ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE1-(2), HYDERABAD V. M/S. VPR MINING INFRASTRUCTURE PVT LTD, HYDERABAD

ITA 90/HYD/2021

AI Insights

The case involves the Income Tax Department (Revenue) appealing against the order of the CIT(A) which had partly allowed the appeal of M/s. VPR Mining Infrastructure Pvt. Ltd. (the assessee) concerning the assessment year 2015-2016. The primary issues revolved around the Transfer Pricing (TP) adjustments related to outstanding receivables from the AE and the characterization of certain transactions as loans or investments. The CIT(A) had re-characterized some transactions and adjusted the interest rates applicable to these transactions, which the Revenue contested. The Tribunal examined the appropriateness of the interest rates applied and the characterization of the transactions, ultimately upholding some of the CIT(A)'s decisions while reversing others.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 112124 (ITAT-HYDERABAD)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-04-2025
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: DB-B
• Assessment Year: 2015-2016
• Other Referred Cases: Gopal Lal Bhadruka Vs DCIT, Canara Housing Development Company Vs DCIT, CIT Vs Chennai Properties & Investment Limited
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: M. NARMADA
• Assessee Lawyers: S K GUPTA; PRODUCING SHARE CERTIFICATES
• Keywords: Condonation of delay; Transfer pricing; International transaction; TDS; Search and seizure; Block assessment; Share purchase agreement
• Section: 22; 13; 92D; 20

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “B” BENCH : HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G, ACCOUNTANT MEMBER ITA.No.90/Hyd/2021 Assessment Year 2015-2016 The ACIT, Central Circle-1(2), Hyderabad – 500 004. Telangana. vs. M/s. VPR Mining Infrastructure Pvt. Ltd., Hyderabad – 524 003. PAN AACCV6733A (Appellant) (Respondent) For Revenue : MS. M. Narmada, CIT-DR For Assessee : Shri S K Gupta, Advocate Date of Hearing : 26.03.2025 Date of Pronouncement : 16.04.2025 ORDER PER MANJUNATHA G, A.M. : This appeal has been filed by the Revenue against the order dated 28.08.2020, of the learned CIT(A)-11, Hyderabad, relating to the assessment year 2015-2016. 2. The Revenue has raised the following grounds in the instant appeal : 1. “The Ld. CIT(Appeals) erred both in law and on facts of the case in allowing relief to the assessee. 2 ITA.No.90/Hyd./2021 2. The Ld. CIT(Appeals) erred in holding that LIBOR+200 bps is the appropriate interest rate to be charged on outstanding shipping and customs clearance charges from the A.E. ignoring the fact that the assessee paid interest of Rs.21.67 cr at PLR rates which can be taken as internal CUP. 3. The Ld. CIT(Appeals) erred in deleting the TP adjustment since the initial burden of proving the claim of investment in share capital was not discharged by the assessee by producing share certificates. 4. The Ld. CIT(Appeals) erred in holding that the Revenue could not produce contrary evidence even when the assessee failed to prove its claim by discharging the initial burden lying on it. 5. The Ld. CIT(Appeals) erred in holding that entries in books of account and other approvals from regulatory authorities cannot be disregarded even when the assessee failed to produce share certificates which are the primary evidence. 6. The Ld. CIT(Appeals) erred in deleting the TP adjustment ignoring the fact that the alleged investment of Rs.2,73,06,977/ in PT, VPR Laxmindo in F.Y. 2010- 11 and receiving the same amount back on disinvestment in F.Y.2015-16 when viewed in totality 3 ITA.No.90/Hyd./2021 does not represent a rationale behavior by independent parties. 7. The Ld. CIT(Appeals) erred in determining the interest on delayed receivables from Associated Enterprises at the rate of Libor + 2% basis points ignoring the fact that potential loss of the assessee in India is the ALP factor which contributes to the additional income attributable to the assessee and therefore the TPO is justified in adopting Indian rate. 8. The Ld. CIT(Appeals) erred in holding that in an unabated assessment, additions can be made only on the basis of incriminating seized material without considering the decision of the Hon'ble jurisdictional High court in the case of Gopal Lal Bhadruka Vs DCIT (2012) 27 taxmann.com 167 and the decision of the Hon'ble Karnataka High Court in the case of M/s Canara Housing Development Company Vs DCIT (2014) taxmann.com 98. 9. The Ld. CIT(Appeals) erred in deleting the disallowance made towards delayed deposit of TDS on the ground that it is compensatory in nature without considering the decision of the Hon'ble Madras High Court in CIT Vs Chennai Properties & Investment Limited (1999) 105 Taxmann 346. 4 ITA.No.90/Hyd./2021 10. The appellant craves leaves to amend or alter any ground or add any other grounds which may be necessary. 11. Any other ground(s) that may be urged at the time of hearing.” 3. At the very outset, there is a delay of 51 days in filing the instant appeal before the Tribunal. The learned CIT-DR has filed a petition for condonation of delay contending, inter alia, that the delay has been occurred due to administrative reasons which are beyond the control. She, therefore, submitted that the delay of 51 days in filing the appeal may please be condoned in the interest of justice. 4. The Learned DR has not raised any objection. 5. We are satisfied with the reasons explained by the Learned DR in filing the appeal before the Tribunal with a delay of 51 days. We, therefore, condone the delay of 51 days in filing the appeal before the Tribunal and proceed to adjudicate the appeal as under. 6. Briefly stated facts of the case are that, the assessee company is engaged in the business of mining / excavation of coal, removal of over burden and execution of 5 ITA.No.90/Hyd./2021 other related works. The company is also engaged in execution of irrigation projects. The assessee company filed it’s original return of income on 13.11.2015 admitting total income of Rs.29,47,24,690/- for the impugned assessment year 2015-2016. The assessee also has shown a book profit of Rs.30,84,70,100/-u/sec.115JB of the Income Tax Act, 1961 [in short “the Act”]. 6.1. A search and seizure operation was carried out in the case of assessee viz., M/s.VPR Mining Infrastructure Pvt Ltd. (herein after VPRMIPL) on 06.10.2015. Consequent to search and seizure operation, notice u/sec.153A of the Income tax Act, 1961 was issued on 29.09.2016 for block assessment years from 2010-11 to 2015-16, requiring the assessee to file returns of income for the above assessment years. In response to the said notice issued u/sec.153A, the assessee company filed the return of income on 18.02.2017 admitting total income of Rs.40,47,24,690/-including an additional income of Rs.11,00,00,000/- as undisclosed income admitted during the course of search for the F.Y 2014-15 relevant to the assessment year 2015-2016. 6 ITA.No.90/Hyd./2021 Subsequently, the Assessing Officer issued notice u/sec.143(2) of the Act dated 12.06.2017 for the assessment years 2010-11 to 2015-16 which was duly served. Further, the Assessing Officer also issued notices u/sec.142(1) and u/sec.142(1) r.w.s.129 on 13.12.2017 and on 30.07.2018, respectively, calling for relevant information based on the seized material. In response, the assessee appeared from time to time and furnished the information. 6.2. The Assessing Officer after due verification and examination of the seized/impounded material and information furnished by the assessee during the assessment proceedings observed that the assessee had entered into the international transactions with it’s AE, PT VPR Laxmindo under two heads i.e., receipt of lease rentals at Rs.56,30,38,068/- and disinvestment in equity of Rs.2,73,06,977/-. Therefore, the Assessing Officer referred the matter to the Transfer Pricing Officer [in short “TPO”]. Notices u/sec.92CA were issued by the TPO on 29.12.2017, 14.05.2018, 29.08.2018, 12.10.2018 calling for information regarding the books of accounts and various other 7 ITA.No.90/Hyd./2021 information such as P & L Account, Balance Sheet, return of income, copy of documents maintained in terms of sec 92D of the Act, copies of agreements entered into with the associated enterprises, explanation regarding the basis for furnishing the particulars in Form no.3CEB. The appellant furnished the aforementioned documents. The TPO after examining the documents filed by the assessee-company, determined the TP adjustment of Rs.1,16,83,376/- vide order dated 29.10.2018 passed u/sec.92CA(3) of the Act. 6.3. Thereafter, the Assessing Officer passed Draft Assessment Order u/sec.144C(1) of the Act dated 28.12.2018 which was served upon the assessee on 29.12.2018. In response, the assessee vide letter dated 24.01.2019 has opted not to file any objection with the DRP against the adjustments made to the income declared by the assessee. Therefore, the Assessing Officer passed Final Assessment Order on 25.02.2019 u/sec.143(3) r.w.s.153A r.w.s.144C(13) of the Act and determined the total income of the assessee company at Rs.43,10,73,147/-. 8 ITA.No.90/Hyd./2021 7. Aggrieved by the Final Assessment Order dated 25.02.2019 passed by the Assessing Officer, the assessee carried the matter in appeal before the learned CIT(A). The learned CIT(A) after considering the submissions of the assessee, deleted the addition made on account of delay in payment of service tax u/sec.40(a)(ii); partly allowed the ground on account of shipping and custom clearance charges as unsecured loans from AE @ LIBOR + 2% instead of @ 14.45% [SBI PLR]; adjustment made on account of interest on receivables at LIBOR +2% bps instead of interest charged at SBI short term deposit rates by AO/TPO; deleted the addition made on account of interest on loan of Rs.39,45,858/-. Accordingly, the learned CIT(A) partly allowed the appeal of the assessee. 8. Aggrieved by the order of the learned CIT(A), the Revenue is in appeal before the Tribunal. 9. The first issue that came-up for consideration from ground no.2 to 5 of Revenue’s appeal is TP adjustment in respect of outstanding receivable from AE towards 9 ITA.No.90/Hyd./2021 reimbursement of shipping expenses and it’s re- characterisation as “loan” and imputing of interest. During the course of TP proceedings, the TPO noticed that the assessee had incurred expenditure of Rs.5,01,01,126/- on shipping and customs clearance in connection with transportation of the leased equipment from the premises of the assesse in India to the premises of the AE in Indonesia. As per clause-5(H) of the lease agreement dated 24.02.2011, the transportation charges and other incidental charges to be borne by the AE. However, the assessee had incurred said expenditure and claimed it as an expenditure against the lease rental without recovering the same from the AE during the F.Y. 2011-2012. Therefore, the Assessing Officer treated the amount of shipping expenditure incurred by the assessee for transportation of lease equipment as incurred on behalf of the AE and the same to be recovered by the assessee. Since the assessee has not recovered the amount and the same has been treated as loan receivable from the AE and accordingly worked-out the interest on receivables 10 ITA.No.90/Hyd./2021 by taking into account SBI PLR as on 31.03.2015 @ 14.75% and determined the TP adjustment of Rs.72,39,630/-. 10. Being aggrieved by the assessment order, the assessee preferred an appeal before the learned CIT(A) and contended that re-characterisation of transaction with AE as loan is contrary to the TP proceedings as prescribed u/sec.92C of the Income Tax Act, 1961 [in short “the Act”]. The assessee further contended that if at all the interest need to be imputed on the said notional receivable, then, it should be at LIBOR + appropriate spread, but, not SBIPLR as claimed by the learned Assessing Officer/TPO. The learned CIT(A) after considering the relevant submissions of the assessee and also taking note of reasons given by the Assessing Officer/TPO observed that the transaction between the appellant and it’s AE towards expenditure on shipping for transportation of leased machinery is an international transaction and the same needs to be benchmarked. Since the assessee has receivable from the AE which is an international transaction, the appropriate rate for benchmarking interest receivable on said 11 ITA.No.90/Hyd./2021 transaction is LIBOR + 200 basis points instead of SBIPLR @ 14.75% adopted by the TPO. Therefore, the learned CIT(A) has directed the Assessing Officer/TPO to compute interest by adopting LIBOR + 200 basis points on the total outstanding receivable from the AE. 11. Aggrieved by the learned CIT(A) order, the Revenue is in appeal before the Tribunal. 12. Ms. M Narmada, learned CIT-DR, submitted that, the learned CIT(A) has erred in not appreciating the fact that the assessee has borrowed funds and paid interest at PLR rates which could be taken as internal CUP for the purpose of benchmarking the interest receivable from the AE on outstanding receivables. 13. Shri S.K. Gupta, Learned Counsel for the Assessee, on the other hand, supporting the order of the learned CIT(A) submitted that the transaction between the appellant and it’s AE is an international transaction. Once the transaction is treated as outstanding receivable from the AE, then, the interest rate prevailing at the country in which 12 ITA.No.90/Hyd./2021 the AE is situated or the repayment in which said loan or receivable is payable is relevant for deciding the rate of interest. Since the transaction is an international transaction, the learned CIT(A) has rightly directed the Assessing Officer/TPO to adopt LIBOR + 200 basis points as against the SBI PLR @ 14.75% adopted by the Assessing Officer/TPO. Therefore, the order of the learned CIT(A) should be upheld. 14. We have heard both the parties, perused the material on record and the orders of the authorities below. Although, the assessee has not treated shipping and other expenses incurred on behalf of the AE for transportation of leased machinery is an international transaction and reported in Form No.3CEB, but the TPO has re- characterised the said transaction as receivable from the AE and imputed interest by adopting SBI PLR @ 14.75% p.a. Before the learned CIT(A), although, the assessee has contended re-characterisation of transaction, but, made an argument for adopting LIBOR + appropriate spread for imputing interest. The learned CIT(A) has held that the 13 ITA.No.90/Hyd./2021 transaction between the assessee and it’s AE is an international transaction which needs to be benchmarked and accordingly, applied LIBOR + 200 basis points for imputing interest. Therefore, the issue on hand to the extent of re-characterisation of transaction is reached finality at the level of learned CIT(A) itself. 15. Further, once the transaction is treated as an international transaction, then, the next question comes to our mind is, what is the appropriate rate for benchmarking interest on such transaction. There is no dispute with regard to the fact that it has receivables from AE and in our considered view, the relevant factors for considering appropriate rate of interest is country of residence of the AE and currency in which such outstanding amount is repayable. Since the assessee’s AE is situated outside India, LIBOR + appropriate spread is the most appropriate rate of interest for benchmarking the interest on outstanding receivables. Since the learned CIT(A) has adopted LIBOR + 200 basis points, in our considered view, going by the settled position of law, there is no error in the reasoning 14 ITA.No.90/Hyd./2021 given by the learned CIT(A) in directing the Assessing Officer/TPO to adopt LIBOR + 200 basis points for benchmarking interest on receivables from AE. Thus, we are inclined to uphold the findings of the learned CIT(A) and reject ground nos.2 to 5 of the Revenue. 16. The next issue that came-up for consideration in ground no.6 of Revenue’s appeal is TP adjustment made on account of interest on receivables. During the course of TP proceedings, the learned TPO noted that the appellant has shown an amount of Rs.2,73,06,977/- loan to it’s AE, PT, VPR Laxmindo, Indonesia and claiming the same as “investments”. The TPO rejected the claim of the assessee and treated the amount given to it’s AE as loan and accordingly imputed interest by applying SBI PLR @ 14.75% and made TP adjustment of Rs.40,27,779/-. On appeal, the learned CIT(A), deleted the addition made by the Assessing Officer towards interest receivable on loan to AE on the ground that the transaction between the appellant and it’s AE is an investment, but, not as loan as considered by TPO. 15 ITA.No.90/Hyd./2021 17. Aggrieved by the learned CIT(A) order, the Revenue is now in appeal before the Tribunal. 18. Ms. M Narmada, learned CIT-DR, submitted that, the learned CIT(A) has erred in deleting the TP adjustment towards interest receivable on loan given to AE without appreciating the fact that the assessee could not substantiate the claim of investment with relevant evidences including share certificate, if any, issued by the AE. Therefore, she submitted that the order of the learned CIT(A) should be reversed and the addition made by the Assessing Officer should be upheld. 19. Shri S K Gupta, Learned Counsel for the Assessee, on the other hand, supporting the order of the learned CIT(A) submitted that the assessee has filed all evidences including initial investment made with AE and subsequent sale of said investment by filing relevant evidences. The assessee also proved the claim of receivable from the AE by placing relevant evidences for receipt of consideration in the subsequent financial year. The learned CIT(A) after considering the submissions of the assessee has 16 ITA.No.90/Hyd./2021 rightly treated the amount as investment and accordingly directed the Assessing Officer/TPO to delete the TP adjustment in respect of interest on receivable on said transactions. Therefore, he submitted that the order of the learned CIT(A) should be upheld. 20. We have heard both the parties, perused the material on record and the orders of the authorities below. The TPO treated the transaction between the appellant and it’s AE at Indonesia as loan on the ground that the appellant has not filed relevant evidences including share allotment certificate, annual report of AE to prove the same as investment. On the other hand, the assessee has filed relevant evidences including Minutes of Board Meeting and copy of the request letter as to outward remittance as investment. The learned CIT(A), after considering the relevant evidences has held that the transaction between the appellant and it’s AE at Indonesia is an investment, but, not loan as considered by the TPO and, therefore, re- characterisation of the said transaction without any valid reason is incorrect. In our considered view, the finding of 17 ITA.No.90/Hyd./2021 fact recorded by the learned CIT(A) was uncontroverted by the Revenue with any other evidence. Therefore, we are inclined to uphold the order of the learned CIT(A) and reject ground no.6 taken by the Revenue. 21. The next issue that came-up for consideration through ground no.7 of the Revenue’s appeal is, interest on outstanding receivable from AE. The TPO has treated outstanding receivable from AE as international transaction and imputed interest by applying SBI short-term deposit rate after allowing standard credit period of 30 days. The learned CIT(A) uphold the transaction of receivable as international transaction, however, directed the Assessing Officer/TPO to impute interest by applying LIBOR + 200 basis as against the SBI short-term deposit rate adopted by the TPO. 22. Ms. M Narmada, learned CIT-DR, submitted that, the learned CIT(A) has erred in determining the interest on delayed receivables from the AE @ LIBOR + 200 basis points ignoring the fact that the potential loss of the assessee in India is the ALP factor which contradicts to additional 18 ITA.No.90/Hyd./2021 income accrued to the assessee and, therefore, the TPO is justified in adopting Indian rate. 23. Shri S K Gupta, Learned Counsel for the Assessee, on the other hand, supporting the order of the learned CIT(A) submitted that since it is an international transaction and repayable in currency other than Indian currency, the appropriate rate for benchmarking the interest is the internationally recognized rate like LIBOR and thus, the learned CIT(A) has rightly adopted LIBOR + 200 basis points and, therefore, the order of the learned CIT(A) should be upheld. 24. We have heard both the parties, perused the material on record and the orders of the authorities below. There is no dispute with regard to the fact that the outstanding receivable from AE is an international transaction as defined u/sec.92B of the Income Tax Act, 1961. In fact, the assessee has accepted the re- characterisation of receivable as international transaction. However, disputed the rate of interest applied by the Assessing Officer and standard credit period allowed for 19 ITA.No.90/Hyd./2021 computing the interest. The Assessing Officer allowed standard credit period of 30 days and applied SBI short- term deposit rate and computed interest on receivables. The learned CIT(A) has adopted LIBOR + 200 basis points as against the SBI short-term deposit rate. In our considered view, there is no error in the reasons given by the learned CIT(A) to adopt LIBOR + 200 basis points because relevant rate of interest for benchmarking the interest is the country of residence of the AE and currency in which the said amount is receivable. Since the outstanding receivable from AE is receivable in foreign currency, in our considered view, the internationally recognized rates is appropriate for benchmarking the interest receivable. The learned CIT(A) after considering the relevant facts, has rightly adopted LIBOR + 200 basis points as against the SBI short-term deposit rate applied by the TPO/Assessing Officer. Thus, we are inclined to uphold the finding of the learned CIT(A) on this issue and reject the ground taken by the Revenue. 20 ITA.No.90/Hyd./2021 25. The next issue that came-up for consideration from ground no.9 of Revenue’s appeal is, deletion of additions made by the Assessing Officer towards disallowance of interest on service tax and TDS respectively. 26. The Assessing Officer has disallowed interest on service tax of Rs.46,44,685/- and TDS of Rs.23,56,426/- u/sec.40(a)(ii) of the Act as inadmissible expenses. The assessee challenged the disallowance of interest paid on service tax, however, not challenged the interest paid on delayed remittances of TDS. The learned CIT(A) deleted the interest on delay in payment of service tax by holding that the said expenditure is compensatory in nature and not penal and, therefore, allowable as deduction. 27. Ms. M Narmada, learned CIT-DR, submitted that, the learned CIT(A) has erred in deleting the additions made by the Assessing Officer towards disallowance of interest on service tax without appreciating the fact that the said expenditure is penal in nature which cannot be allowed as deduction. 21 ITA.No.90/Hyd./2021 28. Shri S K Gupta, Learned Counsel for the Assessee, on the other hand, supporting the order of the learned CIT(A) submitted that the assessee has not challenged disallowance of interest payable on TDS. However, interest paid on service tax is deductible expenditure because the said expenditure is in the nature of compensatory expenses, but, not penal. The learned CIT(A) after considering the relevant facts has rightly deleted the addition made by the Assessing Officer and, therefore, the order of the learned CIT(A) should be upheld. 29. We have heard both the parties, perused the material on record and the orders of the authorities below. Although, the Assessing Officer has disallowed interest on service tax and interest on TDS, but, the assessee has challenged only disallowance of interest on service tax before the learned CIT(A) and the learned CIT(A) has rightly allowed relief and held that the said expenditure is compensatory in nature, but, not penal in nature. Therefore, in our considered view, the ground raised by the Revenue in light of disallowance of interest on TDS is 22 ITA.No.90/Hyd./2021 correct and, therefore, we restrict our adjudication in respect of disallowance of interest on service tax alone. The learned CIT(A) has recorded categorical finding that interest on service tax is a compensatory in nature, but, not penal in nature. Therefore, in our considered view, there is no error in the findings recorded by the learned CIT(A) to allow relief to the assessee in respect of disallowance of interest on service tax. Thus, we are inclined to uphold the findings of the learned CIT(A) and reject ground no.9 of the Revenue. 30. The next issue that came-up for consideration through ground no.8 of Revenue’s appeal is, challenging the findings of the learned CIT(A) in deleting the addition made by the Assessing Officer towards various disallowances in light of date of search and first proviso to sec.153A of the Act. 31. Ms. M Narmada, learned CIT-DR, referring to the date of search i.e., 06.10.2015 submitted that the assessment year in question is an ‘abated’ assessment which is evident from the date of search and the time limit available for issue of notice u/sec.143(2) of the Act. 23 ITA.No.90/Hyd./2021 However, the learned CIT(A) by taking note of return of income filed by the assessee i.e., dated 27.02.2012 held that time limit for issue of notice u/sec.143(2) is expired before the date of search and the assessment is “unabated” and accordingly, the additions made by the Assessing Officer/ TPO is not legally tenable. However, the fact remains that assessee has filed return of income on 13.11.2015 and, therefore, the question of assessment being unabated as on the date of search does not arise and consequently, the findings recorded by the learned CIT(A) is incorrect and needs to be set-aside. 32. Shri S K Gupta, Learned Counsel for the Assessee, on the other hand, fairly agreed that the assessee does not wish to challenge the ground taken by the Revenue challenging the findings of the learned CIT(A). 33. We have heard both the parties, perused the material on record and the orders of the authorities below. There is no dispute with regard to the fact that a search and seizure operation was carried-out in the case of the appellant on 06.10.2015 and the assessee has filed it’s 24 ITA.No.90/Hyd./2021 original return of income on 13.11.2015. At the time of search i.e., on 06.10.2015, the assessment for the impugned assessment year is abated because the assessee itself has filed it’s original return of income on 13.11.2015 and further, the time limit for issue of notice u/sec.143(2) of the Act is available up-to 30.09.2016. Therefore, in our considered view, the assessment is ‘abated’ as on the date of search and consequently, the Assessing Officer can make additions without there being any incriminating material found as a result of search. The learned CIT(A) without appreciating the relevant facts and also by taking incorrect date of filing of return of income has held that, assessment year is ‘unabated’ and the Assessing Officer cannot make any additions in absence of incriminating material. Therefore, we reverse the findings of the learned CIT(A) on this issue and allow the ground no.8 taken by the Revenue. 34. In the result, appeal of the Revenue is partly allowed. 25 ITA.No.90/Hyd./2021 Order pronounced in the open Court on 16.04.2025 Sd/- Sd/- [VIJAY PAL RAO] [MANJUNATHA G] VICE PRESIDENT ACCOUNTANT MEMBER Hyderabad, Dated 16th April, 2025 VBP Copy to 1. The ACIT, Central Circle-1(2), 7th Floor, Aaykar Bhavan, Basheerbagh, Hyderabad – 500 004. Telangana. 2. M/s. VPR Mining Infrastructure Pvt. Ltd., 3rd Floor, Plot No.1259, Lakshmi Towers, Road No.36, Jubilee Hills, Hyderabad – 524 003. 3. The CIT(A)-11, 6th Floor, Aaykar Bhavan, Basheerbagh, Hyderabad – 500 004. Telangana. 4. The Pr. CIT-(Central), Hyderabad. 5. The DR ITAT “B” Bench, Hyderabad. 6. Guard File. //By Order// //True Copy// "