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IN THE INCOME TAX APPELLATE TRIBUNAL
JODHPUR BENCH, JODHPUR
BEFORE SHRI HARI OM MARATHA, JUDICIAL MEMBERAND
SHRI N.K.SAINI, ACCOUNTANT MEMBER
ITA Nos. 127 & 128 /JU/2012
(u/s 12A)
M/s Nosegay Public School Vs. The CIT.
Management Committee, Bikaner
Sriganganagar
PAN No. AAATN8221E
(Appellant) (Respondent)
Appellant By : Shri Suresh Ohja
Respondent By : Shri G.R.Kokani
Date of hearing : 27.11.2012
Date of Pronouncement : 19.12.2012
ORDER
PER HARI OM MARATHA, J.M.
Both the appeals by the assessee Committee (Trust) is directed against
the order passed by ld CIT (Administration), Bikaner dated 14.6.2007 passed
u/s 12A(a) of the Income Tax Act, 1961 [hereinafter referred to as "the Act"
in short]. By this common order, we will dispose off both the appeals which
are inter-related.
2. Briefly stated, the facts of the case are that the appellant had filed
application for registration of a Charitable Trust / Institution u/s 12A(a) of

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the Act in form No.10A. As per his application in Column No.4, date of
creation of the Institution has been mentioned as 9.11.1985. The assessee
received a notice of hearing in this case in which it is stated that since you
have applied for registration u/s 12A(a) on 30.3.2006, after expiry of one
year from the date of registration under the Rajasthan Society Registration
Act (RSRA), 1958 (on 9.11.1986), therefore, you are directed to attend this
office on 22.8.2006 at 11.00 AM and explain the reasons for the delay. The
assessee filed condonation petition on 2.4.2007 stating therein that due to
lack of awareness of the law, we could not apply for registration of the
Society in time and when it came to our notice, we immediately applied for
the same. Through this letter, it was prayed that the delay in filing the
application may be condoned. It was also suggested in the alternative that in
case the delay is not condoned, registration may be granted from 1.4.2005 in
view of clause (ii) of proviso to section 12A(a) of the Act. The
Commissioner had inquired into the nature and objects of this Committee /
Institution and had found that its objectives are undisputedly charitable in
nature and, therefore, it deserves registration u/s 12A(a) of the Act. Later
on, on 14.6.2007, the ld CIT registered the assessee u/s 12A(a) w.e.f
1.4.2005.
3. But despite fact that certificate of registration under the Act was
granted, the appellant is aggrieved on two grounds:-
(i) that the order passed by the Commissioner Bikaner on 14.6.2007
is not as per law and as such it is illegal because as per law the
Commissioner is bound to pass order accepting or rejecting

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application for registration u/s 12A within six months from the date
of application filed in his office; and
(ii) the assessee has mentioned the date of registration of the Society
as 9.11.1985, the registration deemed to have been granted w.e.f
9.11.1985, as the Commissioner has not considered the condonation
petition at all. It was argued that without giving reasons for rejection
of condonation application and without mentioning anything in this
regard, the CIT cannot reject the application. The deemed rejection of
application will also not arise.
4. In this manner, the appellant has pleaded – one that the order in
question is not at all a valid order in the eyes of law because it has been
passed beyond the permitted time and two deemed registration would be
from the date of its registration, when order was not passed within six
months of the receipt of application for registration by the Commissioner.
5. Before us, lengthy arguments were advanced by ld AR which was
controverted by ld. CIT – DR who supported the appellate order. Because
the issue before us is admixture of facts and law, we would like to extract
the entire submissions which was made by the assessee before CIT, in
verbatim, as under:-
“To
The Commissioner
of Income-tax,
Bikaner.

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Reg. Nosegay Public School Management
Committee, Sriganganagar.
Assessment year:
Sub : For grant of 12 A OF I .T. ACT 1961
Dear Sir,
I want to draw your kind attention towards the fact that an
application for registration was submitted by the society on dated
30.3.2006. In this connection it is stated that in the application the
date of creation of the society was mentioned as 9.11.1985.
In this connection, it is stated that after application of
registration what I have been able to understand that one report
from the Assessing Officer/ Joint Commissioner was called for.
The order sheet dated 8.8.2006 is crystal clear, for your ready
reference the contents thereof are being reproduced herewith:
The predecessor of your good self issued one notice dated
9.8.2006 in respect of the fact that the registration application was
submitted after expiry of one year from the date of registration.
The assessee submitted replies vide letter dated 2.4.2007 stating full
facts and the reasons mentioned therein were on account of lack of
awareness, of the law. The relevant Paragraph is being reproduced
hereunder:
But due to lack of awareness of the law we could not apply
for the Registration of the Society in time and when it came
to our notice, we applied for the Registration.
From the perusal of the above you will observe that your
predecessor was requested so as to condone the delay and to grant
registration retrospectively.
Now, I want to draw your kind attention towards the provision of section
12AA of the Income-tax Act. The relevant provisions are being
reproduced hereunder:
(2) Every order granting or refusing registration under
clause (b) of sub section (1) shall be passed before the
expiry of six month from the end of the month in which
the application was received under clause(a) [or clause
(aa) of sub section(l)} of section 12A]
In this respect from the perusal of above you will observe that order
has to be passed within six month from the date of submission of the
application. In case of the assessee an application was submitted
on 30.03.2006. The six month expired on 30.09.2006. In the
meanwhile no order for refusal was passed by the Commissioner of

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Income-tax, Bikaner. The word shall has been used. Therefore in
case of the assessee the registration shall be deemed to have been
granted in view of the above provisions.
It is. therefore, humbly prayed that necessary order for the period
prior to 1.4.2005 may kindly be passed so that the assessee may be
able to take legal benefit as provided in the act. Hope you will
consider the request and pass the order for granting registration from
the date of application.
I also want to draw your kind attention that the department himself
has accepted that the society is a Charitable Institution. The report of
the lower authorities is self explanatory in this regard.
Without prejudice to above it is stated that if the predecessor of your
good self was of the opinion that registration cannot be granted
retrospectively in that case speaking order should have been
passed. There is no order at all in respect of refusal of
registration under section 12AA /12A of the Income Tax Act, 1961.
Further without prejudice to above it will be worth mentioning here
that only on account of delay adverse view should not be drawn.
There is a direct judgment of Hon'ble Supreme Court reported in
167 ITR 471 in case of Collector, Land Acquisition vs. Mst. Katiji and
Others. The relevant paras of is being reproduced here under:
1. Ordinarily, a litigant does not stand to benefit by
lodging an appeal late.
2. Refusing to condone delay can result in a
meritorious matter being thrown out at the very
threshold and cause of justice being defeated. As against
this, when delay is condoned, the highest that can
happen is that a cause would be decided on merits after
hearing the parties.
4. When substantial justice and technical
considerations are pitted against each other, the cause
of substantial justice deserves to be preferred, for the
other side cannot claim to have vested right in injustice
being done because of a non-deliberate delay.
5. There is no presumption that delay is occasioned
deliberately, or on account of culpable negligence, or on
account of mala fides. A litigant does not stand to benefit
by resorting to delay. In fact, he runs serious risk.
6. It must be grasped that the judiciary is respected not on
account of itspower to legalize injustice on technical
grounds but because it is capable of removing injustice and
is expected to do so.

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The judgment of Supreme Court is very clear regarding the subject.
As far as the ignorance of law is concern I want to draw your kind
attention towards the order of 1TA1 Jodhpur Bench, Jodhpur reported
in 30 TW 158 the relevant portion is being reproduced as under:
In this case the Honb 'le Supreme Court has held that
Court should adopt rational, common sense and
pragmatic approach. And reliance can also he placed
on the judgment of Apex Court in the case of
Motilal Padampath Sugar Mill Company Limited Vs.
State of Uttar Pradesh and others reported in (1997)
118 1TR 326. In this case it was held that "there is no
presumption that every person knows the law. It is often
said that every one is presumed-to know the law, but
that is not correct statement. There is no such maxim
known to the law."
From the perusal of the above you will observe that there was
reasonable cause made known to the CIT Bikaner regarding delay.
Though the matter became barred by limitation by that time but the
reason was submitted to the Commissioner of Income-tax, Bikaner.
In above mentioned fact and circumstances you will observe that the
order passed by your predecessor is a cyclostyled order in which the
period seems to have beer, typed under some wrong impression.
I want to also draw your kind attention that the matter in respect of the
period prior to 01.04.2005 remained undisposed off in the order. In the
other word there is no order for the period prior to 01.4.2005. It is,
therefore, prayed that order may kindly be passed, in view of section
12AA of the Income Tax Act, 1961, in case of disposal off application
after expiry of six month.
It is therefore prayed that necessary order for the period prior to
01.04.2005 may kindly be passed for granting registration under
section 12A and 12AA of the Income Tax Act, 1961.
It is also prayed that a change of personal hearing may kingly be
allowed sot that the assessee may be able to come forward with
suitable submission and put his submission.
Hope you will consider the request.
Yours faithfully,
Sd/-
For Nosegay Public School ;
Management Committee
dated 11.1.2012”

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6. It was found that the appeal filed before the Tribunal is time barred.
This appeal was received in this office on 5.3.2012. This appeal is directed
against the order of ld. CIT dated 14.6.2007. The delay in filing this appeal
is 1660 days. A condonation petition has been filed which is duly supported
by an attested affidavit. The averments taken in this affidavit of the
Managing Trustee are being reproduced verbatim, to understand the ‘reasons’
for this delay.
“Affidavit
I Papinder Singh Sudan S/o Sh. Hakam Singh Sudan, Age 60 years,
resident of Chak 7-E Chhoti, Sri Ganganagar declare on oath as under:
That I am Managing Trustee of Nosegay Public School,
Sriganganagar and conversant with the affairs of the trust and also
competent to swear this Affidavit.
That Nosegay Public School Management Committee is a Society
created vide Memorandum of Association and was got registered vide
registration certificate dated 09.11.1985,
That an application under section 12 A of the Income-tax Act was
submitted vide application dated 30.03.2006 before the Commissioner of
Income-tax Bikaner.
That the Commissioner of Income-tax, Bikaner allowed the registration
to the Society Nosegay Public School Management Committee with effect from
01.04.2005.
Thai the Society applied for registration since its beginning i.e. from
date of creation.
That the Society now submitted an appeal before the Income-tax
Appellate Tribunal Jodhpur Bench, Jodhpur against the order of the
Commissioner of Income-tax, Bikaner dated 14.06.2007. The appeal is barred
by limitation.
That the appeal in question is delayed substantially on account
of ignorance of law and as per the advice of the tax consultant of the Society
at that time.
That now the present consultants of the Society advised that an appeal
should have been submitted. It has also been made known that no order can

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be passed on an application U/s. 12 A of the Income-tax Act after period of
six months from the date of application.
That since the Members of Society were not aware about the Income-
tax Act and consequences thereof but the consultant advised that it makes
no difference if the registration to the Society has been granted with effect
from 1.4.2005 in place of dated 09.11.1985 whereas the Society was created
and running for fulfillment of aims and objects thereof after creation.
That the application under section 12 A of the Income-tax Act
submitted by the Society was decided by the Commissioner of Income-tax,
Bikaner vide order dated 14.06.2007 i.e. after expiry of 6 months from the date
of submitting of the application.
That an application in respect of condonation of delay was also
submitted before the Commissioner of Income-tax Bikaner vide application
dated 2.4.2007 prepared by the then consultant.
What has been stated above is true to the best of my knowledge
and nothing has been concealed. God may help me.
DEPONENT
Sd/-
(PAPINDER SINGH SUDAN)”
7. With the support of this affidavit and application for condonation of delay
it has been prayed that in the interest of substantial justice, this delay may
kindly be condoned. This request was repelled by ld. CIT – DR stating that this
delay is inordinate, therefore, it should not be condoned. After considering
rival stands, we have found that the reason for this delay is stated to be due to
wrong advice and ‘ignorance of law’ of the persons who are managing this
institution. We have gone through the decisions relied upon by the ld. AR in
respect of condonation of this delay. We have noticed that the Hon’ble Supreme
Court, as back as in the year 1987, had an occasion to decide such an issue in
the case of Collector, Land Acquisition Vs. Mst. Katiji and other [(1987) 167
ITR 471 (SC)]. The Hon'ble Supreme Court has titled their decision
overwhelmingly in the favour of the substantial justice when it is pitted against
the pedantic reasons. Subsequently, the Hon'ble Apex Court reiterated their

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view while deciding the case of Vedabai alias Vijayanatabai Baburao Patil vs
Shantaram Baburao Patil and others [(2002)253 ITR 798 (SC) in which their
lordship have held as under:-
“In exercising discretion under section 5 of the Limitation Act, 1963, to
condone delay for sufficient cause in not preferring an appeal or other
application within the period prescribed, courts should adopt a pragmatic
approach. A distinction must be made between a case where the delay is
inordinate and a case where the delay is of a few days. Whereas in the
former consideration of prejudice to the other side will be a relevant factor
and calls for a more cautious approach, in the latter case no such
consideration may arise and such a case deserves a liberal approach. No
hard and fast rule can be laid down in this regard. The court has to exercise
its discretion on the facts of each case keeping in mind that in construing
the expression “sufficient cause” the principle of advancing substantial
justice is of prime importance. The expression “sufficient cause” should
receive a liberal construction.”
8. Similarly, Hon'ble Allahabad High Court has very succinctly dealt with
this issue threadbare while deciding the case of CIT & Anothers Vs. Ram Kishan
Gupta [(2007) 295 ITR 578 (All.). It has been held in this case as under:-
“In view of the aforesaid discussions, we are of the view that the sufficient cause
had been brought on record to condone the delay of five days. In the
circumstances, the impugned judgment and order dated July 26, 1999, is set
aside. The delay in filing the appeal before the Tribunal is condoned and the
Tribunal is directed to decide the appeal on the merits in accordance with law.
Since the appeal was filed in the year 1992, it would be appropriate that the
Tribunal expedites the hearing of the appeal and decide the same within a period
of three months from the date of production of certified copy of this order.
The appeal stands allowed as above, however in the facts of the case, there shall
be no order as to costs.”
10. The Hon'ble Apex Court has laid down a firm law vide which ‘ignorance of
law’ has been treated as a ‘sufficient cause’ and reasonable excuse for any default
committed under the law when the cause of substantial justice is under
consideration. The Hon'ble Apex Court while dealing with the case of Motilal
Padampat Sugar Mills Co Ltd Vs. State of Uttar Pradesh & others reported in
[(1997) 118 ITR page 326 (SC)], has held thus:-

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“On the basis of an announcement in a newspaper that the State of U.P. had
decided to grant exemption from sales tax for a period of three years to all new
industrial units in the State, the appellant wrote a letter in October, l968, to the
Director of Industries of its intention to set up an industrial unit for the
manufacture of vanaspati, in reply to which the director confirmed that there will
be no sales tax on the finished product of the appellant's vanaspati factory from
the date it gets power connection for commencing production. Thereupon the
appellant approached financiers for financing the project and initiated
negotiations with manufacturers for the purchase of machinery for the factory.
In December, 1968, the Chief Secretary to Government and Adviser to the
Governor reiterated the assurance that the appellant would be entitled to the tax
holiday. On the appellant's request for confirmation, the Chief Secretary in a
reply dated December 22, 1968, confirmed that "the State Government will be
willing to consider your request for grant of exemption from U.P. sales tax for a
period of three years from the date of production", and the appellant to apply
formally to the Secretary in the Industries Department and in the meantime to
"go ahead with the arrangements for setting up of the factory". Since the
financial institutions were not satisfied with that reply, the appellant approached
the Chief Secretary again and the latter wrote a letter dated January 23, 1969, to
the effect that the appellant "will be entitled to exemption from U.P. sales tax for
a period of three years from the date of going into production", the exemption
being applicable to vanaspati sold in the State, and in view of this assurance the
appellant went ahead with the setting up of the vanaspati factory. Thereafter, the
State Government took a policy decision in January, 1970, that new vanaspati
units will be given only a graded partial concession during the first three years of
production and once again the State Government revised its policy in August,
1970, rescinding even the partial exemption. In the meantime, the appellant had
written a letter to the effect that it would be availing of the partial exemption. The
appellant thereupon filed a writ petition which it amended and in the amended
petition raised the plea that the Chief Secretary, acting on behalf of the State
Government, had given an unequivocal assurance that the appellant would be
entitled to exemption from payment of sales tax for a period of three years from
the date of commencement of production, intending or knowing that it would be
acted upon by the appellant, and the appellant, relying on that assurance,
established the factory by investing a large amount, and, therefore, the State
Government was bound to honour the assurance and exempt vanaspati
manufactured and sold by the appellant for a period of three years from July 2,
1970. The High Court rejected the plea. On appeal to the Supreme Court:
Held, reversing the decision of the High Court, that the facts necessary for
invoking the doctrine of promissory estoppel were clearly present and the
Government was bound to carry out the representation and exempt the appellant
from sales tax in respect of sales of vanaspati effected by it in Uttar Pradesh for a
period of three years from the date of commencement of production and was not
entitled to recover such sales tax from the appellant:
Held also, on the facts, that the fact that the appellant wrote a letter accepting the
concessional rate of sales tax did not amount to waiver.

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It is elementary that waiver is a question of fact and it must be properly pleaded
and proved. No plea of waiver can be allowed to be raised unless it is pleaded and
the factual foundation for it is laid in the pleadings. Waiver means abandonment
of a right and it may be either express or implied from conduct, but its basic
requirement is that it must be "an intentional act with knowledge". There can be
no waiver unless the person who is said to have waived is fully informed as to his
right and with full knowledge of such right, he intentionally abandons it.
Where one party by his words or conduct makes to another a clear and
unequivocal promise which is intended to create legal relations or effect a legal
relationship to arise in the future, knowing or intending that it would be acted
upon by the other party to whom the promise is made and it is in fact so acted
upon by the other party, the promise would be binding on the party making it and
he would not be entitled to go back upon it, if it would be inequitable to allow him
to do so having regard to the dealings which have taken place between the parties,
and this would be so irrespective of whether there is any pre-existing relationship
between the parties or not.
It is not necessary, in order to attract the applicability of the doctrine of
promissory estoppel, that the promisee, acting in reliance on the promise, should
suffer any detriment. What is necessary is only that the promisee should have
altered his position: the alteration of position need not involve any detriment to
the promisee. The detriment in such a case is not some prejudice suffered by the
promisee by acting on the promise, but the prejudice which would be caused to
the promisee, if the promisor were allowed to go back on the promise.
Where the Government makes a promise knowing or intending that it would be
acted on by the promisee and, in fact, the promisee, acting in reliance on it, alters
his position, the Government would be held bound by the promise and the
promise would be enforceable against the Government at the instance of the
promise, notwithstanding that there is no consideration for the promise and the
promise is not recorded in the form of a formal contract as required by art. 299 of
the Constitution.
Since the doctrine of promissory estoppel is an equitable doctrine, it must yield
when equity so requires. If it can be shown by the Government that having regard
to the facts as they have subsequently transpired, it would be inequitable to hold
the Government to the promise made by it, the court would not raise an equity in
favour of the promisee and enforce the promise against the Government, because,
on the facts, equity would not require that the Government should be held bound
by the promise made by it. When the Government is able to show that in view of
the facts which have transpired since the making of the promise, public interest
would be prejudiced if the Government were required to carry out the promise,
the court would have to balance the public interest in the Government carrying
out a promise made to a citizen which has induced the citizen to act upon it and
alter his position and the public interest likely to suffer if the promise were
required to be carried out by the Government and determine which way the equity
lies. It would not be enough for the Government just to say that public interest
requires that the Government should not be compelled to carry out the promise or
that the public interest would suffer if the Government were required to honour
it. The Government cannot claim to be exempt from the liability to carry out the

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promise on some indefinite and undisclosed ground of necessity or expediency;
nor can the Government claim to be the sole judge of its liability and repudiate it
on an ex parte appraisement of the circumstances. The Government will have to
disclose to the court what are the subsequent events on account of which the
Government claims to be exempt from the liability and it would be for the court to
decide whether those events are such as to render it inequitable to enforce the
liability against the Government. Mere claim of change of policy would not be
sufficient to exonerate the Government from the liability: the Government would
have to show what precisely is the changed policy and also its reason and
justification so that the court can judge for itself which way the public interest
lies and what the equity of the case demands. It is only if the court is satisfied, on
proper and adequate material placed by the Government, that overriding public
interest requires that the Government should not be held bound by the promise
but should be free to act unfettered by it, that the court would refuse to enforce
the promise against the Government. The court would insist on a highly rigorous
standard of proof in the discharge of the Government's burden in this regard.
But even where there is no such overriding public interest, it may still be
competent to the Government to resile from the promise on giving reasonable
notice, which need not be a formal notice, giving the promisee a reasonable
opportunity of resuming his position provided of course it is possible for the
promisee to restore status quo ante. If, however, the promisee cannot resume his
position, the promise would become final and irrevocable.
The doctrine of promissory estoppel cannot be applied in the teeth of an
obligation or liability imposed by law. Promissory estoppel cannot be invoked to
compel the Government or even a private party to do an act prohibited by law.
There can also be no promissory estoppel against the exercise of legislative
power. The legislature can never be precluded from exercising its legislative
function by resort to the doctrine of promissory estoppel.
Per curiam: (i) If the U.P. Sales Tax Act, 1948, did not contain a provision
enabling the Government to grant exemption it would not be possible to enforce
the representation against the Government, because the Government cannot be
compelled to act contrary to the statute, but since s. 4A of the U.P. Sales Tax Act,
1948, confers power on the Government to grant exemption from sales tax, the
Government can legitimately be held bound by its promise to exempt the appellant
from payment of sales tax. It is true that taxation is a sovereign or governmental
function, but no distinction can be made between the exercise of a sovereign or
governmental function and a trading or business activity of the Government, so
far as the doctrine of promissory estoppel is concerned.
(ii) There is no presumption that every person knows the law. It is often
said that every one is presumed to know the law, but that is not a correct
statement: there is no such maxim known to the law.
………
Decision of the Allahabad High Court reversed.

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11. Therefore, taking the cumulative effect of these decisions, particularly
when appellant before us is a Charitable Institution, and the Commissioner as
well as the ITO have found the objects of the appellant ‘charitable in nature’ no
doubt has been raised in this regard, we are left with no option to condone this
delay in filing appeal before Tribunal. In such a institution the trustee or any
incharge has got no personal interest, but such institutions serve the public
cause of charity. Anybody so connected may have perfunctory interest and such
like long delays usually occur. There are raft of decisions which favour
condonation such delays, instead of defeating the cause of charity at the very
threshold. That is why the law has permitted such institution to exist and
flourish for public cause. We are aware that there may be some institutions
which may also work against the dictum of the law and avail personal benefits
of its trustees but such cases have to be segregated. In the light of the above
decisions, we are of the considered opinion that this appeal deserves to be
admitted after condoning the delay. Accordingly, we admit this appeal.
12. Coming to the merits of the case, we have found that the Commissioner
undeniably has passed the order u/s 12A(a) beyond six months of the receipt of
application in form 10A in its office on 30.3.2006. The impugned order was
passed on 14.6.2007, beyond six months as has been prescribed in Section 12A.
In such eventualities, the application for registration is deemed to have been
allowed. We may rely on the decision of Hon'ble Special Bench of ITAT, Delhi
renedered in the case Bhagwad Swarup Shri Shri Devraha Baba Memorial Shri
Hari Parmarth Dham Trust Vs. CIT reported in [(2008) 299 ITR (AT) 161
(Delhi)(SB]. In the above order it has been held that if the order is passed by
CIT within 6 moths of receipt of application in form 10A, u/s 12A, it is deemed

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that it stand allowed. The order passed by Commissioner refusing registration
was treated as a ‘nullity’ liable to be quashed. Thus, registration was deemed to
be granted ‘as applied for by the assessee’. In this case also, similar situation
has occurred. The only difference is that the Commissioner has registered the
Institution but w.e.f. 1.4.2005, ignoring the date of registration given in the
Form No. 10A. The ratio of the above Tribunal order of the Special Bench the
application is ‘deemed allowed’ as applied for by the assessee. Since the
assessee had applied to get registration from the date of its inception, it is
wrong and illegal to allow the same w.e.f. 1.4.2005 under this deeming
provision. This registration has to be treated to have been granted w.e.f. the
date of its inception i.e. 9.11.1985. Accordingly, we direct the Commissioner
to grant registration to the appellant w.e.f. 09.11.1985, which already deemed to
have been granted. In view of our above finding, the other appeal would be of
academic interest only.
12. In the result, both the appeal stands allow.
(Order Pronounced in the Open Court on 19.12.2012 )
Sd/- Sd/-
(N.K.SAINI) (HARI OM MARATHA)
JUDICIAL MEMBER ACCOUNTANT MEMER
Dated : 19th
December, 2012
Rkk
Copy to:
1. The Appellant
2. The Respondent
3. The CIT
4. The CIT(A)
5. The DR
By Order
Assistant Registrar
ITAT, Jodhpur

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