GENESYS TELECOM LABS INDIA PRIVATE LIMITED,CHENNAI V. DCIT, CIRCLE -1(1), GURGAON, GURGAON

ITTPA 38/CHNY/2024

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The case involves Genesys Telecom Labs India Pvt. Ltd., which appealed against the final assessment order passed under sections 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 for the assessment year 2020-21. The primary contention revolved around the Transfer Pricing Officer's (TPO) adjustments to the assessee's income, which were based on the arms length price of international transactions with associated enterprises. The Tribunal examined the application of turnover filters in selecting comparable companies for transfer pricing analysis and the functional comparability of certain companies.

• Counselvise Citation: [2024] 140 COUNSELVISE.COM (IT) 469866 (ITAT-CHENNAI)
• Duration Of Justice: 3 month(s) 6 day(s)
• Appeal Type: Income Tax (Transfer Pricing) Appeal
• Pronouncement Date: 28-11-2024
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: D
• Next Hearing Date: 26-11-2024
• Assessment Year: 2020-2021
• Appeal Filed On: 21-08-2024
• Other Referred Cases: Kumaran Systems Pvt. Ltd. vs. DCIT, Sprinklr India Pvt. Ltd. vs. DCIT, Nokia Solutions and Networks India Pvt. Ltd. vs. ACIT, Etisalat Software Solutions Pvt. Ltd. vs. DCIT, M/s. Visual Graphics India Computing Services India Pvt. Ltd. vs. CIT, M/s. Pentair Water India Pvt. Ltd. vs. CIT, M/s. Autodesk (I) P. Ltd. vs. DCIT, Inteva Products India Automotive Pvt. Ltd. vs. DCIT, KBACE Technologies Pvt. Ltd. vs. DCIT, Ahlers India Pvt. Ltd. vs. DCIT
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: A. SASIKUMAR
• Assessee Lawyers: DARPAN KIRPALANI; PRATIK LAWANKAR; ADVOCATES
• Keywords: Opportunity of being heard; Transfer pricing; International transaction
• Section: 143(3); 13

Judgement Text

"अपीलȣय अͬधकरण, ‘डी’ Ûयायपीठ, चेÛनई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI Įी जॉज[ जॉज[ क े, उपाÚय¢ एवं Įी एस.आर.रघुनाथा, लेखा सदèय क े सम¢ BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENTAND SHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./IT(TP)A No.: 38/CHNY/2024 िनधाᭅरण वषᭅ/Assessment Year: 2020-21 Genesys Telecom Labs India Pvt. Ltd., Global Infocity, 7th Floor, Block C, Plot No.40, MGR Salai, Kandanchavadi, Perungudi, Chennai – 600 096. PAN: AAECG 4843Q Vs. The Deputy Commissioner of Income Tax, Circle 1(1), Gurgaon. (अपीलाथᱮ/Appellant) (ᮧ᭜यथᱮ/Respondent) अपीलाथᱮ कᳱ ओर से/Appellant by : Shri Darpan Kirpalani & Shri Pratik Lawankar, Advocates ᮧ᭜यथᱮ कᳱ ओर से/Respondent by : Shri A. Sasikumar, CIT सुनवाई कᳱ तारीख/Date of Hearing : 26.11.2024 घोषणा कᳱ तारीख/Date of Pronouncement : 28.11.2024 आदेश /O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: This appeal at the instance of the assessee is directed against the final assessment order dated 24.06.2024 passed under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter called ‘the Act’).The relevant Assessment Year is 2020-21. - 2 - IT(TP)A No.38/CHNY/2024 2. Brief facts of the case are as follows: The assessee is a private limited company. It provides research, development, sales, marketing, administrative support and sub- contract services relating to telecommunication business as a back office service to the Associated Enterprises (AEs) in Ireland and Netherland. For the assessment year 2020-21, the return of income was filed on 25.11.2020 declaring total income at Rs.33,70,65,800/- and book profit under MAT at Rs.23,02,39,911/-. The assessment was selected for scrutiny and notice u/s.143(2) of the Act was issued and served on the assessee on 29.06.2021. During the course of assessment proceedings, the case was referred to the Transfer Pricing Officer (TPO) to determine the Arms Length Price of the international transactions undertaken by the assessee with its AE’s. The TPO passed an order on 28.03.2023 u/s.92CA(3) of the Act and proposed upward adjustment of Rs.9,18,48,775/- on AE sales (Software development segment). Pursuant to the TPO’s order, the draft assessment order was passed u/s.144C(1) of the Act on 25.09.2023 incorporating the aforementioned TP adjustment made by the TPO. 3. Aggrieved by the draft assessment order, the assessee filed objections before the DRP on 25.10.2023. The DRP vide its - 3 - IT(TP)A No.38/CHNY/2024 directions dated 29.05.2024 disposed off the assessee’s objections by partly allowing the objections of the assessee. Pursuant to the DRP’s order disposing off the assessee’s objection, the TPO gave effect to the DRP’s directions and the TP adjustment was revised to Rs.8,52,27,336/- instead of Rs.9,18,48,575/- proposed originally by the TPO. Pursuant to the DRP’s direction and the order of TPO giving effect to the DRP’s direction, the impugned final assessment order was passed on 24.06.2024 u/s.143(3) r.w.s. 144C(13) r.w.s. 144B of the Act. 4. Aggrieved by the final assessment order, the assessee has filed the present appeal before the Tribunal. The assessee has raised several grounds and sub-grounds. The assessee in total has raised 12 grounds. However, during the course of hearing, the ld.AR had limited his submission to Ground Nos.4 & 6 and its sub-grounds. The submissions made by the ld. AR are threefold namely:- (A) In Ground No. 4 and its sub-grounds, assessee is seeking application of upper turnover filter and thereby praying for exclusion of following five companies from the list of comparables :- i) Larsen and Turbo Infotech Ltd., ii) Nihilent Ltd. iii) Mindtree Ltd. iv) Tata Elxi Ltd. v) Cybage Software Pvt. Ltd. - 4 - IT(TP)A No.38/CHNY/2024 (B) Inclusion of Rheal Software Private Limited, which according to the assessee is functionally comparable (Ground No.6 & 6.1) (C) Exclusion of Daffodil Software Pvt. Ltd., since it is not functionally comparable to the assessee company (Ground No.4 & 4.2) 5. We shall adjudicate the aforesaid issues argued by ld.AR as under:- A) Exclusion of five comparables on account of application of upward turnover filter: 6. The ld.AR submitted that the assessee’s turnover in the software development segment is Rs.106 crores. It was submitted by the ld.AR that the TPO had applied lower turnover filter, hence upper turnover filter is also to be applied, in which case, the above mentioned five companies whose turnover exceeded Rs.200 crores are to be excluded from the list of comparables. The ld.AR in support of the above contention relied on the order of the Chennai Bench of the Tribunal in the case of Kumaran Systems Pvt. Ltd., vs. DCIT in IT(TP)A No.95/CHNY/2018 (order dated 09.08.201) and the order of the Bangalore Bench of the Tribunal in Sprinklr India Pvt. Ltd., vs. DCIT in IT(TP)A No.250/Bang/2022 (order dated 15.07.2022). - 5 - IT(TP)A No.38/CHNY/2024 6.1 The ld. DR supported the order of the TPO and the DRP. He echoed TPO’s and DRP’s conclusion that turnover does not have any influence on the margins of the companies. 6.2 We have heard rival submissions and perused the material on record. It is an admitted fact that the assessee’s turnover in SWD segment is Rs.106 crores. It is also a fact that the TPO had applied lower turnover filter by excluding companies having less than one crore turnover. When the TPO has applied lower turnover filter, he ought to have applied upper turnover filter also. As per the Dun & Bradstreet classification of software industry, the companies could be classified under three major heads depending on the turnover of the company viz., a. Less than Rs.200 crores categorized as small size companies. b. Rs.200 crores to Rs.2,000 crores categorized as medium size companies. c. More than Rs.2,000 crores categorized as large size. 6.3 The turnover of the assessee for the relevant assessment year is Rs.106 crores and therefore, would fall under the category of small size company having turnover in the range of Rs.1 crore to Rs.200 crores. Therefore, the companies not falling within the range i.e., companies having turnover less than Rs.1 crore or turnover - 6 - IT(TP)A No.38/CHNY/2024 more than Rs.200 crores deserves to be excluded. The Chennai Bench of the Tribunal on identical facts in the case of Kumaran Systems Pvt. Ltd., (supra), after considering the judicial precedents on the subject had applied upper turnover filter of Rs.200 crores. The relevant submissions of the ld.AR, ld.DR and the findings of the ITAT, Chennai read as under:- 6. The first issue that came up for our consideration is TP adjustment made by the AO to international transactions of the assessee with its AEs by re-characterization of TP study and inclusion of certain new comparables. The ld.AR for the assessee at the time of hearing submitted that although the assessee has taken various grounds challenging erroneous rejection of transfer pricing study of the assessee and conducting new such process and also inclusion of new comparables, but restricted its arguments only on Ground No.3, which agitates not applying upper turnover filter for selection of comparables, on the pleading that, if assessee’s claim is accepted then grounds taken by the assessee challenging inclusion of new comparables become infructuous, because the assessee margin falls within the range and hence, additions made by the AO would become nil. He, further submitted that the issue of application of turnover filters is covered by the decision of the Hon’ble Jurisdictional Madras High court in the case of CIT vs. M/s. Visual Graphics India Computing Services India Pvt. Ltd., (2021) 318 CTR 586, where the Hon’ble High Court held that the Appellate Tribunal has rightly rejected the comparable based on turnover filter criteria. The ld.AR further submitted that Dun and Bradstreet’s analysis classified the software companies into three categories based on size, as per which, small size firms are categorized based on the turnover of Rs.2,000 minimum upto Rs.200 crore. Admittedly, turnover of the assessee for the impugned assessment year is Rs.33.24 crores, whereas the AO has included 4 new comparables whose turnover is above Rs.200 crores. Therefore, those companies will go if turnover filter is applied for selection of comparables. In this regard, he has relied upon the decision of the ITAT, Bangalore in the case of M/s.Autodesk (I) P. Ltd., vs. DCIT, [2018] 96 taxmann.com 263 and argued that there are divergent views on the issue of application of turnover filter but, the Bangalore Bench of the Tribunal in the latest judgment had considered all previous judgments and held that - 7 - IT(TP)A No.38/CHNY/2024 high turnover companies cannot be compared with low turnover companies and hence, the AO has to apply turnover filter based on Dun and Bradstreet’s analysis for selection of comparables. If turnover filter is applied, then 4 new companies selected by the AO will go out of the list of comparables and thus, the margin of the assessee is within the range of comparables selected by the AO and consequently addition made towards TP adjustment would also goes. 7. The ld.DR on the other hand strongly supporting order of the ld.DRP more particularly para 3.1 & 3.2 submitted that where the assessee has not made out a case as how the high or low turnover has influenced operating margin, then a comparable cannot be rejected solely on the basis of high turnover. Therefore, there is no merit in arguments taken by the ld.AR for the assessee for application of turnover filter to exclude new comparables selected by the TPO, when FAR analysis shows that the companies are carrying out similar functions as of the assessee. 8. We have heard both the sides, perused materials available on record and gone through orders of the authorities below. It is a well settled principle of law by various decisions of Courts and Tribunal that upper turnover filter of Rs.200 crores has to be adopted, while selecting the comparable set of companies, for the purpose of benchmarking under TNMM method. Further, Dun and Bradstreet’s analysis has classified software companies into 3 categories based on their turnover, as per which, small size firms are classified on the basis of turnover of Rs.2,000 and upto Rs.200 crores, medium size firms has been classified between Rs.200 to Rs.2000 crores and large size firms has been classified based on turnover of above Rs.2000 crores. The Hon’ble Madras High Court in the case of CIT vs. Visual Graphics Computing Services India Pvt. Ltd., supra, held that the Appellate Tribunal has rightly rejected comparables based on turnover filter criteria. The Hon’ble High Court while dealing with the issue, has considered the decision of Hon’ble Bombay High Court in the case of CIT vs. M/s.Pentair Water India Pvt. Ltd., [2016] 381 ITR 216, wherein it was stated that a giant company in the area of development of software cannot be compared with assessee, which is having a small turnover. Although, the ld.DRP has relied upon the decision of ITAT, Bangalore in the case of M/s. Genisys Integrating Systems (India) P. Ltd., vs. DCIT, [2012] 53 SOT 159, but fact remains that in the latest decision, the ITAT, Bangalore Bench in the case of M/s. Autodesk (I) P. Ltd., vs. DCIT, supra, has considered similar issue and after analyzing various - 8 - IT(TP)A No.38/CHNY/2024 judgments of different High Courts and Tribunals held that turnover filter is a good criteria to exclude comparables and hence, as per the settled principles, a high turnover company cannot be compared with a small turnover company. This being the case, the assessee which is having a small turnover and also catering to the needs of its AEs cannot be compared with giant companies like Mindtree Ltd., Persistent Systems Ltd., R S Software (India) Ltd., etc., which are having huge turnover. Further, the asset base including tangibles and intangibles, their brand value and area of operation would definitely have a bearing on the operating margin of the company because, they in general, provide services to various clients across the globe, whereas the assessee company limited its services to its AEs. In this case, admittedly, the assessee has a turnover of Rs.33.24 crores, whereas the TPO has included 4 comparables whose turnover ranges from Rs.207 crores to Rs.3,032 crores, which is almost more than 6 times to 91 times of the turnover of the assessee and hence, we are of the considered view that the TPO as well as the ld.DRP has erred in not applying turnover filter for selection of comparables and hence, we direct the TPO to apply turnover filter of 0 to 200 crores for selection of comparables and recompute margin of the assessee. In case, the TPO finds that after application of turnover filter, operating margin of the assessee is within admissible range then, we direct the TPO to delete addition made towards TP adjustment. 6.4 In light of the aforesaid reasoning and the judicial pronouncements cited supra, since the turnover of the aforesaid five companies exceeds Rs.200 crores, we direct the TPO to exclude the same from the comparable list. Therefore grounds Nos.4, 4.1, 4.4, 4.5, 4.6 & 4.7 are partly allowed. It is ordered accordingly. B. Inclusion of Rheal Software Pvt. Ltd., (Ground No.6 & 6.1) 7. The DRP in its directions (refer Page 4, Para 5.1.1) admits that company, Rheal Software Pvt. Ltd., is engaged in custom software - 9 - IT(TP)A No.38/CHNY/2024 development and maintenance, hence it is functionally comparable to the assessee. However, the DRP affirmed the TPO’s proposal to exclude Rheal Software Pvt. Ltd., from the list of comparables on the ground that said company was having losses over the years and satisfy the persistent loss filter. The ld.AR submits, admittedly the Rheal Software Pvt. Ltd., for the financial year 2018-19 was having profits and said company does not satisfy the persistent loss filter. In this context, the ld.AR relied on the order of the Delhi Bench of the Tribunal in the case of Nokia Solutions and Networks India Pvt. Ltd., vs. ACIT in ITA No.1447/Del/2022 (order dated 20.03.2024) and also the Bangalore Bench of the Tribunal in the case of Etisalat Software Solutions Pvt. Ltd., vs. DCIT in IT(TP)A No.224/Bang/2023 (order dated 18.07.2023). It was contented by the ld.AR, above judicial pronouncements have specifically dealt with Rheal Software Pvt. Ltd., whether it is a persistent loss making company or not. It has been categorically held that if in one of the financial year when the company was having profits, it cannot be said that the company can be termed as a persistent loss making company. 7.1 The ld.DR relied on the DRP’s direction and the order of the Chennai Bench of the Tribunal in the case of Ahlers India Pvt. Ltd., vs. DCIT in ITA No.1071/Mds/2016 (order dated 03.03.2017). - 10 - IT(TP)A No.38/CHNY/2024 7.2 We have heard rival submissions and perused the material on record. The DRP has admitted that Rheal Software Pvt. Ltd., is functionally comparable to the assessee. The solitary reason for excluding the same from the list of comparables was on the ground that it was showing persistent losses. However, on perusal of Annual Report for the financial year ending 31.03.2018, 31.03.2019 and 31.03.2020, we find that Rheal Software Pvt. Ltd., was having profits for the financial year ending 31.03.2019. In such a scenario, the Delhi Bench of the Tribunal in the case of Nokia Solutions and Networks India Pvt. Ltd., (supra) and the Bangalore Bench of the Tribunal in the case of Etisalat Software Solutions Pvt. Ltd., (supra) had held that, it cannot be stated to be a persistent loss making company. The Delhi Bench of the Tribunal’s findings with regard to Rheal Software Pvt. Ltd., are as under:- “24. Rheal Software Pvt. Ltd.: Seeking inclusion of this company, learned counsel for the assessee submitted, the only reason for which the TPO has excluded the company is that it is a persistent loss making company. However, he submitted, in assessment year 2015- 16, it has reported profit. Therefore, it does not satisfy the persistent loss making company filter applied by the TPO. 25. Learned Departmental Representative submitted, not only the company had made loss in financial years 2016-17 and 2017-18 but its income has progressively diminished. Thus, he submitted, the company was rightly rejected. 26. Having considered rival submissions, we find, while applying the persistent loss making company filter, the TPO has observed that company - 11 - IT(TP)A No.38/CHNY/2024 having persistent losses for the last three years up to and including financial year 2014-15 are to be excluded. In fact, the only reason for which the company was excluded by the TPO was that it is a persistent loss making company. However, learned counsel for the assessee has furnished cogent evidence before us to demonstrate that the company has made profit in financial year 2015-16. Thus, in our view, applying the filter of persistent loss making company of the TPO, the company cannot be rejected. Accordingly, we direct the Assessing Officer to include this company.” 7.3 The finding of the Bangalore Bench of the Tribunal reads as follows:- “5.1 He submitted that Rheal Software Ltd. is rejected by the Ld.TPO on the ground that it satisfies persistent loss filter. However the Ld.AR submitted that this Tribunal has held in a large number of cases that, in order for a comparable to be held to satisfy this filter, the comparable must have incurred losses consequently, for three years and that if it has incurred profit in event one of the three years, it cannot be held that this comparable has to be rejected by applying persistent loss filter. ……….. ………… ………… 5.4.2 In the event, the contentions of the assessee are found to be true, the two comparables are directed for inclusion. Assessee is directed to file all the relevant documents in support of the claim. Needless to say that proper opportunity of being heard must be granted to assessee.” 7.4 As regards the DRP’s and DR’s reliance on the order of the Chennai Bench of the Tribunal in Ahlers India Pvt. Ltd.,(supra), we are of the view that the DRP has misinterpreted the findings of the ITAT. The principle upheld by the Chennai Bench of the Tribunal states that when a comparable company incurs losses both in the relevant assessment year and the immediately preceding - 12 - IT(TP)A No.38/CHNY/2024 assessment year, the company deserves to be removed from the final set of comparables. In the facts of the instant case, Rheal Software Pvt. Ltd., has incurred loss in the relevant financial year but not in the immediately preceding financial year. Accordingly, the Rheal Software Pvt. Ltd., does not fail the persistent loss filter as proposed to be applied by the ITAT in the case of Ahlers India Pvt. Ltd., (supra). The relevant observation of the Chennai Bench of the Tribunal in the case of Ahlers India Pvt. Ltd., reads as follows:- “8.2 We have carefully gone through the above submissions of ld.A.R. As seen from the financial details submitted by ld.A.R, that assessee made loss in financial years 2009-10 & 2011-12 and there was a small profit of Rs.1/- crore in financial year 2009-10. The financial year involved herein is 2010- 11 relevant to assessment year 2011-12. Since the Gordon Woodroffe Logistics is incurred loss in the assessment year under consideration and also in the earlier year, in our opinion it cannot be considered as comparables to the assessee company. Accordingly, the rejection of the TPO is justified.” 7.5 Further, the ITAT, Chennai in the Ahlers India Pvt. Ltd., for the subsequent assessment year namely assessment year 2012-13 in ITA No.795/Mds/2017 (order dated 31.01.2018) had held that the same comparable was to be included in the final list of comparables even though it has incurred loss in two out of three years. The relevant finding of ITAT reads as follows:- “Since this company is making a persistent loss he held that the company cannot be accepted as comparable. On assessee’s objection , the DRP held that since the assessee has not furnished annual reports of earlier years to - 13 - IT(TP)A No.38/CHNY/2024 show that it is not persistent loss making, there is no reason to interfere with the decision of the TPO. Before us, the assessee pleads that the lower authorities erroneously concluding that the company is persistently making losses. It is submitted that the TPO has erred in computing the margins of the company for FY 2011- 12. The OP/OI of GWL for the FY 2011-12 is (+) 4.15 % and hence the company is a profit making company and is comparable to the assessee. This Tribunal although in its case for ay 2011- 12 in ITA No. 1071/Mds/2016 had held that GWL incurred loss in that ay, also in earlier year and hence it cannot be considered as comparable to the assessee, considering the fact that the GWL is earning profits for this ay, it can be held as a comparable . Per contra, the DR supported the order of the TPO and the directions of the DRP. 5.1 We heard the rival submissions and gone through the relevant materials. We find merit in the submissions of the assessee. However, the TPO shall examine the workings given by the assessee stating that the company is making a profit, after giving adequate opportunity to the assessee. If the assesssee’s claim is found correct then the Gordon Woodroffee Logistics Ltd has to be treated as a comparable and re-work the ALP accordingly. The corresponding grounds of appeal is treated as allowed for statistical purposes.” 7.6 From the above order of ITAT, Chennai in the very next year, we find that it had accepted the same comparable i.e., Gordon Woodroffee Logistics Ltd., in the final list of comparables wherein it had incurred losses in two years (AYs 2010-11 and 2011-12) and it made a profit in one year (AY 2012-13). 7.7 Moreover the Bangalore Bench of ITAT in the case of Inteva Products India Automotive Pvt. Ltd., in IT(TP)A No.2843/Bang/2017 (order dated 23.12.2020) and KBACE Technologies Pvt. Ltd., in ITA - 14 - IT(TP)A No.38/CHNY/2024 No.3189/Bang/2018 (order dated 29.01.2020) had held that persistent loss filter can be applied only if there is successive losses in three years and if there is a profit in any one financial year out of three successive financial years, then that company cannot be excluded from the list of comparable on the basis of persistent loss making filter. 7.8 In light of the aforesaid reasoning and judicial pronouncements cited supra, we direct the TPO to include Rheal Software Pvt. Ltd., in the list of comparable companies. It is ordered accordingly. Therefore, the Ground Nos.6 & 6.1 is allowed. C. Exclusion of Daffodil Software Pvt. Ltd., (Ground No.4 & 4.2) 8. The contention of the ld.AR is that the aforesaid company is functionally different from that of the assessee and cannot be included as a comparable. The ld.AR submits that Daffodil Software Pvt. Ltd., is also into product sales and there is no segmental information in the annual report. 8.1 The ld.DR supported the orders of the TPO and the DRP. - 15 - IT(TP)A No.38/CHNY/2024 8.2 We have heard rival submissions and perused the material on record. The financials for the year ending 31.03.2020 with regard to the company, Daffodil Software Pvt. Ltd., is placed on record. On perusal of the same, we find Daffodil Software Pvt. Ltd., is also having revenue from sale of products. We also find from notes to financial statement as on 31.03.2020 (Note 15 – Inventories and Note 21 – revenue from operation) that the company, Daffodil Software Pvt. Ltd., does not have segmented details but only have broad revenue streams. Therefore, on the facts of the instance case, we are of the view that Daffodil Software Pvt. Ltd., cannot be taken as a comparable and we direct the TPO to exclude Daffodil Software Pvt. Ltd., from the list of comparables. It is ordered accordingly. Therefore, the Ground Nos.4 & 4.2 is allowed. 9. In the result, the appeal filed by the assessee is partly-allowed. Order pronounced in the open court on 28th November, 2024 at Chennai. Sd/- Sd/- (एस.आर. रघुनाथा) (S.R. RAGHUNATHA) लेखा सदèय/ACCOUNTANT MEMBER (जॉज[ जॉज[ क े) (GEORGE GEORGE K) उपाÚय¢ /VICE PRESIDENT चेÛनई/Chennai, Ǒदनांक/Dated, the 28th November, 2024 - 16 - IT(TP)A No.38/CHNY/2024 RSR आदेश कȧ ĤǓतͧलͪप अĒेͪषत/Copy to: 1. अपीलाथȸ/Appellant 2. Ĥ×यथȸ/Respondent 3. आयकर आयुÈत /CIT, Chennai 4. ͪवभागीय ĤǓतǓनͬध/DR 5. गाड[ फाईल/GF. "