M/s Parvathi Combines, Visakhapatnam V. THE ACIT., CIRCLE - 1(1), Visakhapatnam

CO 35/VIZ/2015

• Counselvise Citation: [2016] 123 COUNSELVISE.COM (IT) 2402 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 9 month(s) 27 day(s)
• Appeal Type: Cross Objection
• Pronouncement Date: 16-09-2016
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2007-2008
• Appeal Filed On: 19-11-2015
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: C V S MURTHY
• Assessee Lawyers: S RAVI SANKAR NARAYAN
• Keywords: Cost of acquisition; Tangible material; Fair market value; Difference of opinion; Change of opinion
• Section: 143(3); 147; 148

Judgement Text

ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 1 , , IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM . , . , $ BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER & SHRI G. MANJUNATHA, ACCOUNTANT MEMBER ./I.T.A.NO.59/VIZAG/2013 ( / ASSESSMENT YEAR: 2007-08) ACIT, CIRCLE - 1(1), VISAKHAPATNAM VS. M/S. PARVATHI COMBINES, VISAKHAPATNAM [P AN: AABFP4929L ] ( % / APPELLANT) ( &'% / RESPONDENT) C.O. NO.35/VIZAG/2015 (ARISING OUT OF I.T.A.NO.59/VIZAG/2013) ( / ASSESSMENT YEAR: 2007-08) M/S. PARVATHI COMBINES, VISAKHAPATNAM VS. ACIT, CIRCLE - 1(1), VISAKHAPATNAM ( % / APPELLANT) ( &'% / RESPONDENT) / APPELLANT BY : SHRI S. RAVI SANKAR NARAYAN, DR / RESPONDENT BY : SHRI C.V.S. MURTHY, AR / DATE OF HEARING : 23.08.2016 / DATE OF PRONOUNCEMENT : 16.09.2016 ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 2 / O R D E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: THIS APPEAL FILED BY THE REVENUE AND THE CROSS OBJ ECTION FILED BY THE ASSESSEE ARE DIRECTED AGAINST THE COMMON ORD ER PASSED BY THE CIT(A), VISAKHAPATNAM DATED 27.11.2012 AND IT PERTA INS TO THE ASSESSMENT YEAR 2007-08. SINCE, THE FACTS ARE IDEN TICAL AND ISSUES ARE COMMON, THEY ARE CLUBBED, HEARD TOGETHER AND DISPOS ED OFF, BY WAY OF THIS COMMON ORDER FOR THE SAKE OF CONVENIENCE. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E IS A PARTNERSHIP FIRM FILED ITS RETURN OF INCOME FOR THE ASSESSMENT YEAR 2007-08 ON 31.7.2007 DECLARING TOTAL INCOME OF ` 4,01,61,570/-. SUBSEQUENTLY, THE ASSESSMENT WAS COMPLETED ON 30.12.2009 U/S 143(3) O F THE INCOME TAX ACT, 1961 (HEREINAFTER CALLED AS 'THE ACT') AND DET ERMINED TOTAL INCOME OF ` 5,87,74,303/-. THEREAFTER, THE ASSESSMENT WAS RE- OPENED U/S 147 OF THE ACT, FOR THE REASONS THAT DUE TO INCORRECT A PPLICATION OF MARKET VALUE OF LAND RATE OF POORNA MARKET AREA OF ` 600/-.P.SQ.YD., INSTEAD OF ALLIPURAM WARD AREA OF ` 100/- P.SQ.YD., RESULTING SHORT ASSESSMENT OF LONG TERM CAPITAL GAIN. ACCORDINGLY, NOTICE U/S 14 8 OF THE ACT, WAS ISSUED TO THE ASSESSEE REQUIRING HIM TO FURNISH RET URN OF INCOME. SUBSEQUENTLY, THE CASE HAS BEEN SELECTED FOR SCRUTI NY ASSESSMENT AND ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 3 ACCORDINGLY, NOTICE U/S 143(2) OF THE ACT WAS ISSUE D. IN RESPONSE TO NOTICE, THE AUTHORIZED REPRESENTATIVE OF THE ASSESS EE APPEARED FROM TIME TO TIME AND FILED DETAILS CALLED FOR. 3. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE A.O. NOTICED THAT THE ASSESSEE HAS ADOPTED FAIR MARKET VALUE OF THE PROPERTY AS ON 1.4.1981 AT ` 450/- P.SQ.YD, TO COMPUTE COST OF ACQUISITION OF T HE PROPERTY TO DETERMINE LONG TERM CAPITAL GAIN FROM S ALE OF PROPERTY AT ALLIPURAM AREA. TO ASCERTAIN THE CORRECTNESS OF CLA IM MADE BY THE ASSESSEE, THE A.O. ISSUED A SHOW CAUSE NOTICE AND A SKED TO EXPLAIN WHY THE VALUE OF ` 600/- P.SQ.YD. APPLIED SHOULD BE ACCEPTED, WHEN COMMERCIAL MUNICIPAL VALUE OF THE PROPERTY WAS AT ` 100/- P.SQ.YD. AS PER THE CERTIFICATE ISSUED BY THE REGISTERING AUTHO RITY. IN RESPONSE TO SHOW CAUSE NOTICE, THE ASSESSEE SUBMITTED THAT IT H AS ADOPTED FAIR MARKET VALUE OF THE PROPERTY AT ` 450/- P.SQ.YD. BASED ON THE MARKET VALUE OF THE PROPERTY, FIXED BY THE STATE GOVERNMEN T IN THE YEAR 1982. AS PER THE REVISED MARKET VALUE OF THE PROPERTY, TH E STATE GOVERNMENT HAS FIXED ` 600/- P.SQ.YD. IN POORNA MARKET AREA, WHICH WAS DI SCOUNTED BY 25% TO ARRIVE AT FAIR MARKET VALUE OF THE PROPER TY AS ON 1.4.1981 BASED ON THE DECISION OF COORDINATE BENCH OF ITAT, VISAKHAPATNAM IN THE CASE OF SRI V.V. HARI PRASAD (SUPRA). THE ASSE SSEE FURTHER SUBMITTED ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 4 THAT THE STATE GOVERNMENT HAS NOT REVISED MARKET VA LUE OF THE PROPERTY AFTER 1975, THEREFORE, ADOPTING A FAIR MARKET VALUE WHICH WAS FIXED IN THE YEAR 1975 FOR THE YEAR 1981 IS NOT AT ALL CORRE CT. THE A.O. AFTER CONSIDERING THE EXPLANATION FURNISHED BY THE ASSESS EE, HELD THAT THE PROPERTY SOLD BY THE ASSESSEE IS LOCATED IN A DIFFE RENT PLACE THAN POORNA MARKET AREA AND THE MARKET VALUE OF THE PROPERTY AS PER THE CERTIFICATE OF THE REGISTERING AUTHORITY IS AT ` 100 P.SQ.YD. THE ASSESSEE HAS ADOPTED A FAIR MARKET VALUE OF THE PROPERTY AT ` 450/- P.SQ.YD., BY DISCOUNTING 25% ON THE RATE FIXED IN THE YEAR 1982 WITHOUT ANY BASIS. WITH THESE OBSERVATIONS, REJECTED FMV ADOPTED BY THE ASSESSEE AND RE- COMPUTED LONG TERM CAPITAL GAIN BY TAKING INTO ACCO UNT THE FAIR MARKET VALUE OF THE PROPERTY AT ` 100/- P.SQ.YD. 4. AGGRIEVED BY THE ASSESSMENT ORDER, THE ASSESSEE PREFERRED APPEAL BEFORE THE CIT(A). BEFORE THE LD. CIT(A), THE ASSE SSEE CHALLENGED THE VALIDITY OF RE-OPENING OF ASSESSMENT AND ALSO CONTE NDED ISSUES ON MERITS. AS REGARDS RE-OPENING OF ASSESSMENT, THE AS SESSEE SUBMITTED THAT THE A.O. HAS RE-OPENED THE ASSESSMENT WITH A C HANGE OF OPINION WITHOUT ANY FRESH MATERIALS IN HIS POSSESSION TO FO RM BELIEF THAT THE INCOME CHARGEABLE TO TAX HAS BEEN ESCAPED ASSESSMEN T. AS REGARDS MERITS OF THE ISSUE, THE ASSESSEE SUBMITTED THAT TH E A.O. WAS INCORRECT ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 5 IN STATING THAT THE PROPERTY SOLD BY THE ASSESSEE I S LOCATED IN A DIFFERENT PLACE. THE ASSESSEE FURTHER SUBMITTED THAT AS PER T HE CERTIFICATE ISSUED BY THE SUB-REGISTRAR, THE PROPERTY OF THE ASSESSEE LOCATED IN A MUCH PREMIER AREA THAN POORNA MARKET AREA AND ALSO THE F AIR MARKET VALUE ADOPTED BY THE ASSESSEE IS BASED ON THE REVISED RAT ES OF FAIR MARKET VALUE FIXED BY THE STAMP DUTY AUTHORITIES IN THE YE AR 1982. SINCE, THE STATE GOVERNMENT HAS NOT REVISED FAIR MARKET VALUE OF THE PROPERTY, THE ASSESSEE HAS RE-WORKED FAIR MARKET VALUE OF THE PRO PERTY BY TAKING INTO ACCOUNT VALUE FIXED BY THE STATE GOVERNMENT AUTHORI TIES IN THE YEAR 1982 BY DISCOUNTING 25% OF THE VALUE BASED ON THE D ECISION OF COORDINATE BENCH OF ITAT, VISAKHAPATNAM IN THE CASE OF V.V. HARI PRASAD (SUPRA), WHICH IS IN ACCORDANCE WITH LAW AND SHOULD BE ACCEPTED. 5. THE CIT(A) AFTER CONSIDERING THE EXPLANATION FUR NISHED BY THE ASSESSEE, REJECTED THE CONTENTION OF THE ASSESSEE W ITH REGARD TO RE- OPENING OF ASSESSMENT AND UPHELD THE RE-OPENING. T HE CIT(A) FURTHER HELD THAT AS CAN BE SEEN FROM THE REASONS RECORDED BY THE A.O., THERE IS TANGIBLE MATERIAL COME TO THE CONCLUSION THAT THERE IS ESCAPEMENT OF INCOME. THEREFORE, IT IS NOT CORRECT TO SAY THAT IT IS A MERE CHANGE OF OPINION. AS REGARDS MERITS OF THE ISSUE, THE CIT(A ) HELD THAT THE A.O. HAS ADOPTED MUNICIPAL VALUE FIXED IN THE YEAR 1975 FOR ARRIVING FAIR ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 6 MARKET VALUE OF THE PROPERTY AS ON 1.4.1981. IT IS CERTAINLY INCORRECT BECAUSE VALUE AS ON 1.4.1981 WOULD BE DEFINITELY HI GHER THAN THE VALUE AS ON 1.4.1975. ON THE OTHER HAND, THE ASSESSEE FUR NISHED SUB-REGISTRAR CERTIFICATE WHEREIN THE FAIR MARKET VALUE OF THE PR OPERTY IN THE YEAR 1982 IS AT ` 600/- P.SQ.YD. THE ASSESSEE HAS DISCOUNTED FAIR M ARKET VALUE FIXED IN THE YEAR 1982 TO ARRIVE AT A FAIR MARKET V ALUE OF ` 450/- P.SQ.YD. AS ON 1.4.1981. THE CIT(A) FURTHER HELD THAT POORNA MARKET AREA AND ALLIPURAM AREA WHICH ARE COMING IN THE SAME LOCALIT Y, THEREFORE, THE A.O. WAS NOT CORRECT IN OBSERVING THAT THE PROPERTY SOLD BY THE ASSESSEE IS LOCATED IN A DIFFERENT AREA WHERE THE FAIR MARKET V ALUE OF THE PROPERTY IS ` 100/- P.SQ.YD. WITH THESE OBSERVATIONS DIRECTED T HE A.O. TO RE- COMPUTE CAPITAL GAIN BY ADOPTING FAIR MARKET VALUE OF ` 450/- P.SQ.YD. AS ON 1.4.1981. AGGRIEVED BY THE CIT(A) ORDER, THE REVENUE IS IN APPEAL BEFORE US. 6. THE LD. D.R. SUBMITTED THAT THE CIT(A) WAS ERRED IN ADOPTING MARKET VALUE AT ` 450/- P.SQ.YD. AS ON 1.4.1981 BASED ON THE MARKET VALUE OF THE BUILDING LOCATED IN SOME OTHER LOCALIT Y AND ALLOWING 25% DISCOUNT TO MARKET RATE AS ON 1.8.1982 IS TOTALLY A RBITRARY AND CONTRARY TO THE ACCEPTABLE METHOD. THE D.R. FURTHER SUBMITT ED THAT THE CIT(A) OUGHT TO HAVE APPRECIATED THE FACT THAT THE A.O. HA S OBTAINED MARKET ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 7 VALUE FROM SUB-REGISTRAR AS ON 1.4.1981 AND CORRECT LY APPLIED THE SAME AS PER LAW FOR ARRIVING AT FAIR MARKET VALUE, EVEN THOUGH THE PROPERTY WAS ACQUIRED DURING THE YEAR 1971-72. THE D.R. FURT HER SUBMITTED THAT THE PROPERTY SOLD BY THE ASSESSEE IS LOCATED IN ALL IPURAM AREA, WHEREAS CERTIFICATE ISSUED BY THE SUB-REGISTRAR IS FOR POOR NA MARKET AREA AND BOTH AREAS ARE DIFFERENT, THEREFORE, THE CIT(A) WAS ERRE D IN STATING THAT POORNA MARKET AREA AND ALLIPURAM AREA ARE COMING IN SAME LOCALITY. 7. THE LD. A.R. FOR THE ASSESSEE, ON THE OTHER HAND STRONGLY SUPPORTED ORDER OF THE CIT(A). THE A.R. FURTHER SU BMITTED THAT THE ASSESSEE HAS ADOPTED MARKET VALUE OF THE PROPERTY B ASED ON THE REVISED GUIDELINES VALUE FIXED BY THE STATE GOVERNMENT FOR THE PURPOSE OF DETERMINATION OF STAMP DUTY IN THE YEAR 1982. SINCE , EXACT FAIR MARKET VALUE OF THE PROPERTY AS ON 1.4.1981 IS NOT AVAILAB LE, THE ASSESSEE HAS RE-WORKED FAIR MARKET VALUE BY DISCOUNTING 25% ON T HE VALUE FIXED BY THE STATE GOVERNMENT IN THE YEAR 1982 TO ARRIVE AT A FAIR MARKET VALUE OF ` 450/- P.SQ.YD. THE A.R. FURTHER SUBMITTED THAT TH E ASSESSEE HAS OBTAINED CERTIFICATE FROM THE SUB-REGISTRAR, WHEREI N THE SUB-REGISTRAR HAS CERTIFIED FAIR MARKET VALUE OF THE PROPERTY AS ON 1 .8.1982 IS AT ` 600/- P.SQ.YD. IN ALLIPURAM AREA WITH SPECIFIC DOOR NUMBE R OF THE PROPERTY. ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 8 THEREFORE, THE A.O. WAS NOT CORRECT IN ADOPTING ` 100/- P.SQ.YD., IGNORING EVIDENCE FILED BY THE ASSESSEE. 8. WE HAVE HEARD BOTH THE PARTIES, PERUSED THE MATER IALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHOR ITIES BELOW. THE A.O. ADOPTED FAIR MARKET VALUE OF ` 100/- P.SQ.YD. AS ON 1.4.1981. ACCORDING TO THE A.O., THE PROPERTY SOLD BY THE ASS ESSEE IS LOCATED IN A DIFFERENT PLACE AND THE CERTIFICATE ISSUED BY THE S UB-REGISTRAR OFFICE IS FOR THE PROPERTIES LOCATED IN POORNA MARKET AREA. THE A .O. WAS OF THE OPINION THAT THE MARKET VALUE ADOPTED BY THE ASSESS EE AT ` 450/- P.SQ.YD IS WITHOUT ANY BASIS. THE A.O. HAS OBTAINE D A CERTIFICATE FROM THE SUB-REGISTRAR OFFICE, WHEREIN IT WAS STATED THA T THE FAIR MARKET VALUE OF THE PROPERTY AS ON 1.4.1981 IS AT ` 100/- P.SQ.YD. IT IS THE CONTENTION OF THE ASSESSEE THAT FAIR MARKET VALUE OF THE PROPE RTY AS ON 1.4.1981 IS NOT AVAILABLE. THE STATE GOVERNMENT HAS NOT REVISED FAIR MARKET VALUE OF THE PROPERTY AFTER 1975 AND ONLY IN THE YEAR 1982 F AIR MARKET VALUES OF THE PROPERTIES HAVE BEEN REVISED. AS PER THE REVIS ED FAIR MARKET VALUE, THE STATE GOVERNMENT HAS FIXED ` 600/- P.SQ.YD. IN ALLIPURAM AREA. SINCE, EXACT FAIR MARKET VALUE AS ON 1.4.1981 IS NO T AVAILABLE, THE ASSESSEE HAS DISCOUNTED VALUE FIXED IN THE YEAR 198 2 AT 25% TO ARRIVE AT A FAIR MARKET VALUE OF ` 450/- P.SQ.YD. ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 9 9. WE FIND FORCE IN THE ARGUMENTS OF THE ASSESSEE FO R THE REASON THAT THE A.O. HAS ADOPTED FAIR MARKET VALUE OF THE PROPE RTY AT ` 100/- P.SQ.YD. BASED ON VALUE FIXED BY THE STATE GOVERNME NT IN THE YEAR 1975. THE VALUE ADOPTED BY THE A.O. BASED ON THE RATE FIX ED IN THE YEAR 1975 IS INCORRECT, BECAUSE THE VALUE AS ON 1.4.1981 WOUL D BE DEFINITELY HIGHER THAN THE VALUE AS ON 1.4.1975. IT IS UNDISPUTED FAC T THAT THE STATE GOVERNMENT HAS NOT REVISED MARKET VALUE OF THE PROP ERTY FROM 1975 ONWARDS AND ONLY IN THE YEAR 1982, THE STATE GOVERN MENT HAS REVISED VALUES OF THE PROPERTIES, ACCORDING TO WHICH, THE V ALUES OF THE PROPERTIES IN THE POORNA MARKET AREA AND ALLIPURAM AREA HAS BE EN FIXED AT ` 600/- P.SQ.YD. SINCE, EXACT MARKET VALUE OF THE PROPERTY AS ON 1.4.1981 IS NOT AVAILABLE, THE ASSESSEE HAS CHOSEN TO RE-WORK THE F AIR MARKET VALUE BY DISCOUNTING 25% ON THE VALUE FIXED IN THE YEAR 1982 TO ARRIVE AT A FAIR MARKET VALUE OF ` 450/- P.SQ.YD. TO SUPPORT HIS ARGUMENTS, THE ASSES SEE HAS RELIED UPON THE DECISION OF COORDINATE BENCH OF VISAKHAPATNAM ITAT, IN THE CASE OF V.V. HARI PRASAD (SUPRA), WHER EIN THE COORDINATE BENCH OF THIS TRIBUNAL HAS UPHELD THE FAIR MARKET V ALUE ARRIVED BY DISCOUNTING 25% ON THE FAIR MARKET VALUE FIXED IN T HE YEAR 1982. THE ASSESSEE, BASED ON THE DECISION OF THE COORDINATE B ENCH, HAS RE-WORKED FAIR MARKET VALUE BY TAKING INTO ACCOUNT VALUE FIXE D IN THE YEAR 1982 BY ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 10 DISCOUNTING 25% ON SUCH VALUES TO ARRIVE AT A FAIR MARKET VALUE OF ` 450/- P.SQ.YD. WHICH WAS FURTHER SUPPORTED BY CERTI FICATE ISSUED BY THE SUB-REGISTRAR OFFICE, WHEREIN THE SUB REGISTRAR HAS CERTIFIED THE VALUE OF THE PROPERTY IN ALLIPURAM AREA IS AT ` 600/- P.SQ.YD. AS ON 1.8.1982. THEREFORE, WE ARE OF THE VIEW THAT THE A.O. WAS NOT CORRECT IN ADOPTING FAIR MARKET VALUE OF ` 100/- P.SQ.YD., BASED ON THE RATE FIXED BY THE STATE GOVERNMENT IN THE YEAR 1975, WHEN THE ASSESSE E HAS WORKED OUT THE PROPERTY AT ` 450/- P.SQ.YD., BASED ON THE REVISED MARKET VALUE OF THE PROPERTY FIXED BY THE STATE GOVERNMENT IN THE Y EAR 1982. THE CIT(A) AFTER CONSIDERING THE RELEVANT FACTS HAS RIG HTLY DIRECTED THE A.O. TO RE-COMPUTE CAPITAL GAINS BY ADOPTING FAIR MARKET VALUE OF ` 450/- P.SQ.YD. WE DO NOT SEE ANY REASONS TO INTERFERE WIT H THE ORDER PASSED BY THE CIT(A). HENCE, WE INCLINED TO UPHELD THE CI T(A) ORDER AND REJECT GROUND RAISED BY THE REVENUE. 10. THE ASSESSEE HAS FILED CROSS OBJECTION IN SUPPO RT OF ORDER PASSED BY THE LD. CIT(A). IN THE SAID CROSS OBJECTION, TH E ASSESSEE HAS RAISED A GROUND CHALLENGING THE VALIDITY OF RE-OPENING OF AS SESSMENT. DURING THE COURSE OF HEARING, THE LD. A.R. FOR THE ASSESSEE SU BMITTED THAT THE GROUND RELATING TO RE-OPENING OF THE ASSESSMENT IS NOT PRESSED. ITA NO.59/VIZAG/2013 & CO 35/VIZAG/2015 M/S. PARVATHI COMBINES, VISAKHAPATNAM 11 THEREFORE, WE DISMISS THE GROUND RELATING TO RE-OPE NING OF ASSESSMENT AS NOT PRESSED. 11. IN THE RESULT, THE APPEAL FILED BY THE REVENUE AND THE CROSS OBJECTION FILED BY THE ASSESSEE ARE DISMISSED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT ON 16 TH SEPT16. SD/- SD/- ( . ) ( . ) (V. DURGA RAO) (G. MANJUNATHA) /JUDICIAL MEMBER /ACCOUNTANT MEMBER # /VISAKHAPATNAM: ' /DATED : 16.09.2016 VG/SPS )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT THE ACIT, CIRCLE-1(1), VISAKHAPA TNAM 2. / THE RESPONDENT M/S. PARVATHI COMBINES, D.NO.32 -36-11, GEET & SANGEET THEATRES, VISAKHAPATNAM 3. + / THE CIT-1, VISAKHAPATNAM 4. + ( ) / THE CIT (A), VISAKHAPATNAM 5. # . , . , # / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // 12 . (SR.PRIVATE SECRETARY) . , # / ITAT, VISAKHAPATNAM