M/s Engineers India Ltd., New Delhi V. DCIT, New Delhi

CO 158/DEL/2011

• Counselvise Citation: [2014] 122 COUNSELVISE.COM (IT) 9678 (ITAT-DELHI)
• Duration Of Justice: 3 year(s) 1 month(s) 14 day(s)
• Appeal Type: Cross Objection
• Pronouncement Date: 02-07-2014
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 30-06-2014
• Assessment Year: 2004-2005
• Appeal Filed On: 19-05-2011
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: PIYUSH SINGH
• Assessee Lawyers: PARWINDER KAUR
• Keywords: Depreciation; Earning of tax free income; Reassessment proceedings
• Section: 43B; 143(3); 14A; 147; 148

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI DELHI DELHI BENCH BENCH BENCH BENCH B BB B : NEW DELHI : NEW DELHI : NEW DELHI : NEW DELHI BEFORE SHRI H.L. KARWA, BEFORE SHRI H.L. KARWA, BEFORE SHRI H.L. KARWA, BEFORE SHRI H.L. KARWA, HONBLE HONBLE HONBLE HONBLE PRESIDENT AND PRESIDENT AND PRESIDENT AND PRESIDENT AND SHRI SHRI SHRI SHRI B.C. MEENA, B.C. MEENA, B.C. MEENA, B.C. MEENA, HONBLE HONBLE HONBLE HONBLE ACCOUNTANT ACCOUNTANT ACCOUNTANT ACCOUNTANT MEMBER MEMBER MEMBER MEMBER ITA NO ITA NO ITA NO ITA NO. .. .5391/DEL/2010 5391/DEL/2010 5391/DEL/2010 5391/DEL/2010 ASSESSMENT YEAR ASSESSMENT YEAR ASSESSMENT YEAR ASSESSMENT YEAR : : : : 2004 2004 2004 2004- -- -05 0505 05 DEPUTY COMMISSIONER OF DEPUTY COMMISSIONER OF DEPUTY COMMISSIONER OF DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX, INCOME TAX, INCOME TAX, CIRCLE CIRCLE CIRCLE CIRCLE- -- -11(1) 11(1) 11(1) 11(1), ,, , NEW DELHI. NEW DELHI. NEW DELHI. NEW DELHI. VS. VS. VS. VS. M/S ENGINEERS INDIA LIMITED, M/S ENGINEERS INDIA LIMITED, M/S ENGINEERS INDIA LIMITED, M/S ENGINEERS INDIA LIMITED, ENGINEERS INDIA BHAWAN, ENGINEERS INDIA BHAWAN, ENGINEERS INDIA BHAWAN, ENGINEERS INDIA BHAWAN, 1, BHIKAJI CAMA PLACE, 1, BHIKAJI CAMA PLACE, 1, BHIKAJI CAMA PLACE, 1, BHIKAJI CAMA PLACE, NEW DELHI NEW DELHI NEW DELHI NEW DELHI 110 066. 110 066. 110 066. 110 066. PAN : AAACE5318C. PAN : AAACE5318C. PAN : AAACE5318C. PAN : AAACE5318C. (APPELLANT) (RESPONDENT) CROSS OBJECTION CROSS OBJECTION CROSS OBJECTION CROSS OBJECTION NO NO NO NO.158/DEL/2011 .158/DEL/2011 .158/DEL/2011 .158/DEL/2011 ASSESSMENT YEAR : ASSESSMENT YEAR : ASSESSMENT YEAR : ASSESSMENT YEAR : 2004 2004 2004 2004- -- -05 0505 05 M/S ENGINEERS INDIA M/S ENGINEERS INDIA M/S ENGINEERS INDIA M/S ENGINEERS INDIA LIMITED, LIMITED, LIMITED, LIMITED, ENGINEERS INDIA BHAWAN, ENGINEERS INDIA BHAWAN, ENGINEERS INDIA BHAWAN, ENGINEERS INDIA BHAWAN, 1, BHIKAJI CAMA PLACE, 1, BHIKAJI CAMA PLACE, 1, BHIKAJI CAMA PLACE, 1, BHIKAJI CAMA PLACE, NEW DELHI NEW DELHI NEW DELHI NEW DELHI 110 066. 110 066. 110 066. 110 066. PAN : AAACE5318C. PAN : AAACE5318C. PAN : AAACE5318C. PAN : AAACE5318C. VS. VS. VS. VS. DEPUTY COMMISSIONER OF DEPUTY COMMISSIONER OF DEPUTY COMMISSIONER OF DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX, INCOME TAX, INCOME TAX, CIRCLE CIRCLE CIRCLE CIRCLE- -- -11(1), 11(1), 11(1), 11(1), NEW DELHI. NEW DELHI. NEW DELHI. NEW DELHI. (APPELLANT) (RESPONDENT) APPELLANT BY : SMT. PARWINDER KAUR, SR.DR. RESPONDENT BY : SHRI DEEPAK CHOPRA AND SHRI PIYUSH SINGH, ADVOCATES. ORDER ORDER ORDER ORDER PER B.C. MEENA, AM PER B.C. MEENA, AM PER B.C. MEENA, AM PER B.C. MEENA, AM : : : : THIS APPEAL BY THE REVENUE EMANATES FROM THE ORDER OF LEARNED CIT(A)-V, NEW DELHI DATED 17 TH SEPTEMBER, 2010. 2. THE ASSESSEE IS A GOVERNMENT OF INDIA UNDERTAKIN G UNDER THE MINISTRY OF PETROLEUM & NATURAL GAS AND PRIMARILY E NGAGED IN PROVIDING ENGINEERING AND TECHNICAL CONSULTANCY SERVICES AND EXECUTION OF CONTRACTS ON A TURNKEY BASIS PREDOMINANTLY IN OIL, GAS AND HYDROCARBON SECTORS. THE ASSESSEE HAS SUBMITTED THE RETURN OF INCOME ON 28.10.2004 DECLARING INCOME OF ` 140,04,57,990/-. THE RETURN WAS ITA-5391/D/2010 & C.O.158/D/2011 2 REVISED AND INCOME WAS REDUCED TO ` 133,76,87,880/- AND ASSESSMENT WAS COMPLETED UNDER SECTION 143(3) ON 15.12.2006. THE NOTICE UNDER SECTION 148 OF THE ACT WAS ISSUED ON 6.3.2004 AND T HE ASSESSMENT UNDER SECTION 143(3) READ WITH SECTION 147 WAS COMP LETED ON 25.8.2009 WHEREIN THREE DISALLOWANCES WERE MADE P RIOR PERIOD EXPENSES ` 3,25,46,000/-, PROVISION FOR LEAVE SALARY ` 2,29,82,152/- AND DISALLOWANCE UNDER SECTION 14A ` 1,22,68,000/-. IN APPEAL, LEARNED CIT(A) HAS DELETED THE ADDITION FOR PRIOR PERIOD EX PENSES AND PROVISION FOR LEAVE SALARY. THE ADDITION UNDER SECTION 14A W AS REDUCED TO ` 25,000/-. NOW, THE REVENUE IS IN APPEAL BEFORE US BY TAKING THE FOLLOWING GROUNDS:- 1. THE ORDER OF LD.CIT(A) IS WRONG, PERVERSE, ILLE GAL AND AGAINST THE PROVISIONS OF LAW, LIABLE TO BE SET ASI DE. 2. THE LD.CIT(A) ERRED IN DELETING THE ADDITION OF PRIOR PERIOD EXPENSES OF RS.3,25,46,000/-. 3. THE LD.CIT(A) ERRED IN DELETING THE ADDITION OF RS.2,29,82,152/- LEAVE ENCASHMENT. 4. THE LD.CIT(A) ERRED IN DELETING THE ADDITION OF RS.12,268,000/- AS EXPENDITURE INCURRED FOR EARNING INTEREST INCOME EXEMPT U/S 14A. 5. THE APPELLANT CRAVES LEAVE TO ADD, ALTER OR AMEN D ANY GROUND OF APPEAL RAISED ABOVE AT THE TIME OF HE ARING. 3. THE ASSESSEE HAS ALSO FILED CROSS-OBJECTION IN W HICH REASSESSMENT PROCEEDINGS INITIATED UNDER SECTION 14 7 OF THE ACT BY THE DCIT (AO) ARE CHALLENGED. THE GROUNDS TAKEN BY THE ASSESSEE IN THE CROSS-OBJECTION READ AS UNDER:- ITA-5391/D/2010 & C.O.158/D/2011 3 1. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE AND IN LAW, THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) [CIT(A)] ERRED IN HOLDING THAT THE REAS SESSMENT PROCEEDINGS INITIATED UNDER SECTION 147 OF THE ACT BY THE DEPUTY COMMISSIONER OF INCOME-TAX (AO') WERE NOT B AD IN LAW AND ACCORDINGLY, THE REASSESSMENT ORDER PASSED UNDER SECTION 147 OF THE ACT IS VALID AND IS THUS NOT LIA BLE TO BE QUASHED. 2. THAT THE RESPONDENT CRAVES LEAVE TO ADD, ALTER, AMEND AND/OR MODIFY ANY OF THE CROSS OBJECTIONS EIT HER BEFORE OR DURING THE COURSE OF THE APPELLATE PROCEE DINGS. 4. GROUND NOS.1 & 5 OF THE REVENUES APPEAL ARE GEN ERAL IN NATURE AND REQUIRE NO ADJUDICATION. 5. IN GROUND NO.2, THE ISSUE RELATES TO THE DELETIN G OF ADDITION OF ` 3,25,46,000/- ON ACCOUNT OF PRIOR PERIOD EXPENSES. THE CIT(A) HAS GRANTED RELIEF TO THE ASSESSEE BY HOLDING AS UNDER: - 4.2 I HAVE CAREFULLY GONE THROUGH THE ORDER OF THE AO AND THE SUBMISSIONS FILED BY THE APPELLANT. THE AO HAS OBSERVED, IN THE REASSESSMENT ORDER, AS UNDER:- THE AUTHORIZED REPRESENTATIVE OF THE ASSESSEE HAS EXPLAINED THAT, IN ACCORDANCE WITH THE METHOD OF ACCOUNTING/TAX ASSESSMENT ADOPTED SINCE ITS INCEPTI ON, THE ENTIRE AMOUNT OF EXPENDITURE PERTAINING TO THE PRE VIOUS YEAR HAS BEEN FULLY ALLOWED IN THE YEAR IN WHICH I T IS ACCOUNTED JUST AS INCOME PERTAINING TO THE PREVIOUS YEAR IS TAXED IN THE YEAR THE SAME IS ACCOUNTED FOR COMPILA TION OF ITA-5391/D/2010 & C.O.158/D/2011 4 THE FINANCIAL STATEMENTS AT THE END OF EACH ACCOUNT ING YEAR. 4.3 HOWEVER, THE APPELLANT CONTENDED THE AFORESAID EXPLANATION AS RECORDED IN THE REASSESSMENT ORDER W AS NEVER BEEN GIVEN IN THE ASSESSMENT PROCEEDINGS. TH E APPELLANT CONTENDED THAT THE PRIOR PERIOD EXPENSES HAS ALREADY BEEN ADDED IN THE INCOME. IN THIS REGARD, THE APPELLANT PRODUCED THE RETURN OF INCOME ALONG WITH THE COMPUTATION OF INCOME AND SHOWED THAT THE IMPUGNED PRIOR PERIOD EXPENSES HAS ALREADY BEEN ADDED BACK I N THE ORIGINAL RETURN OF INCOME. ON PERUSAL OF THE COMPU TATION OF INCOME, IT IS EVIDENT THAT THE PRIOR PERIOD EXPENSE S HAD ALREADY BEEN DISALLOWED IN THE COMPUTATION OF INCOM E AND ACCORDINGLY, THE DISALLOWANCE OF SUCH EXPENSES AGAI N IS NOT JUSTIFIED. IN VIEW OF THE DISCUSSION, I DIRECT THE AO TO DELETE THE ADDITION OF RS.325.46 LACS MADE ON ACCOUNT OF P RIOR PERIOD EXPENSES. THE ASSESSEES APPEAL ON THIS GRO UND IS ALLOWED. 6. WE HAVE HEARD BOTH THE SIDES ON THE ISSUE. WE H AVE ALSO PERUSED THE PAPER BOOK SUBMITTED BY THE ASSESSEE. LEARNED AR DREW OUR ATTENTION TO PAGE 12 OF THE PAPER BOOK WHICH IS THE COMPUTATION OF ASSESSABLE INCOME OF THE ASSESSEE FOR AY 2004-05 WH EREIN ITEM NO.6 & 7 HAS BEEN DISALLOWED BY THE ASSESSEE ITSELF IN THE COMPUTATION OF INCOME. KEEPING THESE FACTS IN VIEW, WE FIND NO ME RIT IN GROUND NO.2 OF THE REVENUES APPEAL AND WE UPHOLD THE ORDER OF LEARNED CIT(A) ON THIS ISSUE. 7. IN GROUND NO.3, THE ISSUE IS WITH REGARD TO DELE TING THE ADDITION OF ` 2,29,82,152/- ON ACCOUNT OF LEAVE ENCASHMENT. ON T HIS ISSUE ALSO, LEARNED AR DREW OUR ATTENTION TO PAGE 12 WHICH IS C OMPUTATION OF ITA-5391/D/2010 & C.O.158/D/2011 5 INCOME OF THE ASSESSEE IN THE YEAR UNDER CONSIDERAT ION WHEREIN THE ASSESSEE ITSELF HAS ADDED BACK THE PROVISION FOR LE AVE SALARY UNDER SECTION 43B OF THE ACT. THE CIT(A) HAS GRANTED THE RELIEF TO THE ASSESSEE BY HOLDING AS UNDER:- 5.2 IN THIS REGARD, THE APPELLANT PRODUCED THE TAX AUDIT REPORTS AND COMPUTATIONS OF INCOME (ALONG WITH THE RETURN OF INCOME) FOR THE AY 2004-05 AND 2005-06. ON PERU SAL OF TAX AUDIT REPORT FOR THE AY 2005-06, IT IS EVIDENT THAT SUM OF RS.131,342,282 REPRESENTS PROVISION FOR LEAVE ENCASHMENT CREATED DURING THE AY 2005-06 AND REMAIN ED UNPAID. THEREFORE, THE SAME IS TO BE ADDED BACK IN THE COMPUTATION OF INCOME FOR THE AY 2005-06. THE COMPUTATION OF INCOME FOR THE AY 2005-06 PRODUCED B EFORE ME CLEARLY INDICATED THAT SUCH SUM WAS CORRECTLY BE EN ADDED BACK IN THE COMPUTATION OF INCOME FOR THE AY 2005- 06. 5.3 FURTHER, TAX AUDIT REPORT FOR THE AY 2004-05 SH OWS PROVISION FOR LEAVE ENCASHMENT CREATED DURING THE Y EAR AND REMAINED UNPAID IS RS.108,360,130/- AND, ONLY S UCH SUM IS DISALLOWABLE FOR THE AY 2004-05. THE RETURN OF INCOME FOR AY 2004-05 (I.E. THE AY UNDER CONSIDERAT ION) SHOWS THAT RS.108,360,130/- HAD ALREADY BEEN ADDED BACK. THEREFORE, NO FURTHER DISALLOWANCE IS REQUIRED ON A CCOUNT OF PROVISION FOR LEAVE ENCASHMENT FOR THE AY UNDER CONSIDERATION. ACCORDINGLY, I DIRECT THE AO TO DEL ETE THE ADDITION OF RS.22,982,152/- MADE ON ACCOUNT OF PROV ISION FOR LEAVE ENCASHMENT IN THE REASSESSMENT ORDER. AC TUALLY THE ASSESSEE IS ADDING BACK THE PROVISIONS FOR LEAV E ENCASHMENT SUO MOTO AT THE END OF F.Y. EVERY YEAR. THIS GROUND OF APPEAL OF APPELLANT IS ALLOWED. ITA-5391/D/2010 & C.O.158/D/2011 6 8. AFTER HEARING BOTH THE SIDES, WE FIND NO FAULT I N THE ORDER OF LEARNED CIT(A) AND SUSTAIN THE SAME. 9. GROUND NO.4 RELATES TO THE DELETING OF PART ADDI TION MADE ON ACCOUNT OF INVOKING THE PROVISIONS OF SECTION 14A O F THE ACT. 10. WE HAVE HEARD BOTH THE SIDES ON THIS ISSUE. TH E CIT(A) HAS GRANTED PART RELIEF TO THE ASSESSEE BY HOLDING AS U NDER:- 6.2 I HAVE CAREFULLY GONE THROUGH THE ORDER OF THE AO AND THE SUBMISSIONS FILED BY THE APPELLANT. AS EVIDENT FROM THE REASSESSMENT ORDER, THE APPELLANT HAS EARNED AN EXE MPT INCOME OF RS.709.84 LAKH FROM TAX FREE BONDS OF UTI . I HAVE ALSO NOTED THAT NO REDEMPTION OR FURTHER INVES TMENT WAS MADE DURING THE YEAR BY THE APPELLANT IN THE BO NDS. THE ASSESSEE HAS THE FOLLOWING INVESTMENT IN THE BO NDS OF UTI AS PER THE BALANCE SHEET AS ON MARCH 31, 2004: RS IN LACS INVESTMENT MARCH 31, 2004 INVESTMENT IN UTI BOND 12619.42 6.3 THE AO HELD THAT THE PROVISIONS OF RULE 8D OF T HE INCOME-TAX RULES, 1962 ARE APPLICABLE IN THE INSTAN T CASE AND, DISALLOWED/ADDED BACK RS.122.68 LAKHS AS PROPORTIONATE MANAGEMENT EXPENDITURE IN THE COMPUTATION OF INCOME, WITHOUT DISCLOSING THE BASIS OF ARRIVING AT THE FIGURE DISALLOWED. I NOTE THAT THE AO HAD MENTIONED THE SAME AMOUNT OF DISALLOWANCE OF RS.122 .68 LAKHS IN THE REASONS RECORDED FOR RE-OPENING THE ASSESSMENT PROCEEDINGS AND NO BASIS WAS GIVEN. ITA-5391/D/2010 & C.O.158/D/2011 7 6.4 IN RELATION TO THE APPLICABILITY OF RULE 8D OF THE RULES, THE HON'BLE BOMBAY HIGH COURT (IN CASE OF GODREJ & BOYCE V DCIT) HAS RECENTLY HELD THAT RULE 8D WOULD APPLY WITH EFFECT FROM ASSESSMENT YEAR 2008-09. ACCORDINGLY, I AM OF THE OPINION THAT THE AO WAS INCORRECT IN HOLDING TH AT THE PROVISIONS OF SECTION 8D ARE APPLICABLE. HOWEVER, EVEN IN THE ABSENCE OF APPLICABILITY OF RULE 8D, AS HELD IN CASE OF GODREJ & BOYCE V DCIT (SUPRA), THE EXPENDITURE INCURRED/APPORTIONED TO EARN THE EXEMPT INCOME IS REQUIRED TO BE DISALLOWED. 6.5 IN THE INSTANT CASE, THE APPELLANT HAS SUBMITTE D THAT NO EXPENSE HAS BEEN INCURRED FOR EARNING THE EXEMPT INCOME AND HAS CONTENDED THAT THE DISALLOWANCE OF RS.122.68 LAKHS AS PROPORTIONATE MANAGEMENT EXPENSE S IS AN AD-HOC DISALLOWANCE WITHOUT DISCLOSING THE BASIS TO COMPUTE THE SAID FIGURE OF RS.122.68 LAKHS. 6.6 ON PERUSAL OF THE PROFIT AND LOSS ACCOUNT, IT I S EVIDENT THAT THE APPELLANT HAS TOTAL INCOME OF RS.111,741.7 1 LAKHS DURING THE SUBJECT ASSESSMENT YEAR WHICH INCLUDES E XEMPT INTEREST INCOME OF RS.709.84 LAKHS. THE EXPENDITUR E IN PROFIT AND LOSS ACCOUNTS CONSISTS OF TECHNICAL ASSISTANCE/SUB-CONTRACTS, CONSUMABLES/STORES R&D CE NTRE, CONSTRUCTION MATERIAL AND EQUIPMENT, SALARIES AND BENEFITS, FACILITIES, CORPORATE COSTS, DEPRECIATION AND OTHERS. A PERUSAL OF THE ITEMS OF EXPENDITURE SHOW S THAT IF AT ALL, ONLY THE SALARIES AND BENEFITS COULD BE, SA ID TO HAVE BEEN INCURRED IN PART TOWARDS EARNING OF THE EXEMPT INCOME. AS SUBMITTED BY THE APPELLANT, ONLY EFFORT REQUIRED TO REALIZE THE EXEMPT INCOME IS MERELY TO SEND ITA-5391/D/2010 & C.O.158/D/2011 8 SOME EMPLOYEE TO THE BANK TO DEPOSIT THE CHEQUES RECEIVED FROM UTI. DURING THE SUBJECT ASSESSMENT Y EAR, THE APPELLANT HAS RECEIVED INTEREST FROM UTI AT TWO OCCASIONS I.E. 11 CHEQUES AT A TIME. FURTHER, THE APPELLANT DID NOT RECEIVE ANY DIVIDEND FROM ITS SUBSIDIARY CERTIFICATION ENGINEER INTERNATIONAL LIMITED. IN S UCH A CASE, THE EFFORT MADE BY HIM HAS TO BE EVALUATED IN MONETARY TERMS AND MAY CONSTITUTE EXPENDITURE INCUR RED IN RELATION TO THE EARNING OF THE DIVIDEND INCOME. THERE IS ALSO NO NEED TO MAINTAIN ANY INVESTMENT PORTFOLIO D IVISION SINCE THE INVESTMENT IS IN THE UTI BONDS ONLY. THU S, IT APPEARS TO ME THAT A VERY SMALL AND NEGLIGIBLE AMOU NT OF TIME, EFFORT AND EXPENDITURE IS REQUIRED TO EARN TH E EXEMPT INTEREST INCOME. CONSIDERING THIS POSITION, EVEN I F THE DISALLOWANCE IS TO BE UPHELD IN PRINCIPLE, THE COST MAY NOT HAVE BEEN INCURRED IN EXCESS OF RS.5,000. IN THIS REGARD, RELIANCE IS PLACED ON THE HONBLE DELHI TRIBUNALS RULING IN THE CASE OF JUBILIANT ENPRO LTD. VS. DCIT (12 SOT 1 94) WHERE-IN THE HONBLE TRIBUNAL HAD RESTRICTED THE DISALLOWANCE TO RS.25,000/- EVEN THOUGH THE AO IN T HE SAID CASE HAD DISALLOWED RS.50,000/- ON AN ADHOC BASIS. ACCORDINGLY, I HOLD TO DISALLOW RS.25,000/- U/S 14A . 11. IN VIEW OF THE VARIOUS DECISIONS OF HONBLE HIG H COURTS INCLUDING HON'BLE JURISDICTIONAL HIGH COURT, WE FIND THAT THE CIT(A) WAS JUSTIFIED IN GRANTING RELIEF TO THE ASSESSEE. WE, THEREFORE, DI SMISS THIS GROUND OF REVENUES APPEAL. 12. IN THE RESULT, THE APPEAL OF THE REVENUE STANDS DISMISSED. ITA-5391/D/2010 & C.O.158/D/2011 9 13. SINCE WE HAVE DECIDED THE ISSUE ON MERITS IN TH E REVENUES APPEAL, THEREFORE, THE CROSS-OBJECTION FILED BY THE ASSESSEE REMAINS ACADEMIC AND WE ARE NOT DECIDING THIS ON MERITS. 14. IN THE RESULT, THE APPEAL OF THE REVENUE AS WEL L AS THE CROSS- OBJECTION OF THE ASSESSEE IS DISMISSED. DECISION PRONOUNCED IN THE OPEN COURT ON 2 ND JULY, 2014. SD/- SD/- ( (( (H.L. KARWA H.L. KARWA H.L. KARWA H.L. KARWA) )) ) (B.C. MEENA (B.C. MEENA (B.C. MEENA (B.C. MEENA) )) ) PRESIDENT PRESIDENT PRESIDENT PRESIDENT ACCOUNTANT MEMBER ACCOUNTANT MEMBER ACCOUNTANT MEMBER ACCOUNTANT MEMBER DATED : 02.07.2014 VK. COPY FORWARDED TO: - 1. REVENUE : DEPUTY COMMISSIONER OF INCOME TAX, DEPUTY COMMISSIONER OF INCOME TAX, DEPUTY COMMISSIONER OF INCOME TAX, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE CIRCLE CIRCLE CIRCLE- -- -11(1), NEW DELHI. 11(1), NEW DELHI. 11(1), NEW DELHI. 11(1), NEW DELHI. 2. ASSESSEE : M/S ENGINEERS INDIA LIMITED, M/S ENGINEERS INDIA LIMITED, M/S ENGINEERS INDIA LIMITED, M/S ENGINEERS INDIA LIMITED, ENGINEERS INDI ENGINEERS INDI ENGINEERS INDI ENGINEERS INDIA BHAWAN, A BHAWAN, A BHAWAN, A BHAWAN, 1, BHIKAJI CAMA PLACE, NEW DELHI. 1, BHIKAJI CAMA PLACE, NEW DELHI. 1, BHIKAJI CAMA PLACE, NEW DELHI. 1, BHIKAJI CAMA PLACE, NEW DELHI. 3. CIT 4. CIT(A) 5. DR, ITAT ASSISTANT REGISTRAR