M/s. Sri Abirami Leathers Company, CHENNAI V. ITO, CHENNAI

CO 173/CHNY/2009

• Counselvise Citation: [2010] 122 COUNSELVISE.COM (IT) 5252 (ITAT-CHENNAI)
• Duration Of Justice: 11 month(s) 5 day(s)
• Appeal Type: Cross Objection
• Pronouncement Date: 08-10-2010
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: C
• Next Hearing Date: 22-09-2010
• Assessment Year: 2006-2007
• Appeal Filed On: 03-11-2009
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: B SRINIVAS
• Section: 142(1); 144

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL BENCH C CHENNAI BEFORE SHRI ABRAHAM P.GEORGE, AM AND SHRI GEORGE MATHA N, JM .. I.T.A. NO. 1319/MDS/2009 A Y: 2006-07 THE INCOME-TAX OFFICER BUSINESS WARD 1(4) TAMBARAM VS. M/S SRI ABIRAMI LEATHER COMPANY NO. 50, UMAYALPURAM CHROMPET CHENNAI 600 044. (PAN: AAWFS 0605 F) (APPELLANT) (RESPONDENT) CO NO. 173/MDS/2009 [A/O I.T.A. NO. 1319/MDS/2009] A Y: 2006-07 M/S SRI ABIRAMI LEATHER COMPANY VS. THE INCOME-TAX OFFICER NO. 50, UMAYALPURAM BUSINESS WARD 1(4) CHROMPET TAMBARAM CHENNAI 600 044. (PAN: AAWFS 0605 F) ASSESSEE BY : SHRI PHILIP GEORGE SHRI M.P. SENTHIL KUMAR DEPARTMENT BY : SHRI B. SRINIVAS O R D E R PAGE 2 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 PER ABRAHAM P. GEORGE, AM THIS IS AN APPEAL FILED BY THE REVENUE AND A CROSS OBJECTION BY THE ASSESSEE, BOTH AGAINST THE ORDER OF THE LD. CIT (A)-IX, CHENNAI. REVENUES APPEAL IS TAKEN UP FIRST FOR DISPOSAL. 2. GROUND NOS. 1 AND 8 RAISED BY THE REVENUE ARE GE NERAL IN NATURE AND DO NOT NEED ADJUDICATION. 3. VIDE ITS GROUND NO. 2, REVENUE IS AGGRIEVED THAT THE LD. CIT(A) DIRECTED FURTHER VERIFICATION IN RESPECT OF JOB WOR K EXPENSES RS. 13,74,277/- AND ELECTRICITY CHARGES RS. 2,33,725/-, ON A REASONING THAT THE ASSESSING OFFICER HAD NOT GIVEN PROPER OPPORTUN ITY TO THE ASSESSEE. ACCORDING TO THE REVENUE, LD. CIT(A) WAS NOT HAVING POWER FOR SETTING ASIDE THE ASSESSMENT FROM 1.6.2001. 4. SHORT FACTS APROPOS ARE THAT ASSESSEE, ENGAGED I N THE BUSINESS OF MANUFACTURING OF FINISHED LEATHERS, HAD, FOR THE IM PUGNED ASSESSMENT YEAR, FILED A RETURN OF INCOME DISCLOSING INCOME OF RS.1,52,104/-. IN RESPONSE TO NOTICE U/S 142(1) OF THE INCOME-TAX ACT , 1961 [IN SHORT, PAGE 3 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 THE ACT], ASSESSEE SOUGHT ADJOURNMENT FOR A REASON THAT ITS AUDITOR WAS HOSPITALIZED. ASSESSING OFFICER THEN ISSUED A SHOW CAUSE NOTICE WHEREIN HE REQUIRED THE ASSESSEE TO EXPLAIN AS TO W HY 25% OF THE EXPENSES AND TRADE CREDITORS BALANCES SHOULD NOT BE DISALLOWED FOR WANT OF DETAILS. AS PER THE ASSESSING OFFICER, ONE SHRI A.L. ANNAMALAI, MANAGER OF THE ASSESSEE FIRM WHO WAS ALSO THE HUSBA ND OF ITS MANAGING PARTNER, APPEARED WITH BOOKS AND THESE WER E VERIFIED. HOWEVER, ASSESSING OFFICER WAS OF THE OPINION THAT THESE WERE ONLY PARTLY PRODUCED AND HENCE HE GAVE ONE MORE OPPORTUN ITY FOR PRODUCING THE BOOKS. ASSESSEE THEREUPON PRODUCED T HE BALANCE BOOKS OF ACCOUNTS ALONGWITH A LIST OF TRADE CREDITORS. A SSESSING OFFICER SENT LETTERS FOR CONFIRMING BALANCES TO THE RESPECTIVE C REDITORS. AS PER THE ASSESSING OFFICER, OUT OF 37 CREDITORS, 15 REPLIED WHEREIN SOME TALLIED AND SOME HAD MINOR DIFFERENCES. BASED ON THE BOOKS PRODUCED, ASSESSING OFFICER WAS OF THE OPINION THAT THERE WER E DISCREPANCIES IN PURCHASES AND JOB WORK EXPENDITURE OF RS. 5,81,454/ - AND RS. 13,74,277/-. THIS WAS ADDED TO ITS INCOME. ASSESS EE HAD ALSO CLAIMED OFFICE MAINTENANCE EXPENSES OF RS. 3,11,994/- AGAIN ST WHICH ASSESSING OFFICER ALLOWED ONLY RS. 1,37,200/- BEING PAYMENT T O ONE M/S VAJRA SECURITY FORCE RESULTING IN ADDITION OF RS. 1,74,71 4/-. AGAIN, AS PER PAGE 4 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 ASSESSING OFFICER, PROPER BILLS AND VOUCHERS WERE N OT PRODUCED FOR EXPENSES ON TRANSPORT AND CONVEYANCE, PETROL, MACHI NERY MAINTENANCE AND GENERAL EXPENSES TOTAL OF WHICH CAME TO RS. 1,8 6,143/-. 1/4 TH OF THE EXPENSES COMING TO RS. 46,536/- WAS ALSO DISALL OWED. AGAINST ELECTRICITY CHARGES AMOUNTING TO RS. 4,09,493/- CLA IMED BY ASSESSEE, THE BILLS PRODUCED AS PER THE ASSESSING OFFICER COU LD CORROBORATE THE CLAIM OF RS. 1,75,768/- ONLY AND THEREFORE, BALANCE OF RS. 2,33,725/- WAS ADDED. HE ALSO MADE AN ADDITION OF RS. 1,97,71 0/- FOR DIFFERENCE BETWEEN CONFIRMATIONS FILED BY CREDITORS AND BOOK B ALANCES. SINCE 24 CREDITORS DID NOT GIVE ANY REPLY TO THE LETTERS SEN T BY ASSESSING OFFICER OR FOR A REASON THAT THE LETTERS WERE RETURNED BACK OUT OF TOTAL AMOUNT OF RS. 73,54,178/- SHOWN AS DUES TO THEM, 1/4 TH WAS DISALLOWED. THIS DISALLOWANCE CAME TO RS. 18,38,545/-. VIS-A-VIS U NSECURED LOANS OF RS. 1,10,000/- SHOWN BY THE ASSESSEE, ASSESSING OFF ICER WAS OF THE OPINION THAT IT HAD NOT FILED ANY EVIDENCE AND HE T REATED IT AS BOGUS AND MADE AN ADDITION OF RS. 1,10,000/-. ASSESSMENT WAS COMPLETED ON THESE LINES. 5. BEFORE THE LD. CIT(A), ONE OF THE GROUNDS TAKEN BY ASSESSEE WAS THAT PROPER OPPORTUNITY WAS NOT GIVEN TO IT WITH RE GARD TO DISALLOWANCE PAGE 5 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 OF JOB WORK EXPENSES OF RS. 13,74,277/- AND ELECTRI CITY EXPENSES OF RS. 2,33,725/-. LD. CIT(A), VIDE HIS DIRECTIONS AT PAR A 7 AND 9 OF HIS ORDER REQUIRED THE ASSESSING OFFICER TO VERIFY THE BOOKS FOR CONSIDERING ANY TDS DEDUCTIONS MADE ON THE JOB WORK VIS-A-VIS CLAI M OF JOB WORK EXPENSES AND ALSO FOR CONSIDERING THE ELECTRICITY SERVICE METRE CARD BEFORE MAKING DISALLOWANCE OF ELECTRICITY CHARGES. 6. NOW BEFORE US, THE LD. D.R. IS VEHEMENTLY SUBMIT TING THAT THE LD. CIT(A) HAD NO POWER OF REMAND AND THE ASSESSING OFF ICER HAD GIVEN ASSESSEE MORE THAN SUFFICIENT OPPORTUNITIES. 7. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS. BEFORE THE ASSESSING OFFICER, ASSESSEE HAD STATED T HAT ITS AUDITOR WAS ADMITTED IN HOSPITAL AND HENCE IT COULD NOT ENTER A PPEARANCE IN THE INITIAL STAGES. IT IS AN ADMITTED POSITION THAT TH E ASSESSEE PRODUCED AT LEAST A PART OF THE BOOKS OF ACCOUNT INITIALLY AND THESE WERE VERIFIED BY THE ASSESSING OFFICER. IT IS ALSO ADMITTED BY THE ASSESSING OFFICER THAT THE REMAINING PART OF THE BOOKS WERE ALSO PRODUCED BY ASSESSEE LATER ON WHEN FINAL OPPORTUNITY WAS GIVEN TO IT. WE HOWE VER FIND THAT THE ASSESSEE WAS NOT PUT ON NOTICE REGARDING HIS PROPOS AL TO DISALLOW PART PAGE 6 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 OF THE CLAIM OF JOB WORK EXPENSES AND ELECTRICITY C HARGES. EVEN IF TAKE THAT THE LD. CIT(A) HAD NO POWER OF REMAND, WE ARE OF THE CONSIDERED OPINION THAT THE MATER INDEED REQUIRED A SECOND LOO K BY THE ASSESSING OFFICER. HENCE WE ENDORSE THE DIRECTION OF THE LD. CIT(A) THAT THESE CLAIMS HAVE TO BE RE-VERIFIED BY ASSESSING OFFICER WITH THE BOOKS OF ACCOUNT. ASSESSEE HAS TO BE GIVEN AN OPPORTUNITY T O PRODUCE NECESSARY EVIDENCE IN SUPPORT OF CLAIM OF EXPENSES. WE DO NOT FIND ANY PREJUDICE CAUSED TO THE REVENUE ON ACCOUNT OF T HE DIRECTION GIVEN BY THE LD. CIT(A). GROUND NO. 2, THEREFORE, IS DIS MISSED. 8. VIDE ITS GROUND NO. 3, REVENUE IS AGGRIEVED THAT DISALLOWANCE OF GENERAL EXPENSES RS. 46,536/- AND OFFICE MAINTENANC E EXPENSES RS. 1,74,714/- MADE BY THE ASSESSING OFFICER, WERE DELE TED. 9. LD. CIT(A) DELETED THE ABOVE DISALLOWANCE ON A F INDING THAT THESE WERE ADHOC AND ARBITRARY. WE FIND FROM THE ORDER O F THE ASSESSING OFFICER THAT HE HAD MADE AN ADHOC DISALLOWANCE OF G ENERAL AND MAINTENANCE EXPENSES CITING THE REASON THAT PROPER BILLS AND VOUCHERS WERE NOT PRODUCED. HOWEVER, AT PARAS 4 AND 5 OF TH E ASSESSMENT, IT IS MENTIONED BY THE ASSESSING OFFICER THAT BOOKS OF AC COUNT WERE PARTLY PAGE 7 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 PRODUCED INITIALLY WHICH WERE VERIFIED AND LATER ON THE ASSESSEE HAD PRODUCED THE REMAINING BOOKS ALSO. ASSESSING OFFIC ER HAS NOT BEEN ABLE TO POINT OUT WHAT WAS IMPROPER IN THE BILLS AN D VOUCHERS PRODUCED BY THE ASSESSEE AND WHICH OF THE EXPENSES WERE NOT PROPERLY EVIDENCED. THE ADDITION WAS, THEREFORE, MADE ON SH EER ADHOC BASIS, PURELY ON PRESUMPTION AND THEREFORE, RIGHTLY DELETE D BY THE LD. CIT(A). NO REASON TO INTERFERE IS SEEN. GROUND NO. 3, THER EFORE, STANDS DISMISSED. 10. VIDE ITS GROUND NO. 4, REVENUE IS AGGRIEVED THA T THE LD. CIT(A) DELETED AN ADDITION OF RS. 1,97,000/- BEING DIFFERE NCES IN CREDIT BALANCES. 11. LD. CIT(A) HAD DELETED THE ADDITION MADE BY THE ASSESSING OFFICER FOR DIFFERENCE IN CREDIT BALANCE AS PER BOO KS OF ACCOUNT OF ASSESSEE AND AS PER CONFIRMATION OF THE CREDITORS F OR THE REASON THAT THE ASSESSING OFFICER NEVER CALLED FOR A RECONCILIA TION FROM THE ASSESSEE. WE FIND FROM THE ORDER OF THE ASSESSING OFFICER THAT THE PURCHASES AND SALES DECLARED BY ASSESSEE WERE NOT D OUBTED BY THE ASSESSING OFFICER. OF COURSE, HE HAD MADE AN ADDIT ION OF RS. PAGE 8 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 5,81,454/- FOR ALLEGED INFLATION IN PURCHASE ACCOUN T. HOWEVER, LD. CIT(A) HAD DELETED SUCH DISALLOWANCE WITH A FINDING THAT THERE WAS NO SUCH INFLATION. REVENUE HAS NOT RAISED ANY GROUND AGAINST THIS. ONCE PURCHASES ARE CONSIDERED TO BE GENUINE, THEN TRADE CREDITORS BALANCE COULD NOT BE DISTURBED UNLESS ANY OF THE PAYMENTS M ADE TO THEM WERE NOT REFLECTED IN THE ACCOUNTS. THERE IS NO SUCH FI NDING BY THE ASSESSING OFFICER NOR HAD HE REQUIRED THE ASSESSEE TO FURNISH A RECONCILIATION STATEMENT. WE ARE OF THE CONSIDERED OPINION THAT THE LD. CIT(A) WAS WELL JUSTIFIED IN DELETING SUCH DISA LLOWANCE. NO INTERFERENCE IS CALL FOR. GROUND NO 4 OF THE REVEN UE STANDS DISMISSED. 12. VIDE ITS GROUND NO 5, GRIEVANCE OF THE REVENUE IS THAT THE LD. CIT(A) DELETED AN ADDITION OF RS. 18,38,545/- BEING 25% OF THE BALANCE IN TRADE CREDITORS ACCOUNT, WHICH WERE NOT CONFIRME D. 13. FOR A REASON THAT 24 PARTIES TO WHOM LETTERS WE RE SENT HAD NOT RESPONDED OR FOR A REASON THAT THE LETTERS WERE RET URNED, ASSESSING OFFICER HAD CONSIDERED 1/4 TH OF THE TOTAL DUES TO SUCH PARTIES AS UNPROVED. LD. CIT(A) DELETED THE ADDITION FOR A RE ASON THAT THIS WAS ILLEGAL AND ARBITRARY. PAGE 9 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 14. AFTER HEARING THE PARTIES, WE ARE OF THE CONSID ERED OPINION THAT THE LD. CIT(A) WAS FULLY JUSTIFIED IN DELETING THE DISALLOWANCE. IN THE FIRST PLACE ALL THESE WERE BALANCES IN TRADE CREDIT ORS ACCOUNTS. EXCEPT FOR FINDING SMALL PART OF THE PURCHASES COMING TO R S. 5,81,454/- TO BE INFLATED THERE WAS NO DISALLOWANCE WHATSOEVER MADE BY THE ASSESSING OFFICER, NOR HAD HE TREATED ANY PURCHASES TO BE BOG US. EVEN SUCH DISALLOWANCE STOOD DELETED BY THE LD. CIT(A). JUST BECAUSE LETTERS SENT TO TRADE CREDITORS WERE NOT RESPONDED OR RETURNED B ACK, WE CANNOT PRESUME THAT THE BALANCES WERE INCORRECT. ASSESSIN G OFFICER DID NOT SPECIFICALLY POINT WHICH PARTIES HAD NOT RESPONDED AND WHICH OF THEM WERE RETURNED UNSERVED. ASSESSING OFFICER HAD ACCE PTED 75% OF THE BALANCES AND MADE ADDITION OF ONLY 25%. WE ARE UNA BLE TO UNDERSTAND THE LOGIC BEHIND THIS. THERE CANNOT BE AN ESTIMATE MADE FOR UNPROVED CREDIT BALANCES. HAVING FOUND THAT 75% BALANCES WE RE CORRECT, ASSESSING OFFICER HAD NO REASON WITH HIM TO CONCLUD E THAT THE BALANCE OF 1/4 TH WAS INCORRECT. IN OUR OPINION, THIS ADDITION WAS ARBITRARY AND RIGHTLY DELETED BY THE LD. CIT(A). GROUND NO. 5 TH EREFORE, STANDS DISMISSED. PAGE 10 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 15. VIDE ITS GROUND NO. 6, GRIEVANCE OF THE REVENUE IS THAT AN ADDITION OF RS. 1,10,000/- WHICH WAS MADE BY ASSESS ING OFFICER FOR UNPROVED UNSECURED LOAN WAS DELETED BY THE LD. CIT( A). 16. LD. CIT(A) HAD DELETED THE ADDITION OF UNPROVED LOANS FOR A REASON THAT THESE WERE NOT LOANS RELATING TO RELEVA NT PREVIOUS YEAR BUT WERE ACCEPTED BY THE ASSESSEE 2 TO 3 YEARS BACK. N OTHING WAS BROUGHT ON RECORD BY THE REVENUE TO REBUT THIS FINDING OF T HE LD. CIT(A). THUS, IF THE LOANS WERE TAKEN IN AN EARLIER YEAR, EVEN IF IT WAS UNPROVED, COULD HAVE BEEN CONSIDERED FOR ADDITION ONLY IN SUC H EARLIER YEAR. ADDITION MADE FOR THE IMPUGNED ASSESSMENT YEAR WAS RIGHTLY DELETED. GROUND NO. 6 OF THE REVENUE STANDS DISMISSED. 17. VIDE ITS GROUND NO. 7, REVENUE IS AGGRIEVED THA T THE LD. CIT(A) DIRECTED THE ASSESSING OFFICER TO ADOPT GROSS PROFI T RATE OF 13.2% IN LIEU OF VARIOUS ADDITIONS MADE IN THE COURSE OF ASS ESSMENT. 18. LD. CIT(A) HAD, VIDE PARA 14 OF HIS ORDER, HELD AS UNDER: PAGE 11 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 14. FROM THE ASSESSMENT ORDER, IT APPEARS THAT THER E WAS A RESISTANCE FROM THE APPELLANT'S SIDE AT THE TIME OF ASSESSMENT PROCEEDINGS. THEY HAVE PRODUCED CERTAIN DETAILS AND ON CERTAIN DATES. THE APPELLANT HAS NOT PRODUCED FULL BOOKS OF ACCOUNTS. DUE TO THESE REASO NS, THE LEARNED ASSESSING OFFICER HAS COMPLETED THE ASSESSM ENT U/S 144 OF THE INCOME TAX ACT. HE HAS ISSUED SHOW C AUSE NOTICE FOR DISALLOWING THE 25% OF THE EXPENSES AND SUNDRY CREDITORS U/S 144 OF THE INCOME TAX ACT. BUT AT THE TIME OF PASSING ASSESSMENT ORDER, HE DEVIATED FROM THAT SHO W CAUSE. WHATEVER ADDITION HE HAS MADE FROM THAT, HE HAS NOT ISSUED ANY SHOW CASE NOTICE. I HAVE VERIFIED TH E GROSS PROFIT SHOWN BY THE APPELLANT FOR EARLIER YEARS ALS O. APPELLANT HAS SHOWN GROSS PROFIT OF 10.9 % FOR THE FINANCIAL YEAR 04-05 AND 13.2 % FOR THE FINANCIAL YEAR 03-04. SINCE APPELLANT HAS NOT CO-OPERATED IN THE ASSESSMENT PROCEEDINGS, LEARNED ASSESSING OFFICER HAS NOT VERI FIED THE BILLS AND VOUCHERS, CERTAIN ADDITION IS REQUIRED. A FTER CONSIDERING THESE FACTS, THE LEARNED ASSESSING OFFI CER IS DIRECTED TO ADOPT THE GROSS PROFIT OF 13.2 % WHICH IS DECLARED BY THE APPELLANT FOR THE FINANCIAL YEAR 03 -04. ALL THE ADDITIONS ARE DELETED, ONLY G.P ADDITION WILL B E MADE. PAGE 12 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 19. ORDER OF THE ASSESSING OFFICER WOULD CLEARLY SH OW THAT THE ASSESSEE WAS ABLE TO PRODUCE ALL BILLS AND VOUCHERS , BUT THE ASSESSING OFFICER WAS NOT SATISFIED WITH IT. THOUGH THE ASS ESSING OFFICER COULD NOT POINT OUT ANY SPECIFIC FAILURE, THERE COULD BE SOME LAPSES HERE AND THERE. IF WE CONSIDER THE VOLUME OF BUSINESS OF AS SESSEE, ITS PURCHASES WELL EXCEEDED RS. 1.70 CRORES. SINCE NO SUFFICIENT RECORDS HAVE BEEN FILED BY REVENUE, WE ARE UNABLE TO FIND EXACT SALES TURNOVER OF THE ASSESSEE. NEVERTHELESS, PRESUMING THE SALES TURNOV ER TO BE SOMEWHERE IN THE VISIBILITY OF RS. 1.70 CRORES, APP LICATION OF GROSS PROFIT RATE OF 13.2% WOULD RESULT IN A GROSS PROFIT OF MORE THAN RS. 22 LAKHS. ASSESSEE HAD RETURNED AN INCOME OF RS. 1,52 ,104/- ONLY. WHEN THE VARIOUS ADDITIONS WHICH HAVE BEEN MADE BY THE A SSESSING OFFICER WHICH WERE DELETED BY THE LD. CIT(A) AND WHICH DELE TIONS UPHELD BY US SUPRA ARE CONSIDERED WE ARE AT A LOSS TO UNDERSTAND HOW THE REVENUE COULD BE AGGRIEVED ON THE DIRECTION OF THE LD. CIT( A) FOR ADOPTING GROSS PROFIT RATE OF 13.2%. LD. COUNSEL FOR ASSESS EE WAS FAIR TO ADMIT THAT ASSESSEE HAD NOT FILED ANY APPEAL ON THIS ASPE CT ONLY FOR A REASON THAT IT WANTED TO AVOID LITIGATION. WE ARE OF THE OPINION THAT THE REVENUE COULD NOT HAVE ANY MEANINGFUL GRIEVANCE ON THIS DIRECTION OF THE LD. CIT(A). HENCE GROUND NO. 7 OF THE REVENUE STANDS DISMISSED. PAGE 13 OF 13 I.T.A. NO. 1319 & CO. 173/MDS/2010 20. WHEN THE CROSS OBJECTION OF THE ASSESSEE TAKEN UP, LD. COUNSEL FOR ASSESSEE ADMITTED THAT IT WAS FILED WITH A SUBS TANTIAL DELAY. HE WAS NOT HAVING ANY PROPER EXPLANATION FOR THE DELAY NOR WAS THERE ANY PETITION FILED FOR CONDONING THE DELAY. THEREFORE, THE CROSS OBJECTIONS OF THE ASSESSEE ARE DISMISSED. 21. IN THE RESULT, BOTH THE APPEAL OF THE REVENUE A S WELL AS THE CROSS OBJECTIONS OF THE ASSESSEE ARE DISMISSED. PRONOUNCED IN THE COURT ON 08.10.2010. SD/- SD/- ( GEORGE MATHAN) ( ABRAHAM P.GEORGE ) JUDICIAL MEMBER ACCOUNTANT MEMBER CHENNAI, DATED THE 8 TH OCTOBER, 2010. VL COPY TO: ASSESSEE/AO/CIT (A)/CIT/D.R./GUARD FIL E