DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI V. ASHOK LEYLAND LIMITED, CHENNAI

ITA 2905/CHNY/2024

AI Insights

The case involves an appeal by the Revenue against the order of the CIT(A) which had reduced the adjustments made by the Transfer Pricing Officer (TPO) concerning corporate guarantees issued by M/s. Ashok Leyland Ltd. to its Associated Enterprises (AEs). The TPO had initially valued these guarantees at 1% of the guarantee amount, considering them as international transactions under Section 92B of the Income Tax Act. The CIT(A) reduced this rate to 0.2%, referencing previous cases and external benchmarks. The Tribunal, however, modified the CIT(A)'s order, directing the AO to apply a 0.5% rate based on judicial precedents. Additionally, the Tribunal upheld the CIT(A)'s decision on the aircraft-related expenses, agreeing that the aircraft was used for business purposes and the expenses claimed were justifiable.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 717273 (ITAT-CHENNAI)
• Duration Of Justice: 9 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-08-2025
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: D
• Assessment Year: 2012-2013
• Appeal Filed On: 14-11-2024
• Other Referred Cases: PCIT Vs Redington (India) Ltd., CIT v. Everest Kanto Cylinders Ltd, Prolifics Corporation Limited
• Laws Referred To: Income Tax Act
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: REVENUE; DOES; ANN MARRY BABY
• Assessee Lawyers: R. VIJAYARAGHAVAN
• Keywords: Business income; Transfer pricing; International transaction; Retrospective amendment; Business expenditure; Depreciation
• Section: 92B

Judgement Text

"आयकर अपीलीय अिधकरण, ’डी’ \u0001यायपीठ, चे ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH: CHENNAI \u0001ी एबी टी. वक , ाियक सद\u0011 एवं एवं एवं एवं \u0001ी अिमताभ शु\u0018ा, लेखा सद क े सम\u001b BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.2905/Chny/2024 िनधा\u000eरण वष\u000e/Assessment Year: 2012-13 The DCIT, NCC-8(1), Chennai. v. M/s. Ashok Leyland Ltd., No.1, Sardar Patel Road, Guindy, Chennai-600 032. [PAN: AAACA 4651 L] (अपीलाथ\u0016/Appellant) (\u0017\u0018यथ\u0016/Respondent) Department by : Ms.Ann Marry Baby, CIT Assessee by : Mr.R. Vijayaraghavan, Advocate सुनवाईक तारीख/Date of Hearing : 04.06.2025 घोषणाक तारीख /Date of Pronouncement : 14.08.2025 आदेश / O R D E R PER ABY T. VARKEY, JM: This is an appeal preferred by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals)-/NFAC, (hereinafter referred to as ‘Ld.CIT(A)‘), Delhi, dated 19.07.2024 for the Assessment Year (hereinafter referred to as ‘AY‘) 2012-13. 2. At the outset, the Revenue’s appeal is delayed by ‘45’ days, for which, the Ld.DR explained the reason for delay, to which; the Ld.Counsel of the assessee has not raised any serious objection. Consequently, the Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 2 :: delay of ‘45’ days in filing of the appeal stands condoned and the appeal filed by the Revenue is taken up for hearing on merits. 3. Grounds of appeal raised by the Revenue are as under: 1. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is correct in holding that the adjustment made by the TPO was not sustainable without examining the facts of the case and the evidences examined by the TPO and only relying on the judgment of the Ld. CIT(A) in the previous years? 2. Whether on the facts and circumstances of the case and in law, the Ld.CIT(A) is correct in reducing the adjustment made by the TPO relying on the judgment of the Ld.CITA) for the previous years, ignoring the basic tenet that the transfer pricing audit is highly facts-intensive and facts-driven and the contemporaneous facts have to considered and evaluated for every AY independently as dictated by Rule 10B(4) and by taking into account the comparability rains enshrined in Rule 10B(2)? 3. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is correct in reducing the adjustment when the comparable data itself is not charging the same commission for domestic bank guarantees and foreign bank guarantees? 4. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is correct in granting relief on the disallowance of depreciation and maintenance cost aggregating Rs.9,99,16,686/- in respect of aircraft without appreciating that the assessee had only submitted the log without demonstrating that the said depreciation and expenditure was solely for its business and did not have any element of personal or non-business nature and therefore the AO should have been given an opportunity which was not accorded which is in contravention to Rule 46 of Income tax Rules? 5. The appellant craves leave to add or amend any ground of appeal before it is finally disposed off. 4. Ground Nos.1 to 3 are against the action of the Ld.CIT(A) reducing the additions made by the TPO/AO while making adjustment in respect of ‘Corporate Guarantee’ (CG) issued by the assessee to its Associated Enterprises (AEs). 4.1 Brief facts are that the assessee company filed its Return of Income (RoI) for the A.Y. 2012-13 on 28.11.2012 and subsequently filed revised Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 3 :: return declaring total income of Rs.72,57,46,778/-. Subsequently, the RoI was selected for scrutiny under CASS and notice u/s.143(2) of the Act dated 13.08.2013 was duly served on the assessee. The AO noted from the perusal of Form 3CEB submitted by the assessee that the assessee company had International Transaction with AEs to the tune of Rs.744,24,38,759/-. Therefore, the case was referred to the TPO. Pursuant thereto, the TPO noted that the assessee has provided Corporate Guarantee (CG) to its Associated Enterprises to the tune of Rs.356,17,22,311/-. So, the TPO show caused the assessee as to why adjustment towards Arms Length Price (ALP) of this International Transaction shall not be made. Pursuant to which, the assessee company submitted that it has not charged any service fees from the Associated Enterprises for the risk taken by standing guarantee to the loans and was part of its stewardship activity for strategic purpose, which enabled the AE’s to avail loan locally at cheaper rates and thus, indirectly protect the assessee’s investment and therefore, objected to any adjustment made on this account. The TPO noted that assessee has not disclosed the corporate guarantee issued to its AE in Form 3CEB. According to him, issuing Corporate Guarantee is an International Transaction squarely covered under the provisions of Section 92B of the Act. And further observed that the assessee has directly issued corporate guarantees to foreign branches of the Indian Banks towards International Transactions Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 4 :: (being loans) taken by its AEs. The TPO further observed that the corporate guarantee is a weaker substitute to a Bank Guarantee, therefore, the additional risk assumed by the assessee is to be charged. Thus, the TPO valued the service charges receivable by the assessee for the corporate guarantee issued to its AE at 1% amounting to Rs.2,66,71,257/- as adjustment towards the Arm's length Price of International Transaction. Thereafter, the AO based on TPO order made addition of Rs.2,66,71,257/-. 4.2 Aggrieved the assessee preferred an appeal before the Ld.CIT(A) and the Ld.CIT(A) directed the AO to adopt rate of 0.2% by taking note that corporate guarantee fees offered by SBI to assessee was at the rate of 0.2% and followed his own predecessors order on this issue by observing as under: 8. The second ground relates to adjustment to Arms-Length price adopted by the appellant for Corporate Guarantee (CG) issued by the appellant to Financial Institutions on behalf of AEs on which appellant has not charged any fee since it is not an International Transaction u/s 92B of the act. The TPO rejected the appellant's argument and proposed notional fees of 1% for CGs issued to both Indian and Foreign Bank branches which resulted in a total addition of Rs. 2,66,71,257/-. 8.1 The appellant submitted that: 1. It has extended CGs to AEs purely as a stewardship activity for strategic purposes which enables the AEs to borrow locally at cheaper rates and indirectly safeguarded the appellant's investments. 2. Extending CGs do not involve any costs and does not have any bearing on the profits, income, loses or assets of the appellant and hence it is not an international transaction u/s 92B of the IT Act. Reliance is placed on the decision of Hon'ble ITAT in its own case for AY 2008-09 (IT No. 2839/Mds/2014). Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 5 :: 3. Without prejudice, the Appellant submitted that, any adjustment to Arms- Length price cannot exceed the charges for CGs of 0.2% as offered by State Bank of India to the appellant. 8.2 After considering facts involved and submissions made by the Appellant, the principle of whether CG is an international transaction u/s 92B is now settled by jurisdictional High Court in PCIT Vs Redington (India) Ltd. (2021) 430 ITR 298 (Madras), in which the court has upheld that guarantees are covered in the definition of International Transactions u/s 92B, since there may not be immediate charge of profit and loss account of issue of a guarantee, but an inherent risk cannot be ruled out. Hence, the appellant's argument on this principle is rejected. 8.3 On the appropriate fees for CGs, the appellant submitted the details of CG fees offered by SBI to the appellant (0.2% p.a.) which can be taken as an external benchmark as held by Hon'ble CIT (Appeal), Chennai-16 in Appellant's own case for AYs 2010-11 and 2011-12 vide orders number 17/10740/2014- 15 and 17/10834/2015-16 respectively. Therefore, I direct the AO to adopt the rate of 0.2% per annum to all CGs issued by SBI to the appellant and re- compute the amount of disallowance. This ground is partly allowed. 4.3 Aggrieved by the aforesaid action of the Ld.CIT(A), the Revenue is before us. We note that the assessee company had issued CG to Financial Institution abroad on behalf of its AE, on which assessee didn’t charge any fees. The TPO proposed fees of 1% for CG’s issued to Indian & Foreign branches and the AO made addition of ₹2,66,71,257/-. On appeal, the Ld.CIT(A) has directed adoption @ 0.2% in respect of ‘corporate guarantee’ given to its AEs to the tune of Rs.356,17,22,311/- by noticing that the ‘corporate guarantee’ fees offered by the SBI to the assessee was @ 0.2% per annum which was taken as external bench- mark, while computing the ALP for providing ‘corporate guarantee’ to its AEs and is noted to have followed his predecessors action in the assessee’s own case for AY 2011-12 wherein also similar action was taken. Before us, the Ld.AR supporting the impugned action of the Ld.CIT(A) drew our attention to the SBI letter which shows the details of Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 6 :: CG fees offered by SBI to the assessee company @ 0.2% Per Annum which fact is discernable from Page No.36 of the Paper Book. According to the Ld.AR, similar action taken by the Ld.CIT(A) for AY 2010-11 & 2011-12 based on guarantee fees charged by SBI, has not been challenged by the Revenue. Therefore, according to him, the impugned action of the Ld.CIT(A) shouldn’t be disturbed. Per contra, the Ld.DR couldn’t rebut the contention of the Ld.AR that similar action of the Ld.CIT(A) has been accepted by Revenue in assessee’s own case for AYs 2010-11 & 2011-12, however he vehemently supported the action of AO. 4.4 Having heard both parties, we find that the issue agitated by the Revenue is no longer res integra. The Ld.CIT(A) is noted to have followed his predecessor’s view taken in AY 2010-11 & 2011-12, which action has not been contested by the department before this Tribunal and so, should be assumed to have reached finality. Be that as it may, on this issue, in assessee’s own case, the Tribunal for AY 2019-20 had an occasion to adjudicate this issue wherein Tribunal vide order dated 07.07.2025 [in ITA Nos.1402/Chny/2024 for AY 2019-20], held as under: 5. Ground No.2 relates to the transfer pricing adjustment made in respect of corporate guarantee(s) issued by the assessee to its foreign AE(s). The facts as noted are that, the assessee is engaged in the business manufacture & sale of commercial vehicles. It had given corporate guarantee in relation to the loans obtained by its foreign subsidiaries, M/s. Optare Plc and M/s Albonair GmBH. The assessee didn't charge any fee towards such corporate guarantees issued in favour of the AEs. The TPO is noted to have made transfer pricing adjustment in relation thereto, by adopting the ALP value at 1% of the value of corporate guarantee. Aggrieved, the assessee preferred Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 7 :: appeal before the Ld. CIT(A) which confirmed the action of the TPO. Now, the assessee is in appeal before us. 5.1 Heard both the parties. The Ld. AR for the assessee has contended that since the corporate guarantee was provided without any cost to the AE, it didn't have any bearing of profits, income, losses of the assessee and therefore could not be regarded as an international transaction and be benchmarked under the transfer pricing provisions. We however note that the provisions of Section 92B has been amended by the Finance Act 2012, whereby, in terms of the Explanation to Section 92B, the guarantees issued by an assessee has been clarified to be in the nature of international transaction. We note that the Hon'ble Bombay High Court in the case of CIT v. Everest Kanto Cylinders Ltd [2015] 58 taxmann.com 254/232 Taxman 307/378 ITR 57 (Bombay) has considered identical issue in light of the provisions of Section 92B and the Explanation, came to a conclusion that the corporate guarantee issued by an entity on behalf of its AE is an international transaction. We further note that, this identical issue came up before the Hon'ble jurisdictional Madras High Court in the case of Pr. CIT v. Redington (India) Ltd. [2020] 122 taxmann.com 136/[2021] 430 ITR 298 (Madras), wherein, the Hon'ble Madras High Court held that, inherent risk cannot be ruled out in providing guarantees and hence the transaction involving issuance of corporate guarantee is covered by the definition of international transaction consequent to retrospective amendment made by the Finance Act, 2012 and, accordingly adjustments are required to be made for guarantee commission. The relevant findings taken note of by us is as follows: - “75. The concept of Bank Guarantees and Corporate Guarantees war explained in the decision of the Hyderabad Tribunal in the case of Prolifics Corporation Limited. In the said case, the Revenue contended that the transaction of providing Corporate Guarantee is covered by the definition of international transaction after retrospective amendment made by Finance Act, 2012. The assessee argued that the Corporate Guarantee is an additional guarantee, provided by the Parent company. It does not involve any cost of risk to the shareholders. Further, the retrospective amendment of Section 92B does not enlarge the scope of the term international transaction to include the Corporate Guarantee in the nature provided by the assessee therein. The Tribunal held that in case of default, Guarantor has to fulfill the liability and therefore, there is always an inherent risk in providing guarantees and that may be a reason that Finance provider insist on non-charging any commission from Associated Enterprise as a commercial principle. Further, it has been observed that this position indicates that provision of guarantee always involves risk and there is a service provided to the Associate Enterprise in increasing its creditworthiness in obtaining loans in the market, be from Financial institutions or from others. There may not be immediate charge on P & L account, but inherent risk cannot be ruled out in providing guarantees. Ultimately, the Tribunal upheld the adjustments made on guarantee commissions both on the guarantees provided by the Bank directly and also on the guarantee provided to the erstwhile shareholders for assuring the payment of Associate Enterprise. 76. In the light of the above decisions, we hold that the Tribunal committed an error in deleting the additions made against Corporate and Bank Guarantee and restore the order passed by the DRP.” Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 8 :: 5.2 In view of the above decisions (supra), we therefore hold that the transaction of corporate guarantee is an international transaction subject to transfer pricing provisions. Accordingly, the first plea of the assessee is hereby rejected. 5.3 The next issue now to be adjudicated is the ALP value of the guarantee commission. In this regard, the Ld. AR has relied on the quote provided by Bank(s) in which they have proposed to extend bank guarantee at 0.325% and has urged that the ALP adjustment be restricted to 0.325%. We find that the Hon’ble Bombay High Court in the case of Everest Kanto Cylinders Ltd (supra) has observed that bank guarantees cannot be equated with corporate guarantees and accordingly discarded the rates provided by Banks. Following the same, the assessee’s reliance on bank quote of 0.325% is rejected. In the same decision (supra), the Hon'ble Bombay High Court had ascertained the ALP guarantee commission at 0.5%, which was followed by the Hon'ble jurisdictional High Court in the case of Redington (India) Ltd. (supra) wherein also the ALP corporate guarantee commission was fixed at 0.5%. Following the same, we direct the AO to restrict adjustment to 0.5% of the guarantee value. This ground is therefore partly allowed. 4.5 Respectfully following the Tribunal order in the assessee’s own case for AY 2019-20 on the issue, and relying on the decision of Hon'ble jurisdictional Madras High Court in the case of Pr. CIT v. Redington (India) Ltd. 430 ITR 298 (Madras), we modify the order of the Ld.CIT(A) and direct the AO to sustain the addition @ 0.5% of the guarantee value. Thus, this ground of Revenue is partly allowed. 5. Ground No.4 of Revenue is against the action of the Ld.CIT(A) granting relief on the disallowance of depreciation and maintenance cost aggregating Rs.9,99,16,686/- in respect of aircraft. 5.1 Brief facts are that the assessee company claims to own an aircraft and has claimed depreciation @40% on the same. During this year, depreciation was claimed at Rs.4,73,63,414/-, l.e., 40% of opening WDV. Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 9 :: Further, the assessee has claimed to have incurred operating expenditure on this aircraft to the tune of Rs.5,25,53,272/-, which consists of crew salary, fuel, routine maintenance & spares etc. The AO asked the assessee to provide the details of depreciation claimed on the 'aircraft' and its claim of operating expenditure and also directed to produce the log books required to be maintained as per the Aircraft Rule 1937 - Part IX - Rule 67 which was in order to prove that the said aircraft has been used wholly and exclusively for the purpose of business. According to the AO, the assessee had to establish the usage of aircraft with the relevant Log Book Entries vis-a-vis the specific business activities carried out based on the above journey. Pursuant to the notice of the AO, the assessee submitted the reply along with certain documents to support the claim. However, the AO was of the view that the details submitted by the assessee along with letter dated 26.02.2015 only indicates the company had debited expenses in respect of to & fro of the destination with date. According to the AO, in the absence of details regarding specific business activities carried out based on the journey(s), the business exigency for owning and maintaining an aircraft was not convincing and can’t be said to be proved. Also, according to the AO, the assessee has not furnished the requisite Log Books that are required to be maintained as per Rule 67 of the Aircraft Rule 1937. The AO observed that merely owning an aircraft and operating the aircraft does not Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 10 :: automatically qualify it to be eligible for depreciation unless it is put to use in business. Accordingly, the depreciation claimed on the above said aircraft, which according to the AO has been purchased for the personal usage instead of the business activity of the assessee cannot be allowed as deduction. Hence, the depreciation claimed of Rs.4,73,63,414/- and the expenses claimed of Rs.5,25,53,272/- were disallowed being non- business expenditure. [Total amount thus disallowed Rs.9,99,16,686/-]. 5.2 Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who was pleased to allow the same by finding that the assessee had purchased Aircraft in question in the year 2007 for its business use due to increasing international business and connectivity to small town which are not regularly connected by the scheduled operators. The Ld.CIT(A) noted that assessee also leased the aircraft to third party for use on which fees earned was offered to tax as business income. The Ld.CIT(A) also noted from the perusal of the log books and aircraft movement sheet that the Aircraft was used for the purpose of business. According to the Ld.CIT(A), log books and aircraft movement sheet were produced before the AO as well as before him during the appellate proceedings and thereafter, the Ld.CIT(A) having been convinced that the Aircrafts was used for its business use has followed the decision of this Tribunal in assessee’s own case for earlier years and directed the AO to allow the depreciation and other expenditure necessary to operate Aircraft by observing as under: Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 11 :: 11. Ground no. five relates to disallowance of depreciation and maintenance cost totaling to Rs. 9,99,16,686/- claimed on Aircrafts. The AO disallowed these expenses on the ground that the aircrafts have not been put to used for the business of the Appellant. 11.1 The Appellant has submitted that it had purchased aircraft in 2007 for its business use due to increasing international business and connectivity to small town which are not regularly connected by scheduled operators. The Appellant also leased the aircraft to third party for used on which fees earned was offered to tax as business income. The Appellant submitted log books and Aircraft movement sheet which substantiated the uses of aircraft for the purposes of business before the AO as well as during appellate proceedings. The Appellant placed reliance on the decision of Hon'ble ITAT in Appellant's own case in 2007-08 and 2008-09 in ITA nos. 2838,2839/Mds/2014, in which the ITAT directed the AO to allow the depreciation and other expenditure necessary to operate aircraft after examining the relevant licensing requirement. 11.2 I have perused the order of Hon'ble ITAT in its own case for AYs 2007-08 and 2008-09 (Supra), in which the ITAT has directed to AO to verify the licensing requirements and accordingly allow the depreciation and maintenance cost incurred for aircrafts. The decisions of Hon'ble ITAT for AY 2007-08 and 2008-09 (Supra) have been relied upon my predecessor in the orders for AY 2009-10 (ITA No. 21/CIT(A)- 5/13-14) and for AY 2010-11 and 2011-12 in CIT(A), Chennai's orders no. 17/10740/2014-15 and 17/10834/2015-16 respectively. Following decisions of ITAT as well as CIT(A) in Appellant's own case, this ground of appeal is decided in favour of Appellant. 5.3 Before us, it has been brought to our notice by the Ld.AR that on this issue, in the assessee’s own case for earlier years especially that for AY 2007-08 & 2008-09, the Tribunal had directed the AO to verify the log book and aircraft movement sheet and pass order in accordance to law and that the AO gave effect to the order of the Tribunal and after verification of relevant details had allowed the assessee’s claim on both depreciation & operational expenditure. In this regard, we find that the Ld.CIT(A) has allowed the claim of the assessee after making finding of fact that the assessee had produced log books and aircraft movement- sheet and other relevant documents before the AO as well as before him, Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 12 :: and thereafter being convinced that the Aircraft was being used for business purpose, he has allowed the claim. In the aforesaid back ground, we are of the view that the question of violation of Rule 46A of the Income Tax Rules, 1962 as alleged by the Ld.DR for Revenue, does not arise since the grounds of appeal nowhere has challenged the finding of the Ld.CIT(A) that relevant documents were produced before the AO. If the Revenue was of the view that the Ld.CIT(A) finding of fact (supra) is erroneous being perverse, then they ought to have challenged the said finding by asserting that assessee didn’t produce the relevant log- books/aircraft movement sheet and after relevant documents before the AO, which is not the case before us. Therefore, the Ld.CIT(A) finding that the relevant documents [log books and aircraft movement sheet] has been produced before him as well as before the AO stands crystallized. And therefore, we don’t find any infirmity in the action of the Ld.CIT(A) to allow this claim. Hence, fourth ground of appeal raised by the Revenue stands dismissed. 6. In the result, appeal filed by the Revenue is partly allowed. Order pronounced on the 14th day of August, 2025, in Chennai. Sd/- (अिमताभ शु\u0018ा) (AMITABH SHUKLA) लेखा सद\u0003य/ACCOUNTANT MEMBER Sd/- (एबी टी. वक ) (ABY T. VARKEY) \u0005याियक सद\u0003य/JUDICIAL MEMBER Printed from counselvise.com ITA No.2905/Chny/2024 (AY 2012-13) M/s. Ashok Leyland Ltd. :: 13 :: चे ई/Chennai, !दनांक/Dated: 14th August, 2025. TLN आदेश क \u0017ितिलिप अ$ेिषत/Copy to: 1. अपीलाथ /Appellant 2. \u000e\u000fथ /Respondent 3. आयकरआयु\u0015/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय\u000eितिनिध/DR 5. गाड फाईल/GF Printed from counselvise.com "