUPANCY RATE AT 20% FOR CHARUMMOODU HOTEL AND 25% FOR KADAPRA HOTEL. THE ESTIMATE MADE BY THE AO IS ALSO AT LOWER LEVELS WH ICH APPARENTLY SHOWS THAT THE AO HAS CONSIDERED THE LOCATION OF THESE HOTELS ALSO WH ILE ESTIMATING THE OCCUPANCY RATES. THE LD. DR SUBMITTED THAT THE LD. CIT(A) WAS NOT JU STIFIED IN REDUCING THE ESTIMATION FROM 25% TO 20% IN RESPECT OF HOTEL INDRAPRASTHA K ADAPRA. 5.3 WE HAVE HEARD THE RIVAL CONTENTIONS AND CAREFUL LY PERUSED THE RECORD. ADMITTEDLY THE ASSESSEE HAS DECLARED THE OCCUPANCY RATE OF THE HOTELS LOCATED AT CHARUMMOODU AND KADAPRA AT THE RATE OF 2.3% AND 9.3 % RESPECTIVELY. AS SUBMITTED BY LD D.R IT IS VERY DIFFICULT FOR A BUSINESS MAN TO SUSTAIN HIS BUSINESS ACTIVITIES WITH SUCH A LOW OCCUPANCY RATE. HENCE WE AGREE WITH TH E LD D.R IN THIS REGARD. THE ONLY CONTENTION OF THE ASSESSEE IS THAT THESE HOTELS ARE LOCATED IN VILLAGES. HOWEVER THE LD CIT(A) HAS POINTED OUT THAT THE COMMERCIAL TAX OFFI CER (LUXURY TAX) HAS DETECTED CERTAIN DISCREPANCIES AND HENCE HE HAS MADE CERTAIN ADDITIONS TO THE ROOM RENT DECLARED BY THE ASSESSEE. HENCE IN OUR VIEW THE TAX AUTHORITIES ARE JUSTIFIED IN ENHANCING THE OCCUPANCY RATE AND ACCORDINGLY MAKING ADDITIONS. WE NOTICE THAT THE AO HAS TAKEN INTO ACCOUNT THE LOCATIONAL DISADVANTAGE OF THE HOTELS AND HENCE HAS ESTIMATED THE RATE OF OCCUPANCY AT 20%/25%. THE LD . CIT(A) HAS DETERMINED THE OCCUPANCY RATE UNIFORMLY AT 20% FOR BOTH THE HOTELS . THE REVENUE IS ASSAILING THE DECISION OF LD. CIT(A) IN REDUCING THE ESTIMATE IN RESPECT OF KADAPRA HOTEL. WE NOTICE THAT THE LD CIT(A) HAS ONLY REVISED THE ESTIMATE MA DE BY THE AO. SINCE THERE IS ONLY SUBSTITUTION OF ESTIMATE WE DO NOT FIND IT NECESSA RY TO INTERFERE WITH THE DECISION OF LD CIT(A) ON THIS ISSUE. 6. THE NEXT ISSUE RELATES TO THE ADDITION TOWARDS S ALE OF LIQUOR WHICH WAS DELETED BY THE LD CIT(A). THE AO NOTICED THAT THE ASSESSEE HAS PAID TURNOVER TAX OF RS.49 11 969/-. HE NOTICED THAT THE TURNOVER TAX I S LEVIED @ 10% ON SALES AND A I.T.A. NOS.64 & 12/COCH/2013 6 FURTHER 1% IS COLLECTED TOWARDS CESS. THE AO ACCO RDINGLY PROCEEDED TO WORK OUT THE SALES TURNOVER ON THE BASIS OF TAX AMOUNT STATED AB OVE. THE TURNOVER WORKED OUT TO RS.4 86 33 356/- WHERE AS THE ASSESSEE HAD REPORTE D A TURNOVER OF RS.4 75 65 669/-. WHEN THIS FACT WAS CONFRONTED WITH THE ASSESSEE HE SUBMITTED THAT HE HAS MADE EXCESS PAYMENT. HE ALSO FURNISHED A LETTER DATED 1 6.12.11 SUBMITTED TO THE COMMERCIAL TAX OFFICER SEEKING REFUND OF EXCESS PAY MENT. THE AO NOTICED THAT THE ASSESSEE HAS WRITTEN THE ABOVE SAID LETTER ONLY AFT ER HE SOUGHT FOR CLARIFICATION. ACCORDINGLY THE AO HELD THAT THE LETTER WRITTEN TO COMMERCIAL TAX OFFICER DOES NOT CLARIFY THE ISSUE. ACCORDINGLY THE AO ADDED THE D IFFERENCE IN TURNOVER AMOUNTING TO RS.10 67 707/- TO THE TOTAL INCOME OF THE ASSESSEE. 6.1 BEFORE LD CIT(A) THE ASSESSEE SUBMITTED TH AT HE HAS PAID THE TURNOVER TAX ON COMPOUNDED BASIS @ 135% OF THE PURCHASE VALUE. THE LD CIT(A) EXAMINED THE NEW EXPLANATION GIVEN BY THE ASSESSEE AND WAS SATISFIED WITH THE SAME. ACCORDINGLY HE DELETED THE ADDITION OF RS.10 67 707/- WITH THE FOL LOWING OBSERVATIONS:- 12. A COPY OF LETTER WRITTEN TO THE COMMERCIAL TA X OFFICER MAVELIKARA BY THE ASSESSEE GIVING THE DETAILED WORKING OF THE TURNOVE R TAX ON THE BASIS OF PURCHASE TURNOVER HAS ALSO BEEN ENCLOSED WITH THIS LETTER. A REQUEST HAS BEEN MADE IN THIS LETTER FOR REFUND OF EXCESS PAYMENT OF RS.1 67 573/-. AS PER THE DETAILS GIVEN IN THESE DOCUMENTS THE TOTAL PURCHASE OF IMF L IN RESPECT OF HOTEL AT CHARUMMOODU DURING THE YEAR IS RS. 3 46 71 243/-. AS PER THE SALES TAX RULES SALES HAVE BEEN ESTIMATED AT 135% OF THE GROSS PURC HASES WHICH HAS BEEN SHOWN AS RS. 4 68 06 179/-. THE TURNOVER TAX @ 10% AND CESS @ 1% HAS BEEN WORKED OUT AT RS. 46 80 618/- AND RS. 46 806/- RESP ECTIVELY. THEREFORE THE TOTAL AMOUNT OF TAX HAS BEEN SHOWN AT RS. 47 27 424 /-. THE ASSESSEE HAS MADE A CLAIM OF REFUND OF RS. 1 67 573/- AS AN AMOUNT OF RS. 48 94 997/- WAS PAID AS TURNOVER TAX PLUS CESS. THE ASSESSEE HAS ALSO FUR NISHED A COPY OF PERMISSION LETTER DATED 2.5.2008 FOR PAYMENT OF TAX U/S. 7 OF KERALA GENERAL SALES TAX RULES 1963 FOR THE YEAR UNDER CONSIDERATION FROM THE COMM ERCIAL TAX OFFICER MAVELIKARA EVEN BEFORE THE DATE OF ISSUE OF NOTICE U/S. 143(2). FURTHER IT IS SEEN THAT THE AMOUNT OF PURCHASE SHOWN IN THIS DOCU MENT MATCHES WITH THE AMOUNT OF PURCHASE AS PER THE TRADING P & L A/C. THESE FACTS SHOW THAT THE ASSESSEE HAD PAID TURNOVER TAX PLUS CESS ON ESTIMAT ED SALES WORKED OUT AS 135% OF THE PURCHASES AND ESTIMATED SALES AS SUCH A RE NOT THE ACTUAL SALES OF THE ASSESSEE. THEREFORE THE ASSESSING OFFICER WAS NOT JUSTIFIED IN WORKING OUT THE SALES ON THE BASIS OF TURNOVER TAX PLUS CESS PA ID BY THE ASSESSEE. FURTHER NO DISCREPANCY IN THE BOOKS OF ACCOUNTS BILLS AND VOUCHERS HAS BEEN POINTED OUT I.T.A. NOS.64 & 12/COCH/2013 7 BY THE ASSESSING OFFICER. THEREFORE THE ADDITION OF RS. 10 67 707/- MADE BY THE ASSESSING OFFICER IS DELETED. 6.2 WE HAVE HEARD THE PARTIES ON THIS ISSUE. W E NOTICE THAT THE ASSESSEE HAS GIVEN AN ALTOGETHER NEW EXPLANATION BEFORE LD CIT(A) AND THE FIRST APPELLATE AUTHORITY HAS ALSO FOUND THE SAME TO BE CORRECT ON THE BASIS OF R ECORDS PRODUCED BEFORE HIM. HOWEVER WE NOTICE THAT THE LD CIT(A) DID NOT CONFR ONT THE NEW EXPLANATION OF THE ASSESSEE WITH THE AO AND THE SAME RESULTS IN VIOLAT ION OF RULE 46A OF THE INCOME TAX RULES. HENCE IN OUR VIEW THIS ISSUE REQUIRES EX AMINATION AT THE END OF THE AO. ACCORDINGLY WE SET ASIDE THE ORDER OF LD CIT(A) ON THIS ISSUE AND RESTORE THE SAME TO THE FILE OF THE AO WITH THE DIRECTION TO EXAMINE TH E ISSUE AFRESH BY EXAMINING THE RECORDS OF THE ASSESSEE VIS-A-VIS EXPLANATION GIVEN BEFORE THE LD CIT(A) AND ALSO ANY OTHER INFORMATION/EXPLANATIONS GIVEN BY THE ASSESSE E AND TAKE APPROPRIATE DECISION IN ACCORDANCE WITH LAW. 7. IN THE RESULT BOTH THE APPEALS FILED BY THE ASS ESSEE AS WELL AS REVENUE ARE TREATED AS PARTLY ALLOWED FOR STATISTICAL PURPOSES. PRONOUNCED ACCORDINGLY ON 04-10-2 013. SD/- SD/- (N.R.S.GANESAN) (B.R.BASKARAN) JUDICIAL MEMBER ACCOUNTANT MEMBER PLACE: KOCHI DATED: 4TH OCTOBER 2013 GJ COPY TO: 1. SHRI K.P. INDRABALAN INDRAPRASTHAM CHARUMMOODU MAVELIKARA. 2. THE ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE -1 THIRUVALLA. 3. THE COMMISSIONER OF INCOME-TAX(APPEALS) TRIVAND RUM. 4. THE COMMISSIONER OF INCOME-TAX TRIVANDRUM. 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. NOS.64 & 12/COCH/2013 8