Sita Ram Sharma, Jaipur vs Assessee

Jh vkj-ih-rksykuh] U;kf;d lnL; ,oa Jh Vh-vkj-ehuk] ys[kk lnL; ds le{k BEFORE: SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM

vk;dj vihy la-@ITA No. 726/JP/2013 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Sita Ram Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BHKPS 7928 H vihykFkhZ@Appellant izR;FkhZ@Respondent

vk;dj vihy la-@ITA No. 66/JP/2014 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Sita Ram Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BHKPS 7928 H vihykFkhZ@Appellant izR;FkhZ@Respondent

vk;dj vihy la-@ITA No. 725/JP/2013 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Madan Lal Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BISPS 9998 E vihykFkhZ@Appellant izR;FkhZ@Respondent 2 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

vk;dj vihy la-@ITA No. 64/JP/2014 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Madan Lal Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BISPS 9998 E vihykFkhZ@Appellant izR;FkhZ@Respondent

vk;dj vihy la-@ITA No. 724/JP/2013 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Rameshwar Sharma cuke Income Tax Officer, 164 Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BHKPS 7922 P vihykFkhZ@Appellant izR;FkhZ@Respondent

vk;dj vihy la-@ITA No. 67/JP/2014 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Rameshwar Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BHKPS 7922 P vihykFkhZ@Appellant izR;FkhZ@Respondent 3 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

vk;dj vihy la-@ITA No. 723/JP/2013 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Hanuman Sahai Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BITPS 7514 P vihykFkhZ@Appellant izR;FkhZ@Respondent

vk;dj vihy la-@ITA No. 65/JP/2014 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Hanuman Sahai Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BITPS 7514 P vihykFkhZ@Appellant izR;FkhZ@Respondent

vk;dj vihy la-@ITA No. 722/JP/2013 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Bansi Lal Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BHSPS 3742 R vihykFkhZ@Appellant izR;FkhZ@Respondent 4 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

vk;dj vihy la-@ITA No. 68/JP/2014 fu/kZkj.k o"kZ@Assessment Year : 2007-08

Bansi Lal Sharma cuke Income Tax Officer, Seemavato Ki Dhani, Village Vs. Ward-7(2), Jaipur. Sanjharia, Post- Thikariya, Tehsil- Sanganer, district- Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BHSPS 3742 R vihykFkhZ@Appellant izR;FkhZ@Respondent

fu/kZkfjrh dh vksj ls@ Assessee by : Shri Mukesh Khandelwal (CA) jktLo dh vksj ls@ Revenue by : Mrs. Neena Jeph (JCIT)

lquokbZ dh rkjh[k@ Date of Hearing : 27/04/2015 ?kks"k.kk dh rkjh[k@ Date of Pronouncement : 01/05/2015

vkns'k@ ORDER

PER: BENCH

All the appeals filed by the different assessees against the orders

dated 14/12/2010 and 21/11/2013 passed by the learned CIT (A)-III,

Jaipur for A.Y. 2007-08. The common effective grounds of all the

appeals are as under:-

Common grounds of ITA of the year 2013

"1 That the ld. CIT(A) has erred seriously in sustaining addition on account of long term capital gain on sale of land at Rs. 81,75,583/- without appreciating that the land sold by the appellant was an agricultural 5 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

land in terms of section 2(14) of the Income Tax Act, 1961.

2. That the ld CIT(A) erred in allowing relief to the appellant U/s 54B and 54F of the Income Tax Act, 1961 to the tune of Rs. 12,94,999/- only."

Grounds of ITA of the year 2014 "1 Under the facts and circumstances of the case the ld CIT(A) has erred seriously is sustaining the penalty against all the assessees of all the appeals of Rs.

18,45,465/-, Rs. 18,25,623/-, Rs. 18,45,887/-, Rs. 18,35,687/- and Rs. 18,28,290/- levied by the ld.

A.O. U/s 271(1)(c) of the Income Tax Act, 1961."

2. Assessees are different in each case. In all the cases, the

assessees' appeals are against sustaining addition on account of long

term capital gain on sale of land at Rs. 81,75,583/- without appreciating

the land sold by the appellant was an agricultural land in terms of

Section 2(14) of the Income Tax Act, 1961 (in short the Act). The ld

Assessing Officer observed that the department had received

information from bank that the assessees had sold his land to M/s

Vatika Ltd. on 31/5/2006 for sale consideration of Rs. 5,72,48,520/-.

The notice U/s 142(1) of the Act was issued to all the assessees to file

their returns of income for A.Y. 2007-08 by 20/09/2007 but no

compliance was made by the assessees. Assessees namely in case of

Sita Ram Sharma and Madan Lal Sharma filed their return of income

with ITO Ward 7(2), Jaipur on 03/2/2009 declaring NIL income and the 6 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

assessees namely Rameshwar Sharma, Hanuman Sahay Sharma and

Bansi Lal Sharma filed their return of income with ITO Ward 7(2), Jaipur

on 04/10/2007 declaring different incomes. The factum of the case is

that the assessee alongiwth five of his brothers sold their ancestral land

for Rs. 5,72,48,520/-, in which a share was Rs. 95,41,420/- being 1/6th

of the total sale consideration. It was submitted by the assessee before

the Assessing Officer that this land was situated beyond 8 km from the

municipal limit of Jaipur Nagar Nigam and thus it was not a capital asset

and further there is no liability on his part to add the same in his

income. He has further submitted a certificate from Sarpanch, gram

panchayat- Thikaria, Jaipur in his support. He has further given a chart

showing therein that this long term capital gain liability as long term

capital loss. The ld Assessing Officer further observed that on receipt of

information as a scaled map of its municipal limits the land in dispute is

within 8 km of the municipal limit of Jaipur Nagar Nigam. This land also

is within 8 km from the Bagru a town having population of more than

10,000/- as per census of year 2001. The assessee was allowed to

reasonable opportunity of being heard but no reply was filed by the

assessees. It was further found by the Assessing Officer that this land

was sold to M/s Vatika Ltd. was treated as a capital assets U/s 2(14) of 7 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

the Act by the then A.O. where detail field inquiry were also got

conducted by him in this regard. The appellant repeated the same reply

as discussed above, no evidence has been filed for the claim that the

land was outside 8 km from the municipal limits. Accordingly, he held

that land sold by the assessee is a capital assets as envisaged U/s 2(14)

of the Act. The assessee had acquired the said land in inheritance in the

year 1992 as claimed by him but he had not adduced any documentary

evidence in support of his contention. Therefore, he applied cost of

acquisition of land as on 01/4/1981 on the basis of case decided by the

ld CIT(A) in cases of Shri Ram Niwas, Shri Jagdish Prasad Sharma and

Shri Rameshwar Sharma @ 4312.56 per bigha. This rate also proposed

to assessee and asked to comment on it but no reply has been filed by

the assessee before the Assessing Officer. Therefore, he took the cost

of acquisition @ 4312.56 per bigha. Finally long term capital gain was

calculated at Rs. 94,70,582/-. The assessee also claimed deduction U/s

54B and 54F of the Act, which was considered by the Assessing Officer

on page 5 of the assessment order. The ld Assessing Officer further

held that deduction claimed by the assessee U/s 54B at Rs. 9,41,733/-

for purchase of land measuring 20 bighas and 18 biswa with all his

brothers at village Kankrala, Tehsil- Mojamadabad, district- Jaipur on 8 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

simple agreement without any registered deed and also no evidence of

payment of amount to the seller were found to the Assessing Officer

without any basis. The Assessing Officer also has not considered these

agreements to sale on the basis of discrepancy pointed out in

paragraphs 6.3 to 6.6 on page 7 of the assessment order. Similar

findings were given by the Assessing Officer on not allowing deduction

U/s 54F of the Act. Thus, he allowed exemption U/s 54B and 54F of the

Act on Rs. 12,94,999/- in each case. Net long term capital gain was

assessed at Rs. 81,75,583/- in each case.

3. Being aggrieved by the orders of the learned Assessing Officer,

the assessees carried the matter before the learned CIT(A), who had

allowed the appeal partly by observing in all cases that on the basis of

scaled map of Jaipur Nagar Nigam, this land is within 8 km of the

municipal limit. Therefore, impugned land comes under capital assets as

envisaged in Section 2(14) of the Act. Further land sold was within 8 km

of Bagru town, it has population in 2001 more than 10,000/-. It is

clarified by the ld CIT(A) that these facts were brought to notice of the

assessee but no evidence to disprove these facts had been produced by

him. Accordingly he confirmed the Assessing Officer's finding on long

term capital gain. He further held that cost of acquisition as on 9 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

01/4/1981 also taken by the ld Assessing Officer on the basis of Shri

Ram Niwas Sharma and Shri Jagdish Prasad Sharma, which has been

confirmed by him in another case @ 4312.56 per bigha. The assessee

also furnished the additional evidence that his father died on 18/2/1991

and also furnished the copy of death certificate to him. The assessee

also claimed that in case of Nangi Devi, W/o- Prakash Narayan, R/o-

Ramrajpura, Sodala, Jaipur, who sold agricultural land in village

Sanjharia and as per this sale deed, the sale price in 1991 had been

taken at Rs. 29614/- per bigha. Therefore, he accepted these evidences

under Rule 46A of the Income Tax Rules, 1962 (in short the Rules) on

which he also called for remand report from the Assessing Officer but

the assessees had not cooperated with the Assessing Officer at the time

of remand proceedings, therefore, no cognizance has been taken by the

ld CIT(A). Accordingly, he confirmed the order of the Assessing Officer.

4. Now the assessees are in appeals before us but the appeals filed

are belated by 921 days for which he filed condonation application

alongwith affidavit of the assessee as well as affidavit of the advocate

and claimed that appellants being illiterate agriculturists were under

bonafide belief and they were not liable to pay the tax on the

agricultural land sole by them. These facts were also submitted before 10 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

the ld CIT(A) that they are not liable to pay any long term capital gain

on agricultural land. The ld CIT(A)-III, Jaipur held in case of Kamla Devi

Sharma, who had also sold land in village Sanjharia to M/s Vatika

Limited not liable to pay tax on capital gain. In penalty proceeding also

initiated and imposed by the Assessing Officer they claimed the same

that no tax was liable to pay as long term capital gain on agricultural

land. The agricultural land situated at village Sanjharia jointly owned by

all six brothers, which was sold to M/s Vatika Limited. The Hon'ble

Bench in case of Smt. Kamla Devi Sharma in ITA No. 526/JP/2011 vide

order dated 28/08/2014 and in case of Dr. Shubha Tripathi in ITA No.

1129/JP/2011 order dated 24/05/2013 decided the appeal in favour of

the assessee. The ld CIT(A)'s order was not communicated by the then

advocate and repercussion of not filing appeal against the order of

CIT(A)'s order dated 24/12/2010 could not be realized being illiterate

agriculturists. It is fact that this land is not capital assets as envisages

in Section 2(14) of the Act being beyond 8 km of the municipal limits.

The ld AR further relied upon the following decisions on condonation of

delay:

(i) Collector, Land Acquisition Vs. Mst. Katji (167 ITR 471):

11 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

(ii) Motilal Padampat Sugar Mills Co. Ltd. Vs. State of Uttar

Pradesh & Others (1979) 118 ITR 326:

(iii) N. Balakrishnan Vs. M. Krishnamurthy (1998) 7 SCC 123:

Therefore, he prayed to condone the delay and appeal filed by the

assessees are allowed to be heard on merit.

5. At the outset, the Ld. DR vehemently opposed the submission

filed by the assessees and argued that every day of delay is to be

explained by the appellants as held by the various courts. She relied on

the decision of this Hon'ble Bench in the case of M/s KGNMMW

Educational research & Analysis Society Vs. ITO in ITA Nos. 402 &

403/JP/2012 order dated 13/02/2015. The case laws cited by the

assessee are not squarely applicable on condonation of delay on facts

of the assessees' case.

6. We have heard the rival contentions of both the parties and

perused the material available on the record. All the six brothers are

illiterate agriculturalists. They are ignorant with the IT law. The affidavit

filed by the advocate support the claim of the assessee that he had not

informed and impressed upon the assessee about repercussion of the

legal proceedings under the IT Act and also forget the matter to remind

these assessees as file of these assesses were mixed in the other files

12 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

of his office. Further the adjacent land has been treated agricultural

assets as envisaged in Section 2(14) of the Act in the case of Kamla

Devi Sharma vide order dated 23/3/2011 for A.Y. 2007-08 and order

dated 28/08/2014 by the ITAT of this bench but confirmed that the land

situated in Sanjharia village is not a capital asset as envisaged in

Section 2(14) of the Act. When in case of others, the ITAT has decided

the capital assets outside the 8 km from the municipal limits and non

condoning the delay by the Bench will tantamount to miscarriage of

justice. The legal position on this issue is as under:-

(i) Collector, Land Acquisition Vs. Mst. Katji (167 ITR 471):

Held that "When substantial justice and technical considerations are pitted against each other, cause of substantial justice deserves to be preferred".

(ii) Motilal Padampat Sugar Mills Co. Ltd. Vs. State of Uttar Pradesh & Others (1979) 118 ITR 326: held that " it is impossible to know all the statutory provisions of law and hence the principle that everyone is presumed to know the law is not applicable universally since it is of a very different scope and application."

(iii) N. Balakrishnan Vs. M. Krishnamurthy (1998) 7 SCC 123:

Held that "words "sufficient cause" under Section 5 of the

13 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

Limitation Act should received a liberal construction so as to advance substantial justice."

The Hon'ble Supreme Court has held in the case of Collector, Land

Acquisition Vs. Mst. Katiji (supra) that substantial justice and technical

considerations are pitted against each other, the cause of substantial

justice deserved to be preferred. In this case also, it is a fact that

appeal filed by the appellants belated for years if this Bench has not

condoned the delay of the assessees then the assessees would not get

justice and which is against the technical objections to file the appeal

belatedly. In the interest of substantial justice, we feel that delay should

be condoned and the assessee is allowed to be heard on merit.

7. Now coming on merit of the case, the impugned land sold by

these assessees bearing khasra No. 500/1239, 532, 432/1166, 533,

542, 543, 545, 546 and 548 in joint name of all these brothers in village

Sanjharia, post Thikariya, Tehsil Sanganer being agricultural land to M/s

Vatika Ltd. for Rs. 5,72,48,520/- on 21/5/2006. The assessees have

1/6th share of total consideration of Rs. 5,72,48,520/- at Rs.95,41,420/-.

The AR of the assessees submitted that land sold is outside the

municipal limit and is more than 8 km. It is argued that in case of Smt.

Kamla Devi Sharma, who also sold her land of Sanjharia village to M/s 14 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

Vatika Ltd. on 16/05/2006, it has been held by the Hon'ble ITAT that

these lands situated beyond 8 km from the municipal limits and is not

capital assets as envisaged U/s 2(14) of the Act. The ld AR further

argued that in case of Dr. Subha Tripathy Vs. DCIT, Circle-6, Jaipur ITA

No. 1129/JP/2011 vide order dated 24/5/2013, it has been held that

distance of agricultural land is to be measured as it was as on

06/1/1994 i.e. the date of notification of CBDT circular No. 9447 and

not as on date of sale. Since in the present case, the distance of land is

more than 8 km from municipal limits during 2011 then during 2006-07

it was definitely many more kms away from municipal limit as the

organization has increased the area rapidly during the period from year

1994 to 2011. It is further argued that in case of assessee, one of the

assessee's brother Shri Ram Sahay Sharma who also sold his land

alongwith his brothers where case was reopened U/s 147 wherein ld

Assessing Officer himself had accepted the same part of land as not a

capital assets envisaged U/s 2(14) of the Act. He further drawn our

attention on letter dated 15/2/2011 addressed to ITO Ward 7(2), Jaipur

that village Sanjharia, Tehsil Sanganer, Khasra No. 319 and 320 are

beyond 9 kms from the municipal limits. The ld AR also argued that

municipality notified whole village to be included in the municipal area 15 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

not part and partial of the land of particular khasra number. Therefore,

he argued that all the khasra numbers of village Sanjharia, Tehsil-

Sanganer are beyond 8 kms from the municipal limits. Accordingly, he

prayed to allow the appeals of the assessees.

8. The ld DR vehemently supported the order of the ld CIT(A) and

argued that the assessees had not submitted any evidence before the

lower authority to prove that the impugned land sold by all the brothers

beyond 8 km from the municipal limits. Therefore, order of the ld

CIT(A) may please be confirmed.

9. We have heard the rival contentions of both the parties and

perused the material available on the record. The land sold by all the

brothers situated in village- Sanjhaia, Tehsil- Sanganer, district- Jaipur.

In case of assessee's brother namely Shri Ram Sahay Sharma in A.Y.

2007-08 by the ITO ward 7(2), Jaipur order dated 25/03/2013 had not

made any addition on account of long term capital gain. Further the ld

CIT(A) as well as this Bench also allowed the appeal in case of Smt.

Kamla Devi Sharma (supra), who also sold her land at Sanjharia village

to M/s Vatika Ltd. on 16/05/2006 and held that the agricultural land

sold by the assessee is not capital assets as envisaged U/s 2(14) of the

Act as same was sold to Vatika Ltd. within a short span of time. The 16 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

other case laws relied by the assessee is also squarely applicable.

Therefore, we hold that the land sold by all the assessees are

agricultural land and beyond 8 KMs from the municipal limits.

Accordingly, we allow this ground of all the appeals.

10. Ground No. 2 of the all the appeals are against not allowing the

relief U/s 54B and 54F of the Act on different amounts. As we have

decided the land sold by these assessees as not capital assets as

envisaged in Section 2(14) of the Act, we need not to express our views

on these deductions as these deductions is based on capital assets

envisaged in Section 2(14) of the Act.

11. Now we are deciding the penalty orders passed U/s 271(1)(c) of

the Act. The ld. Assessing Officer imposed penalty U/s 271(1)(c) of the

Act, which has been confirmed by the ld CIT(A) in all the cases but as

decided above, the land sold is not capital assets as envisaged in

Section 2(14) of the Act and held agricultural land, which is not come

under the purview of taxable income. No concealment of particulars of

income or furnished inaccurate particulars of income is there.

Therefore, we delete the penalty in all the cases. Thus, we allow the

appeals in all the cases.

17 ITA 726/JP/2013 & 66/JP/2014 & Ors. cases_ Sita Ram Sharma Vs. ITO & Ors. cases

12. In the result, all the assessees' appeals are allowed.

Order pronounced in the open court on 01/05/2015.

Sd/- Sd/- ¼vkj-ih-rksykuh½ ¼Vh-vkj-ehuk½ (R.P.Tolani) (T.R. Meena) U;kf;d lnL;@Judicial Member ys[kk lnL;@Accountant Member

Tk;iqj@Jaipur fnukad@Dated:- 01st May, 2015

*Ranjan

vkns'k dh izfrfyfi vxzsf'kr@Copy of the order forwarded to:

1. vihykFkhZ@The Appellants- Sita Ram Sharma, Madan Lal Sharma, Rameshwar Sharma, Hanuman Sahai Sharma, Bansi Lal Sharma, Jaipur

2. izR;FkhZ@ The Respondent- ITO, Ward-7(2), Jaipur.

3. vk;dj vk;qDr@ CIT

4. vk;dj vk;qDr¼vihy½@The CIT(A)

5. foHkkxh; izfrfuf/k] vk;dj vihyh; vf/kdj.k] t;iqj@DR, ITAT, Jaipur

6. xkMZ QkbZy@ Guard File (ITA Nos. 726, 725, 724, 723, 722 /JP/2013 & ITA No. 66,64,67,65,68/JP/2014 )

vkns'kkuqlkj@ By order,

lgk;d iathdkj@Asst. Registrar