TaxTMI 
TaxTMI 
2019 (1) TMI 696
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....he assessee is a partnership firm and engaged in the business of manufacturing and trading of gold and silver ornaments, precious/semi precious and coloured stones etc. The assessee filed its return of income U/s 139(1) of the Income Tax Act, 1961 (in short the Act) on 11/10/2010 declaring total income of Rs. 19,72,000/-. Subsequently there was a search and seizure action U/s 132 of the Act on 03/4/2013 at the business premises of the assessee. During the course of search from 03/04/2013 to 05/04/2013, statement of the assessee was recorded on three days. Even during the post search investigation, the statement of the assessee was again recorded on 30/5/2013. Consequently, the Assessing Officer issued notice U/s 153A of the Act and completed the reassessment by making the addition on account of loan taken by the assessee from 12 parties, total amounting to Rs. 4,82,00,000/- U/s 68 of the Act. 3. The assessee challenged the action of the Assessing Officer before the ld. CIT(A). The ld. CIT(A) deleted the addition made by the Assessing Officer on two aspects viz (i) there was no incriminating material either found or seized during the search and seizure action and further the asse....
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....rest after deduction of TDS which was allowed by the Assessing Officer, therefore, in absence of any incriminating material found or seized during the course of search and seizure action, no addition can be made to the income of the assessee when the assessment was not pending on the date of search. The ld AR has pointed out that the assessee filed return of income U/s 139(1) of the Act on 11/10/2010 and the time to issue notice U/s 143(2) of the Act expired on 30/10/2011 and therefore, the assessment for the assessment year under consideration was not pending as on the date of search. Admittedly there is not incriminating material or document was found during the course of search disclosing any undisclosed income of the assessee. All the transactions of loan were duly recorded in the books of account of the assessee and were subjected to a verification of the Assessing Officer. The ld AR has further submitted that the alleged admission in the statement recorded U/s 132(4) of the Act is nothing but it was obtained by the department when the assessee was continuously grilled for three days to get this admission. He has referred to the question No. 77 and again referred to question N....
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....e decision of Hon'ble Jurisdictional High Court in the case of Jai Steel (India) Vs ACIT (2013) 259 CTR 281 (Raj). Hence, the ld. CIT(A) has rightly deleted the addition on the ground that there was no incriminating material found or seized during the search and seizure operation. 6.1 On merits, the ld AR of the assessee has submitted that the Assessing Officer issued noted U/s 136 of the Act to all the loan creditors which was duly responded. The assessee has also filed all the relevant supporting documentary evidence in respect of all the loan creditors to establish the identity and creditworthiness of the creditor as well as genuineness of the transaction. He has referred to the documents filed by the assessee before the Assessing Officer in support of the claim at page No. 207 to 505 of the paper book. Further no cash was either found or deposited in the bank accounts and the loan creditors to arrive to the conclusion that these are accommodation entries against the payment of the cash. In support of his contention, he has relied upon the decision of Hon'ble Mumbai High Court in the case of CIT Vs. Deepak Kumar Agarwal 398 ITR 586 and the decision of the Kolkata Benches of t....
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....67 were recorded on 04/4/2013 and up to 1.00 a.m. on 05/4/2013 and thereafter the statement of the assessee was again resumed in the morning of 05/4/2013 and continued up to question No. 78. It is manifest from the statement recorded U/s 132(4) of the Act that repeated questions were asked about the genuineness of the loans taken by the assessee during the financial year 2009-10 relevant to the assessment year under consideration and the assessee has given the answer and stated that all these loans are genuine and taken through banking channel and the assessee also repaid these loans prior to the date of the search. These transactions are very much part of the regular books of account of the assessee. However, the search team again put question to the assessee as question No. 77 in which the assessee has stated that the assessee has checked the details of the loans from M/s Dipnarayan Vyapar Pvt. Ltd. for which the assessee received cash and the same was declared as undisclosed income for the year of the search. We find that prior to that the assessee was also asked question No. 34 to 36 and question No. 39. Even after the statement recorded U/s 132(4) of the Act, the Investigation....
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....e assessee for two days and it is a matter of record that the assessee was grilled up to 1.00 a.m. on the night of 04/4/2013 and again restarted in the morning at 7.50 a.m. and the question No. 77 was again asked specifically regarding loan from M/s Dipnarayan Vyapar Pvt. Ltd. in reply to that the assessee has explained that after trying to remember for continuously for two days and hoping the cooperation from the department, he said that he received cash against the said loan which was declared as undisclosed income for the year of search. The Investigation Wing was still not satisfied with the statement of the assessee and again called the assessee for further investigation on 30/5/2013 and thereafter on 21/6/2013. The assessee was again put the question about the loan taken from M/s Dipnarayan Vyapar Pvt. Ltd., in reply, the assessee explained that on repeated instances of the investigation team and due to exhausted mind, the assessee given an incorrect reply to question No. 77 recorded U/s 132(4) of the Act on 05/4/2013 and again stated that after verifying the books of account, the said loan was taken on interest and was also repaid both the transactions are through banking ch....
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....datorily issued to the person searched requiring him to file returns for six AYs immediately preceding the previous year relevant to the AY in which the search takes place. ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place. The AO has the power to assess and reassess the 'total income' of the aforementioned six years in separate assessment orders for each of the six years. In other words there will be only one assessment order in respect of each of the six AYs "in which both the disclosed and the undisclosed income would be brought to tax". iv. Although Section 153 A does not say that additions should be strictly made on the basis of evidence found in the course of the search, or other post-search material or information available with the AO which can be related to the evidence found, it does not mean that the assessment "can be arbitrary or made without any relevance or nexus with the seized m....
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....her unearthing of incriminating material relating to any one of the AYs could justify the re-opening of the assessment for all the earlier AYs was considered both in Anil Kumar Bhatia (supra) and Chetan Das Lachman Das (supra). Incidentally, both these decisions were discussed threadbare in the decision of this Court in Kabul Chawla (supra). As far as Anil Kumar Bhatia (supra) was concerned, the Court in paragraph 24 of that decision noted that "we are not concerned with a case where no incriminating material was found during the search conducted under Section 132 of the Act. We therefore express no opinion as to whether Section 153A can be invoked even under such situation". That question was, therefore, left open. As far as Chetan Das Lachman Das (supra) is concerned, in para 11 of the decision it was observed: "11. Section 153A (1) (b) provides for the assessment or reassessment of the total income of the six assessment years immediately preceding the assessment year relevant to the previous year in which the search took place. To repeat, there is no condition in this Section that additions should be strictly made on the basis of evidence found in the course of the sear....
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....eration while computing the total income under Section 153A of the Act. The Court then explained as under: "22. In the firm opinion of this Court from a plain reading of the provision along with the purpose and purport of the said provision, which is intricately linked with search and requisition under Sections 132 and 132A of the Act, it is apparent that: (a) the assessments or reassessments, which stand abated in terms of II proviso to Section 153A of the Act, the AO acts under his original jurisdiction, for which, assessments have to be made; (b) regarding other cases, the addition to the income that has already been assessed, the assessment will be made on the basis of incriminating material; and (c) in absence of any incriminating material, the completed assessment can be reiterated and the abated assessment or reassessment can be made." 34. The argument of the Revenue that the AO was free to disturb income de hors the incriminating material while making assessment under Section 153A of the Act was specifically rejected by the Court on the ground that it was "not borne out from the scheme of the said provision" which was in the cont....
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.... iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place. The AO has the power to assess and reassess the 'total income' of the. aforementioned six years in separate assessment orders for each of the six years. In other words there will be only one assessment order in respect of each of the six AYs "in which both the disclosed and the undisclosed income would be brought to tax". iv. Although Section 153 A does not say that additions should be strictly made on the basis of evidence found in the course of the search, or other post-search material or information available with the AO which can be related to the evidence found, it does not mean that the assessment "can be arbitrary or made without any relevance or nexus with the seized material. Obviously an assessment has to be made under this Section only on the basis of seized material." v. In absence of any incriminating material, the completed assessment can be reiterated and the abated assessment or reassessment can be made. The word 'assess' in Section 153 A is relatable to abated proceedings (i.e. those pendin....
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.... of the Act is linked with search and requisition under sections 132 and 132A of the Act, it is evident that the object of the section is to bring to tax the undisclosed income which is found during the course of or pursuant to the search or requisition. However, instead of the earlier regime of block assessment whereby, it was only the undisclosed income of the block period that was assessed, section 153A of the Act seeks to assess the total income for the assessment year, which is clear from the first proviso thereto which provides that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years. The second proviso makes the intention of the Legislature clear as the same provides that assessment or reassessment, if any, relating to the six assessment years referred to in the sub-section pending on the date of initiation of search under section 132 or requisition under section 132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal prov....
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....sessment orders for each of the six years determining the total income of the assessee which would include income declared in the returns, if any, furnished by the assessee as well as undisclosed income, if any, unearthed during the search or requisition. In case where a pending reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. ** ** ** 19. On behalf of the appellant, it has been contended that if any incriminating material is found, notwithstanding that in relation to the year under consideration, no incriminating material is found, it would be permissible to make additions and disallowance in respect of an the six assessment years. In the opinion of this court, the said contention does not merit acceptance, inasmuch as. the assessment in respect of each of the six assessment years is a separate and distinct assessment. Under section 153A of the Act, assessment has to be made in relation to the search or requisition, namely, in relation to material disclosed du....
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....(P.) Ltd. (supra) which was referred to in Kabul Chawla (supra) has been affirmed by the Supreme Court by the dismissal of the Revenue's SLP on 7th December, 2015. The decision in Dayawanti Gupta 64. That brings us to the decision in Smt. Dayawanti Gupta (supra). As rightly pointed out by Mr. Kaushik, learned counsel appearing for the Respondent, that there are several distinguishing features in that case which makes its ratio inapplicable to the facts of the present case. In the first place, the Assessees there were engaged in the business of Pan Masala and Gutkha etc. The answers given to questions posed to the Assessee in the course of search and survey proceedings in that case bring out the points of distinction. In the first place, it was stated that the statement recorded was under Section 132(4) and not under Section 133A. It was a statement by the Assessee himself. In response to question no. 7 whether all the purchases made by the family firms, were entered in the regular books of account, the answer was: "We and our family firms namely M/s. Assam Supari Traders and M/s. Balaji Perfumes generally try to record the transactions made in respect....
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....23 of the decision in Smt. Dayawanti Gupta (supra), it was observed as under: "23. This court is of opinion that the ITAT's findings do not reveal any fundamental error, calling for correction. The inferences drawn in respect of undeclared income were premised on the materials found as well as the statements recorded by the assessees. These additions therefore were not baseless. Given that the assessing authorities in such cases have to draw inferences, because of the nature of the materials - since they could be scanty (as one habitually concealing income or indulging in clandestine operations can hardly be expected to maintain meticulous books or records for long and in all probability be anxious to do away with such evidence at the shortest possibility) the element of guess work is to have some reasonable nexus with the statements recorded and documents seized. In tills case, the differences of opinion between the CIT (A) on the one hand and the AO and ITAT on the other cannot be the sole basis for disagreeing with what is essentially a factual surmise that is logical and plausible. These findings do not call for interference. The second question of law is answered ....
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....l are gathered in course of search or during the proceedings U/s 153A of the Act. The Hon'ble Jurisdictional High court in the case of Jai Steel (India) Vs ACIT (supra) has also considered this issue in para 22 to 26 as under: 22. In the firm opinion of this Court from a plain reading of the provision along with the purpose and purport of the said provision, which is intricately linked with search and requisition under Sections 132 and 132A of the Act, it is apparent that: (a) the assessments or reassessments, which stand abated in terms of II proviso to Section 153A of the Act, the AO acts under his original jurisdiction, for which, assessments have to be made; (b) regarding other cases, the addition to the income that has already been assessed, the assessment will be made on the basis of incriminating material and (c) in absence of any incriminating material, the completed assessment can be reiterated and the abated assessment or reassessment can be made. Though such a claim by the assessee for the first time under Section 153A of the Act is not completed, the case in hand, has to be considered at best similar to a case where in spite ....
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....ante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under Section 148 can be issued, as provided in Section 149 has also been made inapplicable by the non obstante clause. Section 151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time-limit prescribed for completion of an assessment or reassessment by Section 153 has also been done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters, if need be. 21. Now there can be cases where at the time when the search is initiated or requisition is made, the assessment or reassessment proceedings relating to any assessment year falling within the period of the six assessment years mentioned above, may be pending. In such a case, the second proviso to sub-section (1) of Section 153A says that such proceed....
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....caped assessment are clubbed together and assessed as the total income. In such a case, to reiterate, there is no question of any abatement of the earlier proceedings for the simple reason that no proceedings for assessment or reassessment were pending since they had already culminated in assessment or reassessment orders when the search was initiated or the requisition was made." (Emphasis supplied) 24. The said judgment also in no uncertain terms holds that the reassessment of the total income of the completed assessments have to be made taking note of the undisclosed income, if any, unearthed during the search and the income that escaped assessments are required to be clubbed together with the total income determined in the original assessment and assessed as the total income. The observations made in the judgment contrasting the provisions of determination of undisclosed income under Chapter XIVB with determination of total income under Sections 153A to 153C of the Act have to be read in the context of second proviso only, which deals with the pending assessment/reassessment proceedings. The further observations made in the context of de novo assessment proceedings als....
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.... ground taken/ contention raised detailed written submission are made wherein the appellant has challenged the legal validity of the addition made in the order framed u/s 143(3)/153A. It is submitted that such additions cannot be made as they are not relatable to any incriminating seized material found during the course of search. The appellant has cited following judgments in support of the contention taken: 1) Jay Steel limited vs. ACIT (88 DTR 1) [Raj HC] 2) Kabul Chawla vs. ACIT 380 ITR 573 (Del HC) 3) Continental warehousing Corporation 374 ITR 645 etc. 7.3 I have perused the order of the AO and submissions made in this regard. Perusal of assessment order passed u/s 143(3)/153A shows that all the additions made by the AO are not relatable to any seized material. I also find that for the A.Yr the assessment stood completed on the date of search. 7.4 The issue of additions made by the AO in the assessment u/s 143(3)/153A without any reference to incriminating seized material was considered by the Hon'ble Rajasthan High court in the case of Jai Steel limited vs. ACIT (88 DTR 1). The Hon'ble court was of the view in case of completed as....
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....e six AYs "in which both the disclosed and the undisclosed income would be brought to tax". iv. Although Section 153 A does not say that additions should be strictly made on the basis of evidence found in the course of the search, or other postsearch material or information available with the AO which can be related to the evidence found, it does not mean that the assessment "can be arbitrary or made without any relevance or nexus with the seized material. Obviously assessment has to be made under this Section only on the basis of seized material." v. In absence of any incriminating material, the completed assessment can be reiterated and the abated assessment or reassessment can be made. The word 'assess' in Section 153 A is relatable to abated proceedings (i.e. those pending on the date of search) and the word 'reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing....
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....T(A) qua this issue. 8.1 On merits, the stand of the revenue is that the statement made on oath U/s 132(4) of the Act is an admissible evidence and therefore, once the assessee has admitted the loan as an accommodation entry and in return the assessee received the cash then the Assessing Officer justified in making the addition U/s 68 of the Act. However, we find that the statement which is relied upon by the Assessing Officer is only one part and that too a selected part without considering the prior statement and subsequent statement recorded by the Investigation Wing. Therefore, if we consider the statement of the assessee in the context of the questions put and if all the relevant statement is read together then it would not amount to admission of any bogus transaction. Further the transactions were duly recorded in the books of account at the time of taking the loans in the F.Y. 2009-10 and again at the time of repayment of these loans in the F.Y. 2011-12, which was not disturbed by the Assessing Officer. Even the interest paid by the assessee after deducting TDS was not disturbed by the Assessing Officer in the assessment order passed U/s 153A read with Section 143(3) of t....
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....1. • The copy of director report, audit report, Balance Sheet and Profit & Loss a/c along with all annexure of 31.03.2010. • Copy of bank statement showing the entry of payment made to assessee. Rameshwar Finvest Pvt. Ltd. a) Pertaining to AY 2010-11: - • Confirmation of party of loan taken. • PAN Card Copy of Party. • The copy of ITR for AY 2010-11. • The copy of director report, audit report, Balance Sheet and Profit & Loss a/c along with all annexure of 31.03.2010. • Copy of bank statement showing the entry of payment made to assessee. b) Pertaining to AY 2011-12: - • Confirmation of party of loan taken. • PAN Card Copy of Party. • The copy of director report, audit report, Balance Sheet and Profit & Loss a/c along with all annexure of 31.03.2011. c) Pertaining to AY 2012-13: - • Confirmation of party of loan taken. • PAN Card Copy of Party. • The copy of ITR for AY 2012-13. • The copy of director report, audit report, Balance Sheet and Profit & Loss a/c along with all annexure of 31.03.2....
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.... along with all annexure of 31.03.2010. • Copy of bank statement showing the entry of payment made to assessee. b) Pertaining to AY 2011-12: - • Confirmation of party of loan taken. • PAN Card Copy of Party • The copy of director report, audit report, Balance Sheet and Profit & Loss a/c along with all annexure of 31.03.2011. Parmatma Developers Pvt. Ltd a) Pertaining to AY 2010-11: - • Confirmation of party of loan taken. • PAN Card Copy of Party • The copy of ITR for AY 2010-11. • The copy of director report, audit report, Balance Sheet and Profit & Loss a/c along with all annexure of 31.03.2010. • Copy of bank statement showing the entry of payment made to assessee. b) Pertaining to AY 2011-12: - • Confirmation of party of loan taken. • PAN Card Copy of Party • The copy of director report, audit report, Balance Sheet and Profit & Loss a/c along with all annexure of 31.03.2011. c) Pertaining to AY 2012-13: - • Confirmation of party of loan taken. • PAN Card Copy of Party. • ....
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.... addition made by the Assessing Officer is not sustainable. The ld. CIT(A) has considered this issue in para 8 and 9 as under: "8. I have pursued the assessment order and submission made in this regard. I have also gone through the various judgements cited by the Ld A/R, it is seen that the appellant has furnished the following (i) confirmations of all the parties containing their PAN and addresses (ii) Copy of ITR's (iii) Copy of audit report, Balance sheet etc. of the companies and (iv) Copy of bank statements of the companies showing the entry of payment made to appellant. No cash deposit was found deposited in bank a/c of any company. It was stated by ld. AR that the appellant has submitted these documents which prove identity, creditworthiness and genuineness of share capital. None of notice sent u/s 133(6) received back as "Un-served" and in some of the cases it was also complied. 8.2 There is no incriminating material except the admission in statement by the partner of appellant any positive material to controvert the documentary evidence furnished by the appellant. From perusal of the records it reveals that all the loans were received through a/c....
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....sequently, assumption of jurisdiction under section 153A and consequent additions made by Assessing Officer were not justified - Held, yes [Para 36][ln favour of assessee] 8.3 Section 68 is attracted where an entry relating to a sum is found to have been credited in the books kept by the appellant, which thus implies, existence of books and recording of a sum which the Assessing Officer considers as doubtful. The Assessing officer then starts enquiry, specifically to satisfy himself of the source of such credit. If during the enquiry, he is satisfied that the entries are not genuine, them he will have every right to add the said sum represented by such credit entry as income of the appellant. The satisfaction of the assessing officer is the basis of invocation of his powers under section 68. However, such satisfaction must not be illusory or imaginative but must have been derived from relevant facts and factors, and is on the basis of proper enquiry of all material before him but also to which he has commanded. Therefore u/s 68, the onus is on the appellant to offer explanation where any sum is found credited in the books of account and if the appellant offers no explanati....
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....led out, the assessee has been able to prove the genuineness also. (iv) In the case of Kanhailal Jangid vs ACIT (2008) 217 CTR 354 (Raj): Held that the burden does not go beyond to put the assessee under an obligation to further prove that where from the creditor has got or procured the money to be deposited or advanced to the assessee. The fact that the explanation furnished by the creditor about the source from where he procured the money to be deposited or advanced to the assessee is not relevant for the purposes of rejecting the explanation furnished by the assessee and make additions of such deposits as income of the assessee from undisclosed sources by invoking section 68 unless it can be shown by the Department that source of such money comes from the assessee himself or such source could be traced to the assessee itself. (v) In the case of Aravali Trading Co. vs ITO (2008) 220 CTR (Raj): Observed that the fact that the explanation furnished by the four creditors about the sources where from they acquired the money was not acceptable by the Revenue could not provide necessary nexus for drawing inference that the amount admitted to be deposited by these four....
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....on could be arrived at, no question of law as such arises." 12. In the case of CIT v. Chandra Prakash Rana [2001] 48 DTR 271 (Raj.), this Court noticed similar nature grounds urged on behalf of the revenue and found the same not leading to any substantial question of law. This Court noticed, observed, and held as under: 7. Learned counsel for the appellant (Revenue) contended that firstly Tribunal erred in accepting the explanation offered by assessee in relation to source of income. His second submission was that what was offered by assessee was no explanation and hence should not have been accepted and lastly learned counsel made sincere attempt on his part after taking us through factual scenario of the explanation and contended that it can never be taken as satisfactory explanation for deleting the addition made by AO. We do not agree to this submission for more than one reason. 8. In the first place, it is a pure question of fact, what to say question of law, much less substantial question of law. Secondly, this Court cannot again in this appeal undertake the examination of factual issues nor can draw factual inferences on the basis of explanation of....
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....ed initial burden and addition under Section 68 could not be sustained, was essentially a finding of fact. This Court said,- "19. A perusal of the aforesaid finding goes to show that deletion has been made on appreciation of evidence, which was on record Finding that there was existence of investors and their confirmation has been obtained, were found to be satisfactory. All these conclusions are conclusions of fact based on material on record and, therefore, cannot be said to be perverse so as to give rise to question of law, which may be required to be considered in this appeal under S.260A of the IT Act." 14. The ratio of the decisions aforesaid directly applies to the present case too. Herein, as noticed, the appellate authorities have returned the findings of fact in favour of the assessee after due appreciation of the evidence on record, on relevant considerations, and on sound reasonings. These findings have neither been shown suffering from any perversity nor appear absurd nor are of such nature that cannot be reached at all. Thus, no case for interference in the findings of the appellate authorities is made out. In the result, the appeal fails and is, the....
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....an assessee could demonstrate that the statements initially recorded were under pressure/coercion and factually incorrect. In our view, retraction after a sufficient long gap or point of time, as in the instant case, looses its significance and is an afterthought. Once statements have been recorded on oath, duly signed, it has a great evidentiary value and it is normally presumed that whatever stated at the time of recording of statements under Section 132(4), are true and correct and brings out the correct picture, as by that time the assessee is uninfluenced by external agencies. Thus, whenever an assessee pleads that the statements have been obtained forcefully by coercion/undue influence without material/contrary to the material, then it should be supported by strong evidence which we have observed hereinbefore. Once a statement is recorded under section 132(4) such a statement can be used as a strong evidence against the assessee in assessing the income, the burden lies on the assessee to establish that the admission made in the statements are incorrect/wrong and that burden has to be discharged by an assessee at the earliest point of time and in the instant case we notice tha....
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....dence produced by the assessee which established the fact of transaction of loan taken by the assessee, their identity, capacity and genuineness being routed through the banking channel at the time of receipt as well as repayment of the loan alongwith payment of interest which was subjected to TDS, we do not find any error or illegality in the finding of the ld. CIT(A) qua this issue, hence, we uphold the same. 9. In the result, the appeal of the Revenue is dismissed. Order pronounced in the open court on 07th January, 2019. ============= Document 1 पà¥à¤°. 34 मैं आपसे आपकी à¤à¤¾à¤—ीदारी फरà¥à¤® à¤. à¤à¤®. à¤à¤•à¥à¤¸à¤ªà¥‹à¤Ÿà¤°à¥à¤¸ बà¥à¤• में निमà¥à¤¨à¤²à¤¿à¤–ित अनसिकà¥à¤¯à¥‹à¤°à¤°à¥à¤¡ लोन कà¥à¤°à¥‡à¤¡à¤¿à¤Ÿà¤°à¥à¤¸ के लेजर दिखा रहा हूà¤- ....
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