GOVERNMENT OF INDIA

MINISTRY OF FINANCE
INCOME TAX DEPARTMENT
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX
CIRCLE 1(1) GURGAON

To,
BIHARI JI CONTAINERS PRIVATE LIMITED
4/118 SECTOR 4, SECTOR 4
GURUGRAM 122001,Haryana
*ITBA100019017996*

India

PAN: AY: Order No: Dated:

AAECB8489P 2017-18 ITBA/AST/S/143(3)/2019-20/1019649701(1) 01/10/2019

Name of the assessee BIHARI JI CONTAINERS PRIVATE LIMITED

Address of the assessee 4/118 SECTOR 4, SECTOR 4, GURUGRAM
122001, Haryana, India
Status COMPANY
Range/Circle/Ward CIRCLE 1(1) GURGAON
Resident/Resident but not Ordinary resident/ Resident
Non-resident
Date of Hearing 17/09/2018, 24/09/2018, 15/10/2018, 08/02/2019,
26/04/2019, 15/07/2019, 15/07/2019, 07/08/2019,
13/09/2019
Section/Sub-section under which assessment is 143(3)
made
Date of Order 01/10/2019

ASSESSMENT ORDER

In this case, return declaring an income of Rs 83,86,700/- was filed by the

assessee on 31.10.2017.

2. Subsequently, the case was selected for scrutiny under CASS. Statutory
notice u/s 143(2) was issued on 07.09.2018 through ITBA which was duly served
upon the assessee. Further, notice u/s 142(1) were issued through ITBA from time to
time during the assessment proceedings and were duly served on assessee. In
response to the said notices, assessee filed submission through e-proceedings from
time to time and furnished the details which are scrutinized on test check basis
Requisite information furnished by the assessee have been examined and placed on
the record. Assessment in this case is finalized on the following observation.

Note: If digitally signed, the date of digital signature may be taken as date of document.
,HSIIDC BUILDING, VANIJYA NIKUNJ, UDHYOG VIHAR, PHASE-V, GURGAON, Haryana, 122001
Email: gurgaon.dcit1.1@incometax.gov.in, Office Phone:01244040931

* The Notice/Letter/Order No. mentioned above may be treated as DIN for the purpose of procedure for issuance of Income Tax Notice
prescribed by Circular No.19/2019 dt. 14 August 2019.
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3. DISALLOWANCE U/S 14A

On perusal of the balance sheet of the assessee, it is observed that the assessee
has shown an investment to the tune of Rs 19,00,000/- in its balance sheet in the
name of Tirupati Containers Pvt Ltd which is capable of yielding exempt income. On
further examination and verification of financials of the assessee, it is found that the
assessee has not made any disallowance u/s 14A read with rule 8D. Therefore the
assessee was show-caused as vide Notice dated 02.08.2019 as to why no
disallowance u/s 14A not be made in respect of investment in Tirupati Containers Pvt
Ltd. In response to this, the assessee filed its reply dated 14.08.2019 wherein it has
stated that the investment of Rs 19 lacs in shares of M/s Tirupati Containers
Pvt ltd has not been made by the company in the F.Y. 2016-17. Instead, this
investment pertains to the financial year 2015-16. Moreover, neither any
expenditure has been incurred nor any exempted income earned thereon
during the financial year 2016-17 and therefore making any disallowance on
this account does not arise.

I have considered the submission of the assessee but did not find it acceptable
because:

(i) The provision of sub-section(1) of section 14A provides;

14A. For the purposes of computing the total income under this chapter,
deduction shall be allowed in respect of expenditure incurred by the assessee
in relation to income which does not form part of the total income under this
Act.”

(ii) It is pertinent to mention here that even if no exempt income is actually

earned or received during the year in any form whatsoever, the provisions of section
14A r. w. Rule 8D apply where any such investment is made wherefrom such type of
income might be generated either in the past or in the future years(s).

(iii) Circular no. 5 of 2014 dated 11.02.2014 further clarified that the expenses
which are relatable to earning of exempt income have to be considered for
disallowance, irrespective of the fact whether any such income has been earned
during the financial year or not. The para. 6 of the Circular reads as follows:

“.... Thus, in light of above, Central Board of Direct Taxes, in exercise of its
powers under section 119 of the Act hereby clarifies that Rule 8D read with
Section 14A of the Act provides for disallowance of the expenditure even
where taxpayer in a particular year has not earned any exempt Income...”

Therefore, assessees claim that assessee has not earned any exempt income during

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the year therefore, no disallowances can be made is not acceptable.

(iv) Further, as per the provisions of I. T. Act, 1961 the disallowance should be
computed as per provisions of Rule 8D of the I. T. Act, 1962 but nowhere in the
prescribed rule it is mentioned that strategic investment is not to be included while
computing the disallowance. The investment which can yield exempt income that is
required to be taken in consideration while computing the disallowance. It is difficult
to accept that assessee can earn exempt income without incurring any expenses
whatsoever including management or administrative expenses as investment
decisions are generally taken in a planned manner. The term” expenditure” occurring
in Section 14A would take in its sweep not only direct expenditure but also all forms
of expenditure regardless of whether they are fixed, variable, direct, indirect
,administrative ,managerial or financial. On this issue, after comprehensive
consideration of all the relevant aspects including the provisions of law, the Chennai
Bench of ITAT in Southern Petro Chemicals Industries (3 SOT 157)had held that
proportionate management expenses are required to be deducted while computing
the exempt income by way of dividend. In the case of ACIT-Range 10(1)vs. Citicorp
Finance (India) Ltd.(108 ITD 457), the Hon’ble ITAT, Mumbai C Bench, had held that
all expenses connected with the exempt income have to be disallowed under section
14A regardless of whether they are direct or indirect, fixed or variable & managerial
or financial in accordance with law”.

(v) As regards the applicability of Rule 8D of the I.T. Rules, the Hon’ble ITAT in
the case of Citicorp Finance(I)Ld. (supra)held that “.. it is no longer open to the
Assessing Officer to apply his discretion in computing the disallowance or make ad
hoc disallowance u/s.14A….”as”…. sub-sections (2) & (3)Seek to achieve the
underlying objection of section 14A(I) that any expenditure incurred in relation to
exempt income should not be allowed deduction…”. While concluding the Hon’ble
ITAT held that “….. the provisions for quantification of disallowance as contained in
sub-sections(2) & (3) of section 14A are procedural & therefore, apply to all pending
matters…” and that “… the aforesaid provisions have retrospective operation &
therefore, would apply to all pending matters…”.In this context, it may be stated here
that a special Bench of ITAT, Mumbai constituted in the case of ITO vs. Daga capital
Management Private Limited, vide its order dated 20.10.2008 in ITA No.
8056/Mum/03, has also affirmed the decision of the Divisional Bench in the case of
Citicorp Finance (I) Ltd (supra)about the application of section 14A & the Sub-
sections therein inserted w.e.f. 01.04.2007.

(vi) Reliance is also placed on the recent decision of Apex Court in the case of
M/s Maxopp Investment Ltd Vs. CIT (Civil Appeal No. 104-109 of 2015) 91
taxmann.com 154(SC) wherein it was held that the argument that S. 14A & Rule 8D

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will not apply if the “dominant intention” of the assessee was not to earn dividends
but to gain control of the company or to hold as stock-in-trade is not acceptable.

The insertion of section 14A with retrospective effect, ie from 01.04.1962, is a serious
attempt on the part of the Legislature not to allow deduction in respect of any
expenditure incurred by the assessee in relation to income, which does not form part
of the total income under the Act, against the taxable income. The Legislature has
further clarified its intention that the expenses incurred can be allowed only to the
extent they are relatable to the earning of the taxable income. The legislature has,
therefore, made an attempt to curb the practice used to reduce the tax payable on
the no exempt income by debiting the expenses incurred to earn the exempt income
against the taxable income. The language used by the legislature in the statute made
it amply clear that Legislature was well aware that the deduction of expenses in
respect of exempt income were being claimed in full, against the taxable income. It
was, therefore, clarified that expenses incurred can be allowed only to the extent they
are relatable to earning of the taxable income. Nature of the expenses incurred may,
therefore, be related partly to the exempt income, & partly to the taxable income, but
the intention of the Legislature is to allow the expenses only to the extent they are
relatable to the earning of taxable income. It has been clarified unambiguously that in
computing the total income, no deduction shall be allowed in respect of expenditure
incurred by the assessee against the income which is claimed as exempt from tax.
Circular 14 of 2001, dated 22.11.2001, & circular No 8 of 2002, dated 27.8.2002 have
also explained the provisions wherein it has been clarified that no expenses relatable
to an income exempt from tax would be allowed as a deduction.

Keeping in view the facts of the case & in view of the provisions of sec 14A r.w.r. 8D,
I am not satisfied with the genuineness of the claim made by the assessee with
regard to the expenses related to earning of the exempt income. As the
accounts prepared by the assessee does not give true picture about the correctness
of expenditure with regard to the exempt income, provision of section 14A is required
to be invoked to work out the disallowance u/s 14A as per rule 8D of the I.T. Rules
1962. The assessee was required to explain why disallowance of expenditure should
not be make u/s.14A of the I.T. Act in accordance with the computation prescribed
under Rule 8D of the I.T. Rules, 1961.

In view of the above discussion it is clear that disallowance u/s 14A is warranted in
this case. On going through computation of the assessee it is noticed that the
assessee has not computed the disallowance as per Rule 8D(iii), therefore, I hereby
compute the disallowance u/s 14A r.w.s. 8D which is as follows:

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Month Opening Balance Closing Balance(Rs Monthly

(Rs) Average(Rs)

April 2016 19,00,000/- 19,00,000/- 19,00,000/-

May 2016 19,00,000/- 19,00,000/- 19,00,000/-

June 2016 19,00,000/- 19,00,000/- 19,00,000/-

July 2016 19,00,000/- 19,00,000/- 19,00,000/-

August 2016 19,00,000/- 19,00,000/- 19,00,000/-

September 2016 19,00,000/- 19,00,000/- 19,00,000/-

October 2016 19,00,000/- 19,00,000/- 19,00,000/-

November 2016 19,00,000/- 19,00,000/- 19,00,000/-

December 2016 19,00,000/- 19,00,000/- 19,00,000/-

January 2016 19,00,000/- 19,00,000/- 19,00,000/-

February 2016 19,00,000/- 19,00,000/- 19,00,000/-

March 2016 19,00,000/- 19,00,000/- 19,00,000/-

Sum of monthly Average(Rs) 2,28,00,000/-

Annual Average Value (Rs) 19,00,000/-

1% of annual average value (Rs) 19,000/-

Accordingly, Rs. 19,000/- is disallowed and added back to the total income of the

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assessee invoking the provisions u/s 14A r.w.r. 8D.

[Disallowance: Rs. 19,000]

I am satisfied that the assessee has under reported his income by misrepresenting
the facts by not making disallowance u/s 14A to the extent of Rs.19,000/.
Accordingly, penalty proceedings u/s 270A(1) r.w.s270A(9)(a) is initiated separately
for under reporting the income and misrepresentation of facts.

4. Addition u/s 36(1)(va):

During the course of assessment proceedings, it was seen that amount of PF deposited
(employee contribution) as per Col. 20 (b) of Tax Audit Report in Form 3CD after the due
date under the relevant Act was Rs.1,24,697/-, However, no disallowance has been made in
the computation of income by the assessee in this regard. Vide show-cause Notice dated
02.08.2019, the assessee was show caused as to why disallowance for not paying PF
payment in time be made. In response, the assessee filed reply dtd. 14.08.2019 as under :

“It is true that some of the statutory dues like ESIC & PF have been paid after the due date
of payment as indicated in your notice dated 02.08.2019. However, SLP against the
judgment of Rajasthan High Court in a case CIT Vs Rajasthan Steel Beverage Corporation
Ltd.(2017) 84 taxmann.com 173(raj) has been rejected by SC(250 Taxmann 16) wherein
payment of such dues made after the due date but before due date of submission of income
tax return has been allowed. In view of above no disallowance be made on this account.”

The above reply of the asssessee has been perused but was not found tenable for the
reason discussed here under:

As per Section 36(1)(va) of the Income Tax Act, 1961 “Any sum received by the assessee
from any of his employees to which the provisions of sub-clause (x) of clause (24) of
Section 2 apply, if such sum is credited by the assessee to the employee’s account in the
relevant fund or funds on or before the due date.

Explanation- For the purpose of this clause, “due date" means the date by which the
assessee is required as an employer to credit an employee's contribution to the
employee’s account in the relevant fund under any Act, rule, order or notification issued
there under or under any standing order, award, contract of service or otherwise;]

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Hon‘ble High Court of Gujarat in case of Commissioner of Income-Tax vs Gujarat State

Road Transport Corporation dated 26.12.2013 gave its decision in favor of the revenue
and held that “since sums were not credited by the respective assessee to the employee’s
account in the relevant fund or funds on or before the due date as per expln. to sec.
36(1)(va) i.e., date by which the concerned assessee was required as an employer to
credit the employee’s contribution to the employee's account in the provident fund under
the Provident Funds Act and/or in the ESI Fund under the ESI Act, disallowance u/s
36(1)(va) was required to be made.”

Hon’ble High Court of Kerala in case of Commissioner of Income Tax vs Merchem Limited
dated 08-09-2015 gave its decision in favor of the revenue and held that “The assessee
was not entitled to get deduction of the contributions received from the employees if paid
on or before the filing of the return u/s 139(1). The assessee was entitles to get the
deduction on the amounts as provided u/s 36(1)(va) only if the amounts so received from
the employees were paid within the due date as provided under the relevant statute.”

Also, CBDT Circular No. 22/2015 dated 17.12.2015 says as under:-

“As per Section 43B of the Act certain deductions are admissible only on payment basis.
It is observed by the Board that some field officers disallow employer’s contributions to
provident fund or superannuation fund or gratuity fund or any other fund for the welfare of
employees, by invoking the provisions of Section 43B of the Act, if it has been paid after
the ‘due dates’, as per the relevant Acts.

2. The matter has been examined in light of the judicial decisions on this issue. In the
case of Commissioner vs. Alom Extrusions Ltd. [2009] 185 TAXMAN 416 (SC), the Apex
Court held that the amendments made in Section 43B of the Act i.e. deletion of second
proviso and amendment in the first proviso, being curative in nature are retrospectively
applicable from 1-4-1988. It further held that by deleting the second proviso to Section
43B of the Act and amending the first proviso, the contribution to welfare funds have been
brought at par with the other duty, cess, fee etc. Thus, the proviso is equally applicable to
the welfare funds also. Therefore, the deduction is allowable to the employer assessee if
he deposits the contribution to welfare funds on or before the due date of filing of return of
income.

3. Accordingly, w.e.f. 1.4.1988, the settled position is that if the assessee deposits any
sum payable by it by way of tax, duty, cess or fee by whatever name called under any law

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for the time being in force, or any sum payable by the assessee as an employer by way of
contribution to any provident fund or superannuation fund gratuity fund or any other fund
for the welfare of employees, on or before the ‘due date ’ applicable in his case for
furnishing the return of income under section 139(1) of the Act, no disallowance can be
made under section 43B of the Act.

4. In the light of the Supreme Court’s decision in the matter, the issue is well settled.
Accordingly, the Board has decided that no appeal may henceforth be filed on this ground
by the officers of the Department and appeals already filed, if any, on this ground before
Courts/ Tribunals may be withdraw upon. This may be brought to the notice of all
concerned.

5. It is clarified that this circular does not apply to claim of deduction relating to
employee’s contribution to welfare funds which are governed by Section 36(1)(va) of the
IT Act.”

On the basis of above mentioned judgments, CBDT Circular and facts of the case of the
assessee, the delay in deposit of PF amounting to Rs.1,24,697/- after the due date of the
relevant Act is being disallowed and added back to the income of the assessee u/s
36(l)(va).

[Disallowance: Rs. 1,24,697/-]

I am satisfied that the assessee has under reported his income by misrepresenting
the facts by not making disallowance u/s 36 to the extent of Rs.1,24,697/.
Accordingly, penalty proceedings u/s 270A(1) r.w.s270A(9)(a) is initiated separately
for under reporting the income and misrepresentation of facts.

6. Addition u/s 68

During the course of assessment proceedings, it was seen that the assessee company has
taken unsecured loan of Rs 3.5 crores from CCL International Pvt Ltd. A search operation
was conducted by the Investigation Wing Kolkata and Kolkata wing unearthed the racket of
generation of bogus capital gain/loss and as per report provided by Investigation Wingh,
Kolkata, CCL International Pvt Ltd (Scrip code 531900 and Scrip Name : CCLINTER) has
been identified as on of such companies. Therefore, a show-caused as to why Rs 3.5 crorre
may not be added to your income from unexplained sources u/s 68 of the Income Tax
Act,1961. In response to the ibid notice, the assessee company field its reply dated

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23.09.2019 and the relevant portion of the same is reproduced below :

“M/s CCL International Ltd. Is engaged in construction of road activities in India and
was awarded Govt. Contract of more than 50 cr in the state of Meghalaya and
completed work of more than 27 crore during the financial year 2016-17 as per audited
balance sheet.

M/s CCL International Ltd received payment of Rs 6,13,09,162/- on 04.04.2016 and Rs

3,22,20,156/- on dated 06.06.2019 from PWD Megalaya towards payment of bills of
road construction and credited to State Bank of India Ghaziabad. From State Bank of
India fund of Rs 6,13,09,162/- transfer to Oriental Bank of Commerce on 04.04.2016
and Rs 3,22,20,156/- transferred on 07.04.2016

M/s CCL International Ltd transfer Rs 3,50,00,000/- to their current account with HDFC
Raj Nagar to make a temporary loan of Rs 3.5 crore on 11.04.2016 to our company
through bank transfer.

Out company have repaid the temporary loan to M/s CCL International on 20th April
2016 of Rs 1.75 crore and on 22.04.2016 on 22.04.2016 Rs 1.75 crore thorugh banking
channel and a/c was squared up.

Interest has been paid Rs 1,37,774/- after deduction of TDS of Rs 15,308/-.

The above reply of the assessee has been considered and found not tenable due to
following reasons :-

Analysis of CCL International Limited

CCL International Limited is a company registered with ROC Delhi. This company was incorporated
on 04.06.1991. M/s CCL International Ltd Corporate Identification Number is (CIN)
L26940DL1991PLC044520. The company claims to be in the business of Comm. Trading &
Distribution. The shares of the company are traded on Bombay Stock Exchange (BSE) under the

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Security ID: CCL International and the Security Code is 531900.

The financials of the company are as follows: Balance sheet

Mar 16 Mar 15 Mar 14 Mar 13

12 mths 12 mths 12 mths 12 mths 12 mths

EQUITIES AND LIABILITIES

SHAREHOLDER'S FUNDS

Equity Share Capital 19.19 19.19 19.19 19.19 19.19

Total Share Capital 19.19 19.19 19.19 19.19 19.19

Reserves and Surplus 19.10 17.69 16.75 16.31 15.12

Total Reserves and Surplus 19.10 17.69 16.75 16.31 15.12

Total Share holders Funds 38.29 36.88 35.94 35.51 34.32

NON-CURRENT LIABILITIES

Long Term Borrowings 2.66 3.36 3.15 1.02 2.30

Deferred Tax Liabilities [Net] 0.63 0.52 0.12 0.01 0.00

Total Non-Current Liabilities 3.28 3.88 3.27 1.02 2.30

CURRENT LIABILITIES

Short Term Borrowings 7.64 5.10 7.90 3.72 10.31

Trade Payables 11.52 14.28 19.38 16.73 11.21

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Other Current Liabilities 2.36 2.20 2.38 1.75 1.75

Short Term Provisions 0.29 0.86 0.86 1.09 0.78

Total Current Liabilities 21.81 22.44 30.51 23.28 24.05

Total Capital And Liabilities 63.39 63.20 69.72 59.81 60.67

ASSETS

NON-CURRENT ASSETS

Tangible Assets 20.62 21.24 18.86 10.31 9.35

Fixed Assets 20.62 21.24 18.86 10.31 9.35

Non-Current Investments 4.03 4.91 4.31 3.71 0.03

Deferred Tax Assets [Net] 0.00 0.00 0.00 0.00 0.01

Long Term Loans And Advances 3.81 5.57 10.87 14.82 7.41

Other Non-Current Assets 0.01 0.01 0.02 0.04 0.08

Total Non-Current Assets 28.47 31.73 34.05 28.89 16.87

CURRENT ASSETS

Inventories 10.13 15.03 12.11 13.04 6.95

Trade Receivables 13.83 1.58 11.93 3.45 9.44

Cash And Cash Equivalents 4.75 7.25 4.52 4.26 9.47

Short Term Loans And Advances 6.21 7.60 7.07 10.14 17.91

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OtherCurrentAssets 0.00 0.01 0.03 0.03 0.03

Total Current Assets 34.92 31.46 35.67 30.93 43.80

Total Assets 63.39 63.20 69.72 59.81 60.67

OTHER ADDITIONAL INFORMATION

CONTINGENT LIABILITIES, COMMITMENTS

Contingent Liabilities 3.45 1.24 1.91 6.27 6.27

CIF VALUE OF IMPORTS

EXPENDITURE IN FOREIGN EXCHANGE

Expenditure In Foreign Currency 0.02 22.10 2.02 0.00 0.00

REMITTANCES IN FOREIGN CURRENCIES FOR DIVIDENDS

Dividend Remittance In Foreign Currency - - - - -

EARNINGS IN FOREIGN EXCHANGE

FOB Value Of Goods - - - - -

Other Earnings - - - - -

BONUS DETAILS

Bonus Equity Share Capital - - - - -

NON-CURRENT INVESTMENTS

Non-Current Investments Quoted Market Value - 2.85 2.85 2.85 0.00

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Non-Current Investments Unquoted Book Value 1.23 1.47 1.47 0.87 0.03

CURRENT INVESTMENTS

Current Investments Quoted Market Value - - - - -

Current Investments Unquoted Book Value -

Profit/Loss Before Exceptional, ExtraOrdinary 1.25 1.51 1.39 2.30 0.97

Items And Tax

Profit/Loss Before Tax 1.25 1.51 1.39 2.30 0.97

Tax Expenses-Continued Operations

Current Tax 0.29 0.30 0.28 0.53 0.22

Deferred Tax 0.11 0.18 0.12 0.02 -0.01

Tax For Earlier Years 0.00 0.00 0.00 0.00 -0.16

Total Tax Expenses 0.40 0.48 0.40 0.55 0.05

Profit/Loss After Tax And Before ExtraOrdinary 0.85 1.03 0.99 1.75 0.92
Items

Profit/Loss From Continuing 0.85 1.03 0.99 1.75 0.92

Operations

Profit/Loss For The Period 0.85 1.03 0.99 1.75 0.92

Mar 16 Mar 15 Mar 14 Mar 13 Mar 12

12 12 mths 12 mths 12 mths 12 mths

mths

OTHER ADDITIONAL INFORMATION

EARNINGS PER SHARE

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Basic EPS (Rs.) 0.44 0.11 0.10 0.18 0.10

Diluted EPS (Rs.) 0.44 0.11 0.10 0.18 0.10

VALUE OF IMPORTED AND INDIGENIOUS RAW

MATERIALS

STORES, SPARES AND LOOSE TOOLS

DIVIDEND AND DIVIDEND PERCENTAGE

Equity Share Dividend 0.00 0.48 0.48 0.48 0.48

Tax On Dividend 0.00 0.08 0.08 0.08 0.08

Equity Dividend Rate (%) 0.00 3.00 3.00 3.00 3.00

Capital Structure (CCL International)

Period Instrument Authorized Issued -PAIDUP-

Capital Capital

From To (Rs. cr) (Rs. cr) Shares (nos) Face Value Capital

2015 2016 Equity Share 33 19.19 19192600 10 19.19

2014 2015 Equity Share 33 19.19 95963000 2 19.19

2013 2014 Equity Share 33 19.19 95963000 2 19.19

2012 2013 Equity Share 33 19.19 95963000 2 19.19

2011 2012 Equity Share 33 19.19 95963000 2 19.19

2010 2011 Equity Share 8 6.85 6772100 10 6.77

2009 2010 Equity Share 8 6.85 6772100 10 6.77

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2008 2009 Equity Share 8 6.85 6772100 10 6.77

2007 2008 Equity Share 8 6.85 6772100 10 6.77

2006 2007 Equity Share 8 6.85 6772100 10 6.77

2005 2006 Equity Share 8 6.85 6772100 10 6.77

1999 2000 Equity Share 8 6.85 6772100 10 6.77

1996 1999 Equity Share 8 6.85 6772100 10 6.77

Competition

Name Last Price Market Cap. Sales Net Profit Total Assets
(Rs. cr.) Turnover

Adani Enterpris 126.30 13,890.60 8,595.01 221.64 10,530.40

MMTC Ltd 59.20 5,920.00 11,708.36 57.06 1,874.26

Swan Energy 153.55 3,750.57 336.68 1.68 624.86

PTC India 119.25 3,529.90 14,074.83 290.87 3,757.68

STC India 173.20 1,039.20 8,048.83 -165.54 2,548.33

Ind Motor Parts 866.00 720.48 518.90 27.33 265.91

Uniphos Ent 97.50 678.07 11.26 294.72

Control Print 399.40 625.95 147.35 26.08 151.61

Sakuma Exports 204.45 335.83 2,016.18 14.60 235.32

Kothari Petro 26.75 158.32 219.48 5.84 84.63

Page 15 of 23
 AAECB8489P- BIHARI JI CONTAINERS PRIVATE LIMITED
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Sicagen India 38.10 150.77 560.57 7.44 490.41

High Ground Ent 9.00 103.60 307.53 12.54 152.56

UB Holdings 13.90 92.88 371.81 -45.13 1,282.24

Urja Global 1.25 63.40 118.15 1.03 123.11

Khaitan 18.10 8.60 15.74 2.71 93.32

JIK Industries 0.60 4.36 1.23 -1.32 -70.83

Surana Corp 1.25 3.04 234.66 -319.27 790.66

Farmax India 0.05 2.67 4.38 -2.76 33.11

CCL Internation 15.85 30.42 70.84 2.96 48.60

From the above financials it is seen that the financial worth of the company is not significant.

The information available with the department was collated and it is found that the following entities
which have purchased the shares of CCL International Limited are bogus/paper entities:

Sl. No. PAN Party Name Entry Operator QTY TRADE VALUE

1 AABCW0317N WONDER PROCON PRIVATE LIMITED DEVESH 9,99,054 22,28,31,644

WPPL UPADHYAYA

2 AADCV4653Q VISIBLE REALESTATE VENTURES P DEVESH 9,54,070 18,58,64,855

LTD VRVPL UPADHYAYA

3 AANCS7459M STREA, COMMERCIAL PVT. LTD. Bal Kishan Sikaria 7,18,895 17,98,26,978

4 AADCT2680H TERMINAL VINCOM PVT. LTD. DEVESH 9,85,435 13,59,91,326

UPADHYAYA

5 AADCB9903B BLOSSOM DEALCOM PVT. LTD. DEVESH 7,93,847 12,54,10,845

UPADHYAYA

6 AACCJ3899F JAMUNA COMMOSALES PVT. LTD. Devesh Upadhyaya 8,20,820 12,04,92,162

Page 16 of 23
 AAECB8489P- BIHARI JI CONTAINERS PRIVATE LIMITED
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7 AAECK0758J KANSABATI TRADECOM PRIVATE Devesh Upadhyaya 7,17,327 9,39,56,811

LTD.

8 AADCC7549Q COMFORT DEALCOM PVT. LTD. Devesh Upadhyaya 6,45,757 9,15,11,137

9 AAICA9848F ADOPT DEVELOPERS PVT. LTD. DEVESH 1,81,924 8,91,32,959

UPADHYAYA

10 AAECC0401A CHATURBHUJ MARKETING PRIVATE DEVESH 4,56,276 8,59,99,790

LTD. UPADHYAYA

11 AADCT3699L TEJASWANI TRADECOM PVT. LTD. DEVESH 6,75,266 8,56,06,868

UPADHYAYA

12 AAMCS8721P SINJAN OVERSEAS PVT. LTD. Devesh Upadhyaya 3,98,539 8,48,77,272

13 AAECA1364L ANKUR COMMOSALE PVT. LTD. Shiv Kumar Khemka 5,24,970 7,69,73,149

14 AAECA0160A ANAAM MERCHANTS PVT. LTD. DEEPAK 3,78,809 6,88,02,068

PATWARI

15 AABCC0486C CONTINENTAL FISCAL DEEPAK 4,07,907 5,73,33,756

MANAGEMENT LTD. PATWARI

16 AACCI3509F INOVA COMMOTRADE PVT. LTD. DEVESH 3,70,680 5,01,08,067

UPADHYAYA

17 AACCI4643Q INCREDIBLE NIRMAN PVT. LTD. DEVESH 1,01,350 4,86,96,053

UPADHYAYA

18 AAFCM8007K MIHIR ADVISORY SERVICES PRIVATE Shiv Shankar Banka 4,04,359 4,81,74,587
LTD.

19 AACCH5379Q HONOUR CONCLAVE PVT. LTD. DEVESH 98,051 4,72,92,305

UPADHYAYA

20 AAICA6180G ANAMIKA DEALERS PVT. LTD. Devesh Upadhyaya 2,25,654 4,71,90,836

21 AAFCP7362J PROGRESS INFRAESTATE PVT. LTD. Devesh Upadhyaya 1,08,272 4,40,44,939

22 AAICA6177D AMANAT SUPPLIERS LTD. DEVESH 1,98,795 4,35,59,503

UPADHYAYA

23 AABCL9804H LAGAN DEALTRADE PVT. LTD. DEVESH 83,635 3,66,93,222

UPADHYAYA

Page 17 of 23
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24 AABCL9805G LONGLIFE VANIJYA PVT. LTD. DEVESH 1,10,500 3,41,48,964

UPADHYAYA

25 AADCN1915B NILACHAL DEALERS PVT. LTD. DEVESH 68,217 3,40,42,217

UPADHYAYA

26 AAECC2019A COMPACT INFRAPROJECTS PVT. LTD. DEVESH 70,496 3,39,14,279

UPADHYAYA

27 AAECC0400B COMFORT DEALTRADE PVT. LTD. DEVESH 1,15,115 3,23,45,537

UPADHYAYA

28 AACCH4853M HEMLATA VINIMAY PVT. LTD. Devesh Upadhyaya 2,67,878 3,04,45,879

29 AADCD6338G DESIRE CONCLAVE PVT. LTD. DEVESH 61,411 2,94,20,106

UPADHYAYA

30 AAECP8118P PARADISE TRADECOM PVT. LTD. DEVESH 1,80,940 2,64,24,735

UPADHYAYA

31 AAHCM0957E MANIFOLD VINIMAY PVT. LTD. DEVESH 78,750 2,60,01,182

UPADHYAYA

32 AADCD6339H DHANBRISTI SUPPLIERS PVT. LTD. DEVESH 71,100 2,36,91,470

UPADHYAYA

33 AABCL9021C LEISURE DEVCON PVT. LTD. DEVESH 88,518 2,07,48,462

UPADHYAYA

34 AAECD1731G DADHYAN VYAPAAR PVT. LTD. DEVESH 47,500 2,00,10,012

UPADHYAYA

35 AAACE5567B ETL INFRASTRUCTURE FINANCE LTD. Deepak Patwari 1,39,905 1,98,24,908

36 AAACF5005H FUTURE ZONE ENTERTAINMENT PVT. DEEPAK PATWARI 1,47,604 1,98,07,665

LTD.

37 AARCS9176K SYPHER VINCOM PVT. LTD. ASHISH KR. 1,58,262 1,98,07,122

AGARWAL

38 AACCI4646M INVENTION ESTATE VENTURES Devesh Upadhyaya 40,000 1,96,97,053

PRIVATE LTD.

39 AAMCS3593H SHANTI GOODS PVT. LTD. Devesh Upadhyaya 1,25,652 1,80,19,664

40 AACCA5450B ASHOK INVESTORS TRUST LTD. Jagdish Prasad 76,415 1,78,04,912

Purohit

Page 18 of 23
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41 AACCJ0675M JASMINE DEALCOM PVT. LTD. Devesh Upadhyaya 1,14,500 1,68,58,145

42 AAPCS0280G SAFFRON DEVCON PVT. LTD. Devesh Upadhyaya 26,176 1,43,29,292

43 AADCV2143D VSG LEASING AND FINANCE COMPANY Shiv Shankar Banka 71,750 1,32,73,918
LTD.

44 AADCD6337K DECORUM DEVELOPERS PVT. LTD. Devesh Upadhyaya 44,550 1,29,09,300

45 AAACY2462M YASH MERCHANT PVT. LTD. Santosh Kr Shah 88,500 1,18,43,220

46 AARCS9175L SYPHER DEALTRADE PVT. LTD. ASHISH KR. 86,132 1,12,40,352

AGARWAL

47 AABCE7300H EKTA TRADECOM PVT. LTD. Devesh Upadhyaya 74,110 1,12,06,738

48 AARCS1024L SWAKSHA VYAPAAR PVT. LTD. Devesh Upadhyaya 55,000 1,07,55,484

49 AABCO4448C OVERTOP MERCANTILE PVT. LTD. Devesh Upadhyaya 62,500 98,73,985

50 AAJCA3284C ANAMIKA DEALTRADE PVT. LTD. Devesh Upadhyaya 27,774 98,46,175

51 AABCO3804E ORIGIN INFRAPROJECTS PVT LTD. Devesh Upadhyaya 26,954 97,91,600

(OIPL)

52 AACCI1440F ISHWAR VINIMAYN PVT. LTD. Devesh Upadhyaya 48,180 97,86,095

53 AADCG8615M GAYATRI DEALTRADE PVT. LTD. Devesh Upadhyaya 15,502 75,85,109

54 AAPCS5627P SUBHRASHI AGENCIES PRIVATE LTD. Devesh Upadhyaya 35,000 68,18,538

55 AADCB9902A BARBIE TRADELINK PVT. LTD. Devesh Upadhyaya 68,500 67,60,978

56 AAFCP3367H PRIMEROSE DEALCOM PRIVATE LTD. Devesh Upadhyaya 48,343 66,24,907

57 AAICA9850F ARTH DEALTRADE PVT. LTD. Devesh Upadhyaya 10,000 61,55,316

58 AADCE0017B EASH VYAPAAR PVT. LTD. Devesh Upadhyaya 45,200 51,53,853

59 AAGCP2146P PRERNA VYAPAAR PVT. LTD. Devesh Upadhyaya 25,500 50,09,000

60 AARCS9178H SYPHER DEALERS PVT. LTD. ASHISH KUMAR 63,000 47,71,667

AGARWAL

Page 19 of 23
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61 AACCH8885R HELOT PROPERTIES PVT. LTD. Devesh Upadhyaya 65,000 37,38,588

62 AARCS1023P SUBHEKSHA GOODS SUPPLIERS Devesh Upadhyaya 8,000 35,46,100

PRIVATE LTD.

63 AAGCM8618P MANKIND VINTRADE PVT. LTD. Devesh Upadhyaya 27,500 32,55,585

64 AACCH3908H HORA DEALCOMM PVT. LTD. Amit Dalmia 22,000 30,82,700

65 AACCH5378R HIGHLIFE BARTER PVT. LTD. Devesh Upadhyaya 8,500 25,49,975

66 AAECB2398D BINAPANI MERCHANDISE PVT LTD. Devesh Upadhyaya 15,000 19,00,500

67 AAPCS1110D SWIFT DEALMARK PVT. LTD. Amit Dalmia 13,000 17,65,000

68 AABCR2209N REPOSIT FINCO PVT. LTD. Devesh Upadhyaya 15,000 15,68,499

69 AADCD7139B DIKSHA MERCANTILE PVT. LTD. Devesh Upadhyaya 3,400 14,41,600

70 AAACW2797B WIZARD TRADERS PVT LTD. Ramesh Poddar 10,000 13,61,000

71 AACCH3928D HORA VANIJYA PVT LTD. AMIT DALMIA 10,000 13,30,000

72 AACCB6452E BESTWAY CONSULTANTS PVT LTD. PRAVEEN 10,000 12,87,500

AGARWAL

73 AADCK5292N KESARI NANDAN TIE UP PVT. LTD. Rajendra Bubna 10,500 12,51,000

74 AAACH2324P HILL QUEEN INVESTMENT (P) LTD. Rakesh Agarwal 9,500 12,49,250

75 AAKCA4354Q AYAAN COMMERCIAL PVT. LTD. Devesh Upadhyaya 20,645 11,35,460

76 AACCI5654H INTIME COMMOSALES PVT. LTD. Devesh Upadhyaya 5,000 9,89,818

77 AAFCR7247G RODHAN VANIJYA PVT. LTD. Devesh Upadhyaya 2,000 8,76,000

78 AAICA5455A ANANYA VINTRADE PVT. LTD. Devesh Upadhyaya 1,510 8,01,810

79 AAECS8293G SILVERSON TRACOM PVT. LTD. PAWAN KUMAR 8,000 7,41,549

JAIN

80 AAECP2470J PREFER ABASAN PVT. LTD. NARENDRA KR JAIN 5,435 5,34,865

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81 AABCB1880H BASIL TRACON PVT. LTD. PANKAJ AGARWAL 5,000 4,57,420

82 AAECA3447Q AKANSHA MERCANTILE PVT LTD. Pankaj Agarwal 4,500 4,05,175

83 AABCP8375R PCJ FINVEST PVT LTD Rakesh Agarwal 7,052 3,34,957

84 AADCD3427G DESTINY VINCOM PVT. LTD. Devesh Upadhyaya 2,100 2,64,267

85 AADCK3086C KAMDHENU VINCOM PVT. LTD. PANKAJ 1,000 1,71,000

AGARWAL

Grand Total 14,42 1,768 2,723,158,583

Departmental Enquiries have been conducted on these entities by Kolkata

Directorate of investigation and the statements of the operators who control and
manage these entities have been recorded. The operators have stated in their
statements that these entities are bogus/paper entities which are not doing any real
business and have been used for providing accommodation entries. These entities
have facilitated the entire scheme whereby the unaccounted income of the
beneficiaries of bogus LTCG/STCG has been routed into the books of the
beneficiaries in the garb of proceeds of sale of shares. The unaccounted income of
the beneficiaries has been routed into the accounts of these bogus/paper entities
and the same has been used by the bogus/paper entities for purchasing he shares
of the beneficiaries.

CONCLUSION: The above discussion establishes the following points:

The financials of CCL International Limited are very poor and the business profile
shows that the company was not engaged into any substantial activity. The business profile shows
that the company was not having any future plans which could attract investors from all over India to
invest in the company. Various Exit Providers have confirmed that they have purchased the shares of
CCL International Limited to provide entry of bogus LTCG/STCG/loss.

As part of the investigation done by investigation wing, Kolkata statements of a

number of promoters, brokers and accommodation entry providers were recorded
on oath who defined the modus operandi as well as admitted to the malicious use of
circular trading of these scripts to convert unaccounted money into accounted.

Page 21 of 23
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7. In the light of above mentioned facts and circumstances, it is concluded that

the assessee grossly failed to substantiate its claim by establishing the genuineness
of the transactions and creditworthiness of the parties. Therefore, it is inferred that
the assessee failed to discharge its basic onus which is easily casted by the law on
it. By no stretch of imagination and human probabilities the assessee could be
considered to have established its claim by furnishing the basic evidence through
which its basic onus could said to be discharge. None the less, it is pertinent to note
that the section 68 applied on the amount found to be credited to the books of the
assessee and it is the onus on the assessee to discharge its obligation to prove the
source of credits in the year in which the amount is received. Therefore, keeping the
above mentioned discussion into consideration the sum credited worth
Rs.3,50,00,000/- into the assessee books are liable to be treated as income of
the assessee. And accordingly an addition of Rs. 3,50,00,000/- is being made to the
returned income of assessee.

[Addition/s 68 of Rs.3,50,00,000-]

I am satisfied that the assessee has under reported his income by misrepresenting
the facts on account of unsecured loans to the extent of Rs.3,50,00,000/-.
Accordingly, penalty proceedings u/s 271AAC is initiated separately for undisclosed
income.

INCOME OF THE ASSESSEE FOR THE A.Y. 2017-18 IS ASSESSED AS UNDER

Returned Income : Rs 83,86,700

Disallowance(as discussed in Para 03 : Rs 19,000/-

above)

Disallowance(as discussed in para 04 : Rs 1,24,697/-

above)

Addition(As discussed in Para 07 : Rs 3,50,00,000/-

above)(to be taxed in terms of section
115BBE)

Page 22 of 23
 AAECB8489P- BIHARI JI CONTAINERS PRIVATE LIMITED
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Assessed Income : Rs 4,35,30,397/-

8. Assessed. Charge interest u/s 234A, 234B & 234C of the IT Act. Issue
requisite documents. Calculation of tax is enclosed. Give credit of prepaid taxes after
due verification. Penalty proceedings u/s 270A(1) r.w.s 270A(9)(a) and u/s 271AAC
of the Act, are being initiated separately.

SEEMA DHANKHAR
CIRCLE 1(1) GURGAON

Copy to:

Assessee

SEEMA DHANKHAR
CIRCLE 1(1) GURGAON

(In case the document is digitally signed please

refer Digital Signature at the bottom of the page)

Page 23 of 23
 GOVERNMENT OF INDIA
MINISTRY OF FINANCE
INCOME TAX DEPARTMENT
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX
CIRCLE 1(1) GURGAON

Computation Sheet

General Details
PAN AAECB8489P Assessment 2017-18
*ITBA100019018008*

Year
Name BIHARI JI Address 4/118 SECTOR 4 ,SECTOR
CONTAINERS 4 GURUGRAM 122001
PRIVATE LIMITED ,Haryana
India
Residential Resident Document ITBA/AST/S/116/2019-
Status Number 20/1019649713(1)
Order 143(3) Order Date 01/10/2019
Section

SI.
Reporting Heads Amount as per Current Order (in Rs.)
No.
HEADS OF INCOME
1. INCOME FROM HOUSE PROPERTY 0
INCOME FROM BUSINESS OR
2. PROFESSION 85,30,393
3. INCOME FROM CAPITAL GAINS 0
4. INCOME FROM OTHER SOURCES 3,50,00,000
5. INTRA HEAD ADJUSTMENTS 0
TOTAL(AFTER INTRA HEAD
6. 4,35,30,393
ADJUSTMENT) 6=(1+2+3+4)-5
LOSSES OF CURRENT YEAR SETOFF
7. 0
AGAINST 6
BROUGHT FORWARD LOSSESS SET
8. OFF AGAINST 0
8=(6-7)
GROSS TOTAL INCOME (INCLUDING
9. SPECIAL INCOME) 4,35,30,393
9=6-(7+8)
INCOME CHARGEABLE TO TAX AT
10. 3,50,00,000
SPECIAL RATE
11. DEDUCTION U/S 10A or 10AA 0

Note: If digitally signed, the date of digital signature may be taken as date of document.
,HSIIDC BUILDING, VANIJYA NIKUNJ, UDHYOG VIHAR, PHASE-V, GURGAON, Haryana, 122001
Email: gurgaon.dcit1.1@incometax.gov.in, Office Phone:01244040931

* The Notice/Letter/Order No. mentioned above may be treated as DIN for the purpose of procedure for issuance of Income Tax Notice
prescribed by Circular No.19/2019 dt. 14 August 2019.
 AAECB8489P- BIHARI JI CONTAINERS PRIVATE LIMITED
A.Y. 2017-18
ITBA/AST/S/116/2019-20/1019649713(1)

DEDUCTIONS UNDER CHAPTER VI A

TOTAL DEDUCTIONS UNDER CHAPTER
12. 0
(VIA)
TOTAL INCOME AFTER DEDUCTIONS
13. (10A/10AA AND CHAPTER VIA) 4,35,30,390
13=(9-11-12)
INCOME CHARGEABLE TO TAX AT
14. 3,50,00,000
SPECIAL RATES
INCOME CHARGEABLE TO TAX AT
15. 83,86,700
NORMAL RATES
16. NET AGRICULTURAL INCOME 0
AGGREGATE INCOME
17. 85,30,390
17=(13+16)
LOSS IN CURRENT YEAR TO BE
18. 0
CARRIED FORWARD
19. DEEMED TOTAL INCOME U/S 115JB 1,41,28,215
TAX DETAILS
TAX PAYABLE ON DEEMED TOTAL
20. 26,13,720
INCOME UNDER SECTION 115JB
21. SURCHARGE (ON ABOVE 20) 1,82,960
22. EDUCATION CESS (ON 20 +21 ABOVE) 83,900
TOTAL TAX PAYABLE U/S 115JB
23. 28,80,580
(23=20+21+22)
TAX AT NORMAL RATES (INCLUDED.
24. 25,59,117
AGRICULTURAL INCOME)
25. TAX AT SPECIAL RATES 2,10,00,000
TAX PAYABLE ON TOTAL INCOME
26. 2,35,59,117
26=(24+25)
27. SURCHARGE (ON ABOVE 26) 1,79,138
28. EDUCATION CESS on (26 + 27) 8,69,648
GROSS TAX LIABILITY
29. 2,98,57,903
(29=26+27+28)
GROSS TAX PAYABLE
30. 2,98,57,903
(HIGHER OF 23 OR 29)
CREDIT UNDER SECTION 115JAA OF
31. 0
TAX PAID IN EARLIER YEARS
TAX PAYABLE AFTER CREDIT UNDER
32. 2,98,57,903
SECTION 115JAA
TAX RELIEF
33. RELIEF U/S 90/90A 0
34. RELIEF U/S 91 0
TOTAL TAX RELIEF
35. 0
35=(33+34)
TOTAL INCOME TAX LIABILITY
NET TAX LIABILITY
36. 2,98,57,903
36=(32-35)
INTEREST PAYABLE
FOR DEFAULT IN FURNISHING THE
37. 0
RETURN ( SECTION 234A)
FOR DEFAULT IN PAYMENT OF
38. 89,55,267
ADVANCE PAYMENT ( SECTION 234 B)
FOR DEFERMENT OF ADVANCE TAX
39. 1,36,521
(SECTION 234C)
40. INTEREST U/S 234D 0
41. TOTAL INTEREST LIABILITY 90,91,788

Page 2 of 4
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41=(37+38+39+40)
AGGREGATE INCOMETAX LIABILITY
42. 3,89,49,691
42=(36+41)
PRE-PAID TAXES
43. TDS 48,485
44. TCS 29,658
45. ADVANCE TAX 5,00,000
46. SELF ASSESSMENT TAX 26,92,132
47. REGULAR TAX PAID 0
TOTAL TAXES PAID
48. 32,70,275
48=(43+44+45+46+47)
TAX PAYABLE/REFUND
AMOUNT PAYABLE /REFUND AMOUNT
49. 3,56,79,416
49=(42-48)
INTEREST U/S 244A ON CURRENT
50. 0
AMOUNT
TOTAL AMOUNT PAYABLE/ REFUND
51. AMOUNT 3,56,79,416
51= (49+50)
REFUND ALREADY ISSUED (incl. interest
52. 0
u/s 244A)
BALANCE AMOUNT
PAYABLE/REFUNDABLE
53. (incl. provisional Interest u/s 244A till 3,56,79,416
current order - if any)
53 = (51-52)
54. INTEREST U/S 220(2) CHARGED (In Rs.) 0
AMOUNT PAYABLE/REFUNDABLE
55. 3,56,79,416
55=(53+54)
DEMAND IDENTIFICATION NO AGAINST
56. 2019201737050437772C
ORIGINAL DEMAND

58. DIVIDEND DISTRIBUTION TAX (DDT) COMPUTATION

SI.
No.
Reporting Heads As per Current Order
DDT
1. DDT PAYABLE U/S 115O 0
2. SURCHARGE ON DDT 0
EDUCATION + SECONDARY & HIGHER
3. 0
EDUCATION CESS
4. TOTAL DDT PAYABLE 0
5. INTEREST U/S 115P 0
6. TOTAL DDT LIABILITY 0
7. TAX AND INTEREST PAID 0
8. NET TAX PAYABLE 0

59. DETAILS OF TAX ON DISTRIBUTED INCOME OF A DOMESTIC COMPANY ON

BUY BACK OF SHARES(BBS), NOT LISTED ON STOCK EXCHANGE
SI.
No.
Reporting Heads As per Current Order
BBS
TAX ON DISTRIBUTED INCOME ON
1. 0
BUY BACK OF SHARES U/S 115QA
2. SURCHARGE ON ABOVE 0
3. EDUCATION+SECONDARY & HIGHER 0

Page 3 of 4
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EDUCATION CESS
TOTAL TAX ON DISTRIBUTED INCOME
4. 0
ON BUY BACK OF SHARES PAYABLE
5. INTEREST U/S 115QB 0
ADDITIONAL INCOME TAX AND
6. INTEREST PAYABLE 0
6=(4+5)
7. TAX AND INTEREST PAID 0
NET TAX PAYABLE
8. 0
8=(6-7)

60. AGGREGATION OF REFUND & DEMAND ARISING OUT OF ASSESSMENT ORDER

(AFTER ROUNDING OFF AND CROSS ADJUSTMENTS)
HEADS REFUND AMOUNT DEMAND PAYABLE
INCOME TAX 0 3,56,79,416
DDT NA 0
BBS NA 0
BALANCE REFUND/DEMAND AFTER CROSS
0 3,57,71,422
ADJUSTMENTS

*In case of refund, Refund Intimation cum Adjustment sheet will be issued subsequently and
separate communication will be sent for that.

SEEMA DHANKHAR
CIRCLE 1(1) GURGAON

(In case the document is digitally signed please

refer Digital Signature at the bottom of the page)

Page 4 of 4