Need Tally
for Clients?

Contact Us! Here

  Tally Auditor

License (Renewal)
  Tally Gold

License Renewal

  Tally Silver

License Renewal
  Tally Silver

New Licence
  Tally Gold

New Licence
 
Open DEMAT Account with in 24 Hrs and start investing now!
« From the Courts »
Open DEMAT Account in 24 hrs
 Inordinate delay in income tax appeal hearings
 Income Tax leviable on Tuition Fee in the Year of Rendering of Services: ITAT
 Supreme Court invoked its power under Article 142 of Constitution to validate notices issued under section 148 as notices issued under section 148A. However the same shall be subject to amended provisions of section 149.
 ITAT refuses to stay tax demand on former owner of Raw Pressery brand
 Bombay HC sets aside rejection of refund claims by GST authorities
 [Income Tax Act] Faceless Assessment Scheme does not take away right to personal hearing: Delhi High Court
 Rajasthan High Court directs GST Authority to Unblock Input Tax Credit availed in Electronic Credit Ledger
 Sebi-taxman fight over service tax dues reaches Supreme Court
 Delhi High Court Seeks Status Report from Centre for Appointments of Chairperson & Members in Adjudicating Authority Under PMLA
 Delhi High Court allows Income Tax Exemption to Charitable Society running Printing Press and uses Profit so generated for Charitable Purposes
 ITAT accepts Lease Income as Business Income as Business Investments were mostly in nature of Properties

Surendra Kumar Jain Vs. Principal Commissioner Of Income Tax (Central)-Iii, New Delhi & Anr.
October, 18th 2018
$~21 to 34
*       IN THE HIGH COURT OF DELHI AT NEW DELHI
%                                        Date of Decision: 01.10.2018
+       W.P.(C) 4304/2018 & CM APPL.16759/2018
        SURENDRA KUMAR JAIN                         ..... Petitioner
                        versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
22
+       W.P.(C) 4305/2018 & CM APPL.16760/2018
        SURENDRA KUMAR JAIN                         ..... Petitioner
                                versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
23
+       W.P.(C) 4306/2018 & CM APPL.16761/2018
        SURENDRA KUMAR JAIN                         ..... Petitioner
                                versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents

24
+       W.P.(C) 4307/2018 & CM APPL.16762/2018
        SURENDRA KUMAR JAIN                         ..... Petitioner
                                versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
25
+       W.P.(C) 4308/2018 & CM APPL.16763/2018
        SURENDRA KUMAR JAIN                         ..... Petitioner
                                versus


W.P.(C) 4304/2018 & connected matters                   Page 1 of 15
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
26
+       W.P.(C) 4309/2018 & CM APPL.16764/2018
        SURENDRA KUMAR JAIN                      ..... Petitioner
                                versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
27
+       W.P.(C) 4310/2018 & CM APPL.16766/2018
        SURENDRA KUMAR JAIN                      ..... Petitioner
                                versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
28
+       W.P.(C) 4311/2018 & CM APPL.16768/2018
        VIRENDRA JAIN                            ..... Petitioner
                                versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
29
+       W.P.(C) 4313/2018 & CM APPL.16772/2018
        VIRENDRA JAIN                            ..... Petitioner
                                versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
30
+       W.P.(C) 4314/2018 & CM APPL.16774/2018
        VIRENDRA JAIN                            ..... Petitioner
                                versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents


W.P.(C) 4304/2018 & connected matters                Page 2 of 15
31
+       W.P.(C) 4315/2018 & CM APPL.16781/2018
        VIRENDRA JAIN                                       ..... Petitioner
                        versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                   ..... Respondents
32
+       W.P.(C) 4316/2018 & CM APPL.16782/2018
        VIRENDRA JAIN                          ..... Petitioner
                        versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                       ..... Respondents
33
+       W.P.(C) 4318/2018 & CM APPL.16786/2018
        VIRENDRA JAIN                          ..... Petitioner
                        versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                       ..... Respondents
34
+       W.P.(C) 4319/2018 & CM APPL.16787/2018
        VIRENDRA JAIN                          ..... Petitioner
                        versus
        PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)-III,
        NEW DELHI & ANR.                       ..... Respondents
        Present:        Mr.Piyush Kaushik, Adv. for petitioners, in Item Nos.21
                        to 34.
                        Mr.Ajit Sharma and Mr.Asheesh Jain, Adv. for
                        respondents in Item Nos.21 to 34.
CORAM:
HON'BLE MR. JUSTICE S. RAVINDRA BHAT
HON'BLE MR. JUSTICE A.K.CHAWLA
S.RAVINDRA BHAT, J.(ORAL)

1.      In all these writ petitions, the narrow question agitated by the
assessees is that assessment order made on 22.12.2017 under Section

W.P.(C) 4304/2018 & connected matters                           Page 3 of 15
153A read with Section 254 of Income Tax Act, 1961 (hereinafter
,,the Act') for Assessment Year 2005-06 and subsequent years (up-to
2012-13) covered by search assessment, were barred and therefore,
needs to be quashed.

2.      The brief facts necessary to decide these writ petitions are that
pursuant to search and seizure proceedings under Section 132 of the
Act, the assessment was completed for the block period on 28.03.2013
by the concerned Assessing Officer (AO). The Commissioner of
Income Tax (A) partly allowed the assessee's appeal on 14.08.2014.
The matter was carried further to the Income Tax Appellate Tribunal
(ITAT) which remitted the matter back to the AO to complete the
assessment de novo. The assessee contends that in fact the concerned
AO sought tax effect by re-computing the income under Section 153A
of the Act, in effect, following the ITAT's order of 18.02.2016.
Relying upon that order, the assessment proceedings were taken up
after remand by the AO who completed them on 22.12.2017. Relying
upon the Full Bench decision of this Court in Odeon Builders Pvt.
Ltd. vs. Pr. Commissioner of Income Tax-4, (2017) 393 ITR 27, it is
urged on behalf of the assessees that the impugned order is per se
illegal and void. It was contended that apart from the AO's order ­
made after the ITAT's decision (on 18.02.2016), there is other
evidence as well, in the form of reply to the assessee's ITR queries
dated 12.03.2018 where the revenue clearly admitted that the order
was served by hand to the Commissioner of Income Tax
(Departmental Representative) on 30.03.2016. Taking strength from


W.P.(C) 4304/2018 & connected matters                          Page 4 of 15
the then existing proviso to Section 153(2A), it is urged that time
available then to the AO in this case was only up-to 31.12.2016, for
working out of the remand and completing the assessment.

3.      The revenue resisted the proceedings and urged that the
impugned order was made within the time prescribed. Firstly, it is
urged that petitioners cannot be heard to complain as they did not
attend to the queries and co-operate in an assessment proceeding
which got delayed. Learned counsel emphasized that as a result the
petitioners could not be given any discretionary relief given that the
petitioner was an entry provider/facilitator and that the search resulted

in addition of `70 crores as income in his hand. Secondly, it was

argued that the plain reading of Section 153A of the Act would reveal
that it overrides the other provisions of the Act ­ because of the non-
obstante clause. Elaborating further, it was submitted that period of
limitation prescribed by Section 153B i.e. two years is substantial that
excludes search assessment and therefore, excludes applicability of
Section 153(2A) which is general and governs all demands other than
those concerning search assessment.

4.      The question as to what would be the starting point of limitation
with respect to any proceedings which are to be initiated by the
revenue or any steps to be taken by it, was the precise issue of point of
determination by this Court in Odeon Builders (supra). The Court
then held as follows:




W.P.(C) 4304/2018 & connected matters                          Page 5 of 15
        "28. The above decisions under Section 256 (3) are clearly
        distinguishable. The limitation for the purpose of Section
        256 begins to run the moment the order is communicated
        to the parties. Another distinction to be drawn is that the
        word used in Section 256 of the Act "served" whereas
        under Section 260A it is "received". The word "received"
        has to be seen in the context of the decision in CIT v.
        Sudhir Choudhrie (supra), which made it mandatory for
        pronouncement of the orders of the Income-tax Appellate
        Tribunal. At the time of such pronouncement, apart from
        the authorized representative of the assessee, the
        Departmental representative is expected to remain present.
        Through him the Department becomes immediately aware
        of the said judgment of the Income-tax Appellate Tribunal.
        The "concerned" Commissioner of Income-tax
        43. Viewed differently, the contextual interpretation of the
        expression "receive" would be when the parties notified of
        the pronouncement are represented at that time in the open
        court. When pronounced, both parties are said to receive
        it. The agency which they choose for transmission to the
        official or executive component to authorise an appeal is
        not the concern of the judicial system.
        49. Consequently, where the order is common to several
        appeals, while for the assessee the starting point for
        limitation will be when the assessee aggrieved by such
        order first receives a copy thereof; for the Revenue, the
        date when the Department representative of the
        Commissioner of Income-tax (Judicial) first receives a
        copy thereof will be the starting point for limitation for all
        the appeals.
        50. It is, therefore, not possible to accept the submission
        that till a particular jurisdictional Commissioner of
        Income-tax or Principal Commissioner of Income-tax has
        not received the order of the Income-tax Appellate
        Tribunal, the period of limitation for filing an appeal
        against that order does not commence.
W.P.(C) 4304/2018 & connected matters                            Page 6 of 15
        Answers to the questions
        51. The answers to the questions referred to this Court are
        answered thus:
        Question : (i) What is the correct interpretation to be
        placed on the expression "received by the assessee or the
        Principal Chief Commissioner or the Chief Commissioner
        or Principal Commissioner" in Section 260A (2) (a) of the
        Act ? Does it mean "received" by any of the named
        officers including the Commissioner of Income-tax
        (Judicial)?
        Answer : The word "received" occurring in section 260A
        (2) (a) would mean received by any of the named officers
        of the Department, including Commissioner of Income-tax
        (Judicial). The provision at present names four particular
        officers i.e. the Principal Commissioner, Commissioner,
        Principal Chief Commissioner, and the Chief
        Commissioner of Income Tax. These are the only
        designations of the officers who could receive a copy of the
        order. In the absence of a qualifying prefix "concerned",
        the receipt of a copy of the order of the Income- tax
        Appellate Tribunal by any of those officers in the
        Department including the Commissioner of Income-tax
        (Judicial) will trigger the period of limitation.
        Question: (ii) Does limitation begin to run for the purposes
        of Section 260A (2)(a) only when a certified copy of the
        order of the Income-tax Appellate Tribunal is received by
        the "concerned" Commissioner of Income-tax within
        whose jurisdiction the case of the assessee falls
        notwithstanding that it may have been received by any
        other Commissioner of Income- tax, including the
        Commissioner of Income-tax (Judicial) prior thereto? Is it
        open to the court to read the word "concerned" into
        section 260A(2(a) of the Act as a prefix to any of the
        officers of the Department named therein?







W.P.(C) 4304/2018 & connected matters                          Page 7 of 15
        Answer : In section 260A(2) of the Act, the words
        Commissioner of Income-tax, Principal Commissioner of
        Income-tax or Chief Commissioner of Income-tax are not
        prefixed or qualified by the word "concerned". There is no
        warrant for the court to read into the provision such a
        qualifying word. The Court rejects the contention of the
        Revenue that limitation for the purposes of section
        260A(2)(a) begins to run only when a certified copy of the
        order of the Income-tax Appellate Tribunal is received by
        the "concerned" Commissioner of Income-tax within
        whose jurisdiction the case of the assessee falls
        notwithstanding that it may have been received by any
        other Commissioner of Income-tax, including the
        Commissioner of Income-tax (Judicial) prior thereto.
        Question : (iii) In the context of section 254 (3) of the
        Act, is there an obligation on the Income-tax Appellate
        Tribunal to send a certified copy of its order to a
        Commissioner of Income-tax other than the one whose
        details are given to it during the pendency of the appeal?
        Will change in the jurisdiction concerning the case of the
        respondent-assessee to another Commissioner of Income-
        tax subsequent to the order of the Income-tax Appellate
        Tribunal have the effect of postponing the time, from which
        limitation would begin to run in terms of section
        260A(2)(a) of the Act, to when such Commissioner of
        Income-tax receives the order of the Income-tax Appellate
        Tribunal?
        Answer : As far as the obligation of the Income-tax
        Appellate Tribunal under Section 254 (3) of the Act is
        concerned, the said obligation is satisfied once the
        Income-tax Appellate Tribunal sends a copy of an order
        passed by it to the assessee as well as to the Principal
        Commissioner of Income-tax or the Commissioner of
        Income-tax or even the Commissioner of Income-tax
        (Judicial). The Income-tax Appellate Tribunal has to be
        simply go by the details as provided to it in the memo of
        parties. If there is a change concerning the jurisdiction of

W.P.(C) 4304/2018 & connected matters                          Page 8 of 15
        the Commissioner of Income-tax and it is some other
        Commissioner of Income-tax who has jurisdiction, it will
        not have the effect of postponing the commencement of the
        period of limitation in terms of section 260A(2)(a) of the
        Act. The statute is not concerned with the internal
        arrangements that the Department may make by changing
        the jurisdiction of its officers. It is for the officer of the
        Department who first receives a copy of the Income-tax
        Appellate Tribunals order to reach it in time to the officer
        who has to take a decision regarding the filing of an
        appeal.
        Question : (iv) After the decision of this court in CIT v.
        Sudhir Choudhrie [2005]278 ITR 490 (Delhi), do the
        decisions in CIT v. Arvind Construction Co. (P.) Ltd.
        [1992] 193 ITR 330 and CIT v. ITAT [2000] 245 ITR 659
        (Delhi) require to be reconsidered, explained or
        reconciled?
        Answer : The decisions in CIT v. Arvind Construction Co.
        (P) Ltd. (supra) and CIT v. ITAT (supra) were rendered in
        the context of Section 256 of the Act (and not Section
        260A(2)(a) of the Act) and also prior to the decision in CIT
        v. Sudhir Choudhrie (supra). While the former decisions
        may not require reconsideration, they require to be
        reconciled with the latter decision in CIT v. Sudhir
        Choudhrie (supra). The decisions in CIT v. Arvind
        Construction Co. (P) Ltd. (supra) and CIT v. ITAT (supra)
        are of no assistance to the Revenue in its interpretation of
        Section 260A(2)(a) of the Act.
        Question : (v) After the change of procedure where orders
        of the Income-tax Appellate Tribunal are pronounced in
        the open, is it incumbent on the Department through its
        Departmental representative or Commissioner of Income-
        tax (Judicial) to apply for a certified copy of the order of
        the Income-tax Appellate Tribunal and should limitation
        for the purposes of Section 260A(2)(a) be computed from
        the date on which such certified copy is made ready for
        delivery by the Income-tax Appellate Tribunal?

W.P.(C) 4304/2018 & connected matters                            Page 9 of 15
        Answer : While there is no requirement for the
        Departmental representative or the Commissioner of
        Income-tax (Judicial) to apply for a certified copy of the
        Income-tax Appellate Tribunal, in any event under the
        extant Income-tax Appellate Tribunal Rules, a copy of the
        order is sent to the Commissioner of Income-tax (Judicial).
        In the context of Section 260A(2)(a) of the Act, once an
        order is listed for pronouncement in the Income-tax
        Appellate Tribunal, the Departmental representative or the
        Commissioner of Income-tax (Judicial) should be taken to
        be aware of the order. From that point, it is a purely an
        internal administrative arrangement as to how the
        Departmental representative or Commissioner of Income-
        tax (Judicial) obtains and further communicates the order
        to the officer who has to take a decision on filing the
        appeal. It is possible that immediately after
        pronouncement, the authorized representative or the
        Departmental representative or both may apply for a
        certified copy of the order of the Income-tax Appellate
        Tribunal. In that case, the time taken for the certified copy
        to be readied for collection by the applicant will be
        excluded while computing limitation. But here again, if
        earlier to such date, a copy is received by a party from the
        Income-tax Appellate Tribunal, then such earlier date will
        be the starting point for limitation.
        Question : (vi) Whether the receipt of a certified copy of
        the order of the Income-tax Appellate Tribunal by the
        Commissioner of Income-tax (Judicial) is sufficient to
        trigger the commencement of the limitation period under
        Section 260 A (2) (a) of the Act?
        Answer : The receipt of a certified copy of the order of the
        Income-tax Appellate Tribunal by Commissioner of
        Income-tax (Judicial) would trigger the commencement of
        the limitation period under Section 260 A (2) (a) of the
        Act.



W.P.(C) 4304/2018 & connected matters                           Page 10 of 15
        Question : (vii) In the context of a common order of the
        Income-tax Appellate Tribunal covering several appeals,
        whether limitation for all the appeals would begin to run
        when the certified copy is received first by either the
        Commissioner of Income-tax (Judicial) or any one of the
        officers of the Department mentioned in Section 260 A (2)
        (a) or only when the Commissioner of Income-tax
        "concerned" receives it? Where the same Commissioner
        of Income-tax has jurisdiction over more than one assessee
        in the batch, will limitation begin to run for all such
        appeals when such Commissioner of Income-tax receives
        the order in either of the assessee's cases?
        Answer : Where there, is a common order of the Income-
        tax Appellate Tribunal covering the several appeals,
        limitation would begin to run when a certified copy is
        received first by either the Commissioner of Income-tax
        (Judicial) or one of the officers of the Department and not
        only when the Commissioner of Income-tax "concerned"
        receives it. When the same Commissioner of Income-tax
        has jurisdiction for more than one assessee, the limitation
        begin to run for all from the earliest of the dates when the
        Departmental representative of Commissioner of Income-
        tax (Judicial) or any Commissioner of Income-tax first
        receives the order in any of the cases forming part of the
        batch disposed of by the common order. If there are four
        separate orders passed, then the limitation begins to run
        when such separate orders are received first by any officer
        of the Department.
        Question: (viii) Whether administrative instructions issued
        by the Department for its own administrative convenience
        can have the effect of altering the time from which
        limitation will begin to run for the purposes of Section 260
        A(2) (a) of the Act?
        Answer : Instructions issued by the Department for its
        administrative convenience cannot alter the time when
        limitation would begin to run under Section 260A (2) (a) of
        the Act. To reiterate these administrative instructions are

W.P.(C) 4304/2018 & connected matters                          Page 11 of 15
        for the administrative convenience of the Department and
        will not override the statute, in particular, Section 260A
        (2) (a) of the Act."

5.      It is quite evident from the decision in Odeon Builders (supra)
that limitation begins (for any purpose under the Act) from the point
of time when the departmental representative receives the copy of a
decision or an order of the ITAT. The evidence on record in this case
clearly establishes that the concerned DR (a Commissioner ranking
officer) nominated by the revenue received a copy of the ITAT order
dated 30.03.2016.         The Starting point of limitation therefore was
31.03.2016.

6.      The next question is whether the non-obstante clause under
Section 153 of the Act, which prescribes a specific period of
limitation to complete a search assessment for the block period
concerned, could override the general period of limitation.       In this
context, the Court notices that Section 153 of the Act generally talks
of various periods of limitation.        It prescribes that no order of
assessment shall be made either under Section 143 or Section 144 of
the Act any time after expiry of twenty one months from the end of
the assessment year in which the income was first assessable. The
exception carved by way of Section 153(2) ­ relates to reassessment
and states that in cases covered by it, the period is reduced to nine
months from any of financial year in which the notice for re-
assessment is served. The relevant provision which applies at that
point of time for purpose of this case, reads as follows:


W.P.(C) 4304/2018 & connected matters                          Page 12 of 15
        "(2A) Notwithstanding anything contained in sub-
        sections (1), (1A), (1B) and (2), in relation to the
        assessment year commencing on the 1st day of April,
        1971 and any subsequent assessment year, an order of
        fresh assessment in pursuance of an order under Section
        250 or section 254 or section 263 or section 264, setting
        aside or cancelling an assessment, may be made at any
        time before the expiry of one year from the end of the
        financial year in which the order under Section 250 or
        section 254 is received by the Principal Chief
        Commissioner or Chief Commissioner or Principal
        Commissioner or Commissioner or, as the case may be,
        the order under Section 263 or Section 264 is passed by
        the Principal Chief Commissioner or Chief
        Commissioner or Principal Commissioner or
        Commissioner "






7.      During the relevant period when the assessment was completed,
the period prescribed was nine months (on account of substitution
carried out by the amendment). The special provision under Section
153B of the Act in the opinion of the Court carves out a special period
of limitation without which search/block assessments would not be
completed. The entire provisions under Chapter XIV relating to block
assessment, have been termed by the Supreme Court to be a complete
code. At the same time, a specific period of limitation prescribed is
for completion of original block assessments for the search and
seizure proceedings. The period for issuing notice and completion of
block assessment for all the concerned years (7 years) is within two
years. Now, in the opinion of the Court, to apply that general two
years limitation, the block reassessment proceeding after remand is
not a feasible proposition. In the judgments in Nokia India (P) Ltd.

W.P.(C) 4304/2018 & connected matters                          Page 13 of 15
vs. Deputy Commissioner of Income Tax, (2017) 85 Taxmann.com
291 (Del.) as well as Commissioner of Income Tax vs. Bhan Textile P.
Ltd., (2008) 300 ITR 176 (Del.) are relevant authorities. In Principal
Commissioner of Income Tax vs. PPC Business and Products P. Ltd.,
(2017) 398 ITR 71 (Del.), this Court emphasized the need to initiate
the proceedings wherever the revenue wished to proceed further in
case of search and seizure within the time and underlined that in case
the assessments are not initiated and completed within the time
prescribed, the valuable right accrues to the assessee.

8.      The general provision of two years, in the opinion of the Court,
has been provided with one important objective i.e. to cater to a
specific situation where upon search and seizure operation, if new
material is found, already completed assessments are revisited. Had
Parliament not prescribed such a specific period of limitation,
possibly, the assessee's concern would have successfully urged that
search and seizure proceedings would be confined only to the
concerned year in which the search operation took place. It was
proposed to tide over such situation.               The only provision that
prescribed a period of limitation in respect of remands at the relevant
time at least in this case is Section 153(2A). In that sense, that period
of limitation prescribed for completion of remand (nine months)
constituted a special provision, which applies to every class of remand
regardless       whether        they    originate    from    assessments/re-
assessments/revisions or search and seizure assessments. In these
circumstances, completion of the assessment proceedings for the


W.P.(C) 4304/2018 & connected matters                              Page 14 of 15
block period by the impugned order dated 22.12.2017 was clearly
beyond the period of limitation. As noticed earlier, the last date by
which the remand order could have been worked out validly was
31.12.2016.

9.      For the forgoing reasons, the petitions have to succeed. The
impugned order pursuant to the remand dated 22.12.2017 and all
consequential orders and actions are hereby quashed.         The writ
petitions are allowed. All the pending applications stand disposed of.



                                               S. RAVINDRA BHAT
                                                         (JUDGE)


                                                      A.K.CHAWLA
                                                           JUDGE)
OCTOBER 01, 2018
ssc




W.P.(C) 4304/2018 & connected matters                        Page 15 of 15

Home | About Us | Terms and Conditions | Contact Us
Copyright 2024 CAinINDIA All Right Reserved.
Designed and Developed by Ritz Consulting