Appeal Details
Counselvise Citation
[2017] 127 COUNSELVISE.COM (IT) 8879 (ITAT-VISAKHAPATNAM)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
2 year(s) 2 month(s) 15 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
07-06-2017
Appeal Filed By
Assessee
Order Result
Dismissed
Bench Allotted
DB
Assessment Year
2011-2012
Appeal Filed On
23-03-2015
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM SMC BENCH, VISAKHAPATNAM BEFORE SHRI V. DURGA RAO, HON'BLE JUDICIAL MEMBER ITA NO. 100/VIZ/2015 (ASST. YEAR : 2011-12) SAKHARI LAKSHMI PRASADA RAO, D.NO. 9-93, ADIVARAMPETA, BALAGA, SRIKAKULAM. VS. ITO, WARD-2, SRIKAKULAM. PAN NO. ACZPL 8574 B (APPELLANT) (RESPONDENT) ASSESSEE BY : SHRI G.V.N. HARI ADVOCATE. DEPARTMENT BY : SHRI M.K. SETHI SR. DR DATE OF HEARING : 07/06/2017. DATE OF PRONOUNCEMENT : 30/06/2017. O R D E R THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER OF COMMISSIONER OF INCOME TAX (APPEALS)-2, VISAKHAPATNAM, DATED 30/01/2015 FOR THE ASSESSMENT YEAR 2011-12. 2. FACTS ARE IN BRIEF THAT THE ASSESSEE IS AN INDIVIDUAL FILED A RETURN OF INCOME DECLARING TOTAL INCOME OF 2,09,826/-. RETURN FILED BY THE ASSESSEE WAS INITIALLY PROCESSED UNDER SECTION 143(1) OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO AS THE 'ACT'). THEREAFTER, ASSESSEES CASE WAS SELECTED FOR SCRUTINY AND AFTER DUE PROCESS, ASSESSMENT IS COMPLETED BY MAKING ADDITIONS IN RESPECT OF UNPROVED CREDIT TO THE TUNE OF 28 LAKHS AND DEVELOPMENT EXPENSES 8,71,570/-. 2 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) 3. FIRST GROUND OF APPEAL IS RELATING TO UNEXPLAINED CREDIT. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER HAS OBSERVED THAT ASSESSEE HAS TAKEN LOANS FROM SMT. P. JAYALAKSHMI ( 9,80,000/-), SRI PYDI SANYASI APPA RAO ( 9,50,000/-) AND SRI B.V. KRISHNA RAO ( 9,00,000/-) DURING THE YEAR UNDER CONSIDERATION. THE ASSESSING OFFICER CALLED UPON THE ASSESSEE TO PRODUCE THESE CREDITORS AND PROVE THEIR CREDITWORTHINESS AND GENUINENESS OF THE TRANSACTIONS. THE ASSESSING OFFICER, AFTER EXAMINING SRI B.VENKATA KRISHNA RAO, OBSERVED THAT IN THE STATEMENT RECORDED ON OATH, HE HAD DEPOSED THAT HE IS NOT AN INCOME-TAX ASSESSEE AND DURING THE LAST SIX YEARS HE HAD NOT ACQUIRED ANY MOVABLE OR IMMOVABLE PROPERTY. HE WORKED AS A TECHNICIAN IN DISTRICT MEDICAL AND HEALTH OFFICE, SRIKAKULARN AND RETIRED ON 31.07.1995 AND RECEIVING PENSION OF 1,95,600/- PER YEAR AND ALSO GETS AGRICULTURAL INCOME OF RS.10,000/- PER YEAR AND HAS NO OTHER SOURCE OF INCOME. HE FURTHER DEPOSED THAT HE GAVE LOAN OF 9,00,000/- TO THE ASSESSEE THROUGH BANKING CHANNELS. HE STATED THAT ASSESSEE IS RELATIVE AND THE SOURCE FOR THE AMOUNT ADVANCED WAS HIS RETIREMENT BENEFITS. HE CLAIMED THAT HE GAVE AN AMOUNT OF 9,00,000/- ON 28.03.2011 TO THE ASSESSEE AND ALSO STATED THAT HE HAD KEPT THE AMOUNT WITH HIM IN THE HOUSE SINCE THE TIME HE WAS RETIRED ON 31.07.1995 WITHOUT DEPOSITING IN BANK. THE ASSESSING OFFICER FELT THAT THIS IS FAR FROM REALTY. THE ASSESSING OFFICER ALSO NOTED THAT AN AMOUNT OF 9,00,000/- WAS DEPOSITED IN THE BANK JUST ONE DAY BEFORE THE DATE OF ADVANCE. THE ASSESSING OFFICER CAME TO A CONCLUSION THAT THE SAID 3 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) CREDITOR HAD ONLY INCOME FROM PENSION OF 1,95,600/- PER YEAR AND AGRICULTURAL INCOME OF 10,000/- PER YEAR AND THERE IS NO PROOF OF SAVINGS AND DURING THE LAST SIX YEARS, HE HAS NOT ACQUIRED ANY MOVABLE OR IMMOVABLE PROPERTY AND ABSENCE OF WRITTEN DOCUMENT EVIDENCING THE LOAN TRANSACTION BETWEEN THE ASSESSEE AND SRI BOLLAPRAGADA VENKATA KRISHNA RAO WITHOUT ANY INTEREST BEING CHARGED, THE ASSESSING OFFICER DISBELIEVED THE CREDITWORTHINESS OF THE CREDITOR AND GENUINENESS OF THE TRANSACTION AND AS A RESULT MADE THE IMPUGNED ADDITION. 4. ON APPEAL BEFORE THE LD. CIT(A), IT WAS SUBMITTED THAT THE ASSESSEE HAS DISCHARGED HIS ONUS OF PROVING THE IDENTITY, GENUINENESS AND CREDITWORTHINESS OF THE TRANSACTION. THE ASSESSING OFFICER IS NOT JUSTIFIED IN MAKING THE ADDITION. THE LD. CIT(A) AFTER CONSIDERING THE EXPLANATION GIVEN BY THE ASSESSEE, HE HAS OBSERVED THAT THE CREDITOR HAS NO CREDITWORTHINESS TO ADVANCE THE ABOVE SAID AMOUNT. HE ALSO CONSIDERED THAT THE AMOUNT ADVANCED IS FROM HIS RETIREMENT BENEFITS RECEIVED 15 YEARS BACK. THEREFORE, THE LD. CIT(A) NOT BELIEVED THE EXPLANATION OF THE ASSESSEE AND CONFIRMED THE ORDER OF THE ASSESSING OFFICER. 5. BEFORE THE TRIBUNAL EXCEPT STATING THAT ASSESSEE HAS PROVED THE IDENTITY, GENUINENESS AND CREDITWORTHINESS OF THE CREDITOR, NO OTHER MATERIAL IS FILED. I FIND THAT THE ASSESSEE HAS FAILED TO PROVE THE CREDITWORTHINESS OF THE CREDITOR AND ALSO THE GENUINENESS OF THE TRANSACTION AND THEREFORE, THE ASSESSING OFFICER AS WELL AS LD. CIT(A) 4 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) CORRECTLY MADE THE ADDITION IN THE HANDS OF THE ASSESSEE. I FIND NO INFIRMITY IN THE ORDER OF THE LD. CIT(A). 6 . SO FAR AS CREDIT IN THE NAME OF SRI PYDI SANYASI APPA RAO, THE ASSESSING OFFICER HAS NOTED FROM THE SWORN STATEMENT OF SRI PYTH SANYASI APA RAO THAT HE WORKED AS A MANAGER-IN-CHARGE IN DISTRICT CENTRAL CO-OPERATIVE BANK AND RETIRED IN THE MONTH OF JUNE, 2006. HE HAD NOT FILED ANY RETURN OF INCOME SO FAR AND DURING THE LAST SIX YEARS HE HAS NOT ACQUIRED ANY MOVABLE OR IMMOVABLE PROPERTY AND ALSO NOT INVESTED IN ANY BUSINESS. HIS ONLY SOURCE OF INCOME WAS PENSION OF RS.750/- PER MONTH I.E. RS. 9,000/- PER YEAR AND HAS ALSO AN AGRICULTURAL INCOME OF RS.30,000/- PER YEAR. HE FURTHER STATED THAT HE GAVE LOAN OF RS. 9,50,0O0/- TO THE ASSESSEE ON 22.01.2011 VIDE CHEQUE NO.25408, BUT HE IS UNABLE TO FURNISH THE COPY OF THE BANK STATEMENT OR COPY OF THE CHEQUE LEAF. HE STATED THAT THE ASSESSEE IS HIS RELATIVE. REGARDING THE SOURCE FOR THE AMOUNT ADVANCED TO THE ASSESSEE, HE STATED THAT HE HAD COLLECTED THE AMOUNTS FROM THE VILLAGERS OF UDIGILAPADU, JALAMURU MANDAL & SRIKAKULAM DISTRICT TO WHOM HE GAVE ADVANCES EARLIER AND THESE AMOUNTS WERE POOLED AND DEPOSITED IN HIS SAVINGS BANK ACCOUNT NO.30633744970 TO GIVE THE LOAN TO THE ASSESSEE. BUT SRI PYDI SANYASI APPA RAO WAS UNABLE TO GIVE THE DETAILS OF THE PERSONS FROM WHOM HE COLLECTED AMOUNTS AND HOW MUCH AMOUNT COLLECTED. THE ASSESSING OFFICER NOTED THAT SRI PYDI SANYASI APPA RAO RETIRED IN JUNE, 2006 AND WAS RECEIVING PENSION OF RS 9,000/- PER YEAR AND AGRICULTURE INCOME OF RS 30,000/- PER YEAR, 5 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) I.E., THE TOTAL HE IS RECEIVING AN INCOME OF RS. 39,000/- (9,000/- + 30,000/-) PER YEAR, AND WITH SUCH MEAGER INCOME THE CLAIM THAT HE HAD ADVANCED AN AMOUNT OF RS 9,50,000/- TO THE ASSESSES LACKED CREDENCE. NO EVIDENCE WAS GIVEN FOR THE SAVINGS MADE AND ADVANCES GIVEN. THERE ARE NO ASSETS ACQUIRED, WHETHER IMMOVABLE PROPERTY OR MOVABLE PROPERTY DURING THE LAST SIX YEARS. FURTHER, WRITTEN DOCUMENT EVIDENCING THE TRANSACTION BETWEEN THE ASSESSEE AND SRI PYDI SANYASI APPA RAO WAS PRODUCED AND NO INTEREST WAS CHARGED. SRI PYDI SANYASI APPA RAO IS NOT FILING RETURNS OF INCOME. THE ASSESSING OFFICER ALSO NOTED THAT SRI PYDI SANYASI APPA RAO HAD TAKEN EDUCATIONAL LOAN FROM ANDHRA PRADESH GRAMEENA VIKAS BANK, MAIN BRANCH, SRIKAKULAM ALONG WITH HIS SON PYDI ASHOK KUMAR FOR THE STUDY OF MS HEALTHCARE IN USA OF RS 4,00,000/- IN THE YEAR 2008 AND HE WAS STILL REPAYING THE AMOUNT AND THAT THE OUTSTANDING AMOUNT AS ON THE DATE OF DEPOSITION WAS RS. 2,20,000/-APPROXIMATELY. IN VIEW OF THE ABOVE, THE ASSESSING OFFICER CONCLUDED THAT SRI PYDI SANYASI APPA RAO DID NOT HAVE CREDIT WORTHINESS AND GENUINENESS OF THE TRANSACTION WAS NOT PROVED. 7 . ON APPEAL BEFORE THE LD. CIT(A), IT WAS SUBMITTED THAT THE ASSESSEE HAS DISCHARGED HIS ONUS, THEREFORE, ADDITION MADE BY THE ASSESSING OFFICER IS NOT CORRECT. THE LD. CIT(A) AFTER CONSIDERING THE EXPLANATION OF THE ASSESSEE HAS OBSERVED THAT THE ABOVE SAID CREDITOR DID NOT HAVE ANY SOURCE TO ADVANCE THE IMPUGNED AMOUNT. IT WAS FURTHER SUBMITTED BEFORE THE ASSESSING OFFICER THAT THE CREDITOR HAS ADVANCED EARLIER TO VARIOUS PEOPLE AND COLLECTED FUNDS FROM THOSE 6 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) PEOPLE AND ADVANCED TO THE ASSESSEE. THE ASSESSEE HAS NOT FILED ANY DETAILS REGARDING WHEN THE CREDITOR ADVANCED FUNDS TO THE THIRD PARTIES, WHEN HE RECEIVED AND WHAT WAS THE AMOUNT. THEREFORE, LD. CIT(A) CONFIRMED THE ORDER OF THE ASSESSING OFFICER. 8 . BEFORE THE TRIBUNAL ALSO, ASSESSEE HAS NOT FILED ANY DETAILS EXCEPT REITERATING THE SUBMISSIONS WHICH HE MADE BEFORE THE LOWER AUTHORITIES. THEREFORE, I FIND NO FAULT IN THE ADDITION MADE BY THE ASSESSING OFFICER AND CONFIRMED BY THE LD. CIT(A). 9. SO FAR CREDIT IN THE NAME OF P. JAYALAKSHMI IS CONCERNED, THE ASSESSING OFFICER HAS OBSERVED FROM THE STATEMENT OF SMT. PUTREVU JAYAIAKSHM, SRIKAKULAM HAD DEPOSED THAT SHE IS WORKING AS LIC AGENT IN SRIKAKULAM. IT WAS STATED THAT SHE WAS ASSESSED TO TAX. SHE WAS GETTING AROUND RS.40,000/- AS LIC COMMISSION PER YEAR AND SHE HAS NO OTHER INCOME. SHE STATED THAT SHE HAD ADVANCED 9,50,000/- TO THE ASSESSEE ON 25/10/2010 VIDE CHEQUE NO. 5319, BUT SHE WAS UNABLE TO PRODUCE THE COPY OF BANK ACCOUNT STATEMENT OR COPY OF CHEQUE LEAF. SHE STATED THAT ASSESSEE IS HER BROTHER AND THE SOURCE FOR THE LOAN AMOUNT ADVANCED TO THE ASSESSEE ARE THE SALE PROCEEDS OF THE GOLD, WHICH SHE CLAIMS TO HAVE SOLD IN THE MONTH OF OCTOBER, 2010 AND THE REMAINING ARE THE SAVINGS, LIC COMMISSION RECEIVED AND THE GIFTS RECEIVED OF 1,25,000/- AT THE TIME OF HALF SAREE FUNCTION OF HER DAUGHTER HIMA LAKSHMI IN THE YEAR 2006. BUT SHE WAS UNABLE TO GIVE THE PROOF FOR THE GOLD SOLD LIKE COPY OF THE RECEIPT ETC. OR EVEN THE DETAILS OF SALE OF GOLD LIKE WHERE IT WAS SOLD; QUANTITY OF GOLD SOLD, AT 7 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) WHAT RATE GOLD WAS SOLD ETC. THERE WAS NO PROOF FOR SAVINGS MADE. THE DETAILS OF ALLEGED GIFTS RECEIVED WERE NOT FURNISHED. THE ASSESSING OFFICER NOTED THAT SHE HAS FILED INCOME-TAX RETURN FOR THE ASSESSMENT YEAR 2011-12 IN ITR-4 AND ON VERIFICATION OF THE SAID RETURN OF INCOME, IT WAS FOUND THAT IN THE BALANCE SHEET - CURRENT ASSETS, LOANS AND ADVANCES, THE RELEVANT COLUMN NO: A.II - SUNDRY DEBTORS' WAS LEFT BLANK. THERE WERE NO ASSETS ACQUIRED, WHETHER IMMOVABLE PROPERTY OR MOVABLE PROPERTY, DURING THE LAST SIX YEARS. THERE WAS NO WRITTEN DOCUMENT EVIDENCING THE TRANSACTION BETWEEN THE ASSESSEE AND SMT.PUTREVU JAYA LAKSHMI AND NO INTEREST WAS CHARGED. THEREFORE, THE ASSESSING OFFICER CONCLUDED THAT SMT. PUTREVU JAYA LAKSHMI HAS NO CREDIT WORTHINESS AND THAT THE GENUINENESS OF THE TRANSACTION WAS NOT PROVED . 10 . ON APPEAL BEFORE THE LD. CIT(A), IT WAS SUBMITTED THAT LOAN CREDITOR IS ASSESSED TO TAX AND THE TRANSACTION IS THROUGH BANKING CHANNEL. THEREFORE, THE ASSESSING OFFICER WAS NOT JUSTIFIED IN MAKING THE ADDITION. THE LD. CIT(A) AFTER CONSIDERING THE EXPLANATION OF THE ASSESSEE OBSERVED THAT THE CREDITOR HAS GIVEN LOAN TO THE ASSESSEE OUT OF JEWELLERY SALES AND GIFT RECEIVED FROM CERTAIN OCCASIONS, HOWEVER, THE ASSESSEE HAS NOT FILED ANY DETAILS IN RESPECT OF SALE OF JEWELLERY AS WELL AS GIFT RECEIVED. THEREFORE, LD. CIT(A) CONFIRMED THE ORDER OF THE ASSESSING OFFICER. 11 . EVEN BEFORE THE TRIBUNAL, NO EVIDENCE IS FILED TO SUBSTANTIATE THE CASE OF THE ASSESSEE. IN VIEW OF THE ABOVE, LD. CIT(A) HAS CORRECTLY 8 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) CONFIRMED THE ORDER OF THE ASSESSING OFFICER. THUS, THIS GROUND OF APPEAL RAISED BY THE ASSESSEE IS DISMISSED. 12 . THE SECOND GROUND OF APPEAL RELATING TO DISALLOWANCE OF DEVELOPMENT EXPENSES. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER HAS NOTED THAT THE ASSESSEE CLAIMED COST OF DEVELOPMENT OF VACANT SITE, WHICH WAS SOLD ON 15/09/2010 AT RS.9,28,570/-. IN THE CONFIRMATION, IT WAS MENTIONED THAT THE TOTAL COST OF DEVELOPMENT OF THE SITE IN SURVEY NO 126/2C I.E. FOR DEVELOPING 486 SQ. YARDS WAS 15,07,140/-, AND THAT THE ASSESSEE'S SHARE OF EXPENSES IN REGARD TO 285 SQ. YARD WAS CLAIMED AT RS.9,28,570/-. THE ASSESSING OFFICER NOTED THAT THE ASSESSEE'S SHARE IN THE TOTAL SITE WAS ONLY 285 SQ.YARDS AND THEREFORE THE PROPORTIONATE COST OF DEVELOPMENT WORKED OUT TO 8,83,816/- ONLY, AND THAT EVEN THIS AMOUNT OF 8,83,816/- SPENT FOR DEVELOPING THE VACANT SITE WAS ALSO ON THE HIGHER SIDE. A SHOW CAUSE LETTER WAS ISSUED ON 30.07.2013 REQUESTING THE ASSESSEE TO EXPLAIN, WHY SUCH A HUGE AMOUNT WAS SPENT TOWARDS DEVELOPMENT OF THE VACANT SITE AND WHY HIS CLAIM OF COST OF DEVELOPMENT OF RS.9,28,570/- SHOULD NOT BE DISALLOWED AND BROUGHT TO TAX. IN RESPONSE TO THE SHOW CAUSE LETTER, THE ASSESSEE SUBMITTED THAT THE SAID VACANT SITE WAS NOT IN GOOD SHAPE AND FULLY COVERED WITH BUSHES, TREES AND MOST OF THE EXTENT IS IN UPS AND DOWNS. MOREOVER, THIS SITE WAS NOT GOOD FOR SENTIMENTAL REASONS, HENCE, IT REQUIRED MORE AMOUNT FOR DEVELOPMENT. THE ASSESSEE CLAIMED THAT HE AND HIS WIFE SMT.S.GOWRI ENTRUSTED THIS DEVELOPMENT WORK TO 1. SRI TANDRA HARI AND 2. SRI TANDRA 9 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) GOVINDA RAO AND BOTH WERE PAID AN AMOUNT OF 15,07,140/-. THE ASSESSEE FURTHER STATED THAT OUT OF THIS AMOUNT, THE ASSESSEE SPENT RS.9,28,570/- IRRESPECTIVE OF HIS EXTENT OF OWNERSHIP. COPY OF THE AGREEMENT WAS SUBMITTED. ON VERIFICATION OF THE COPY OF THE AGREEMENT BETWEEN THE ASSESSEE AND HIS WIFE AS ONE PARTY AND SRI TANDRA HARI AND TANDRA GOVINDA RAO AS ANOTHER PARTY, IT WAS FOUND THAT THE AGREEMENT WAS FOR LEVELLING THE SAID SITE, REMOVING THE WASTE PLANTS IN THE SITE AND TAKING OUT THE OLD SOIL IN THE SITE UP TO A DEPTH OF 12 FEET AND REFILLING THE SITE WITH NEW SOIL. THE AGREEMENT WAS NOT REGISTERED. THERE WERE NO STRUCTURES WHEN THE SITE WAS ACQUIRED AND THAT THE ASSESSEE HAS NOT CONSTRUCTED ANY STRUCTURE IN THE SITE TAKING OUT THE SOIL UP TO 12 FEET AND REFILLING IT AGAIN WAS NOT REQUIRED TO SELL THE SITE AS IT IS. FURTHER, THE COST OF ACQUISITION OF SITE HAVING AN EXTENT OF 285 SQUARE YARDS BY THE ASSESSEE WAS ONLY RS. 8,32,771/- AND THAT THE CLAIM OF COST OF DEVELOPMENT OF 9,28,570/- WAS NOT REASONABLE AT ANY STANDARDS. THE ASSESSING OFFICER DOUBTED THE GENUINENESS OF THE SAID EXPENDITURE. TO MEET THE ENDS OF JUSTICE, THE ASSESSING OFFICER ALLOWED RS.200/- PER SQUARE YARD AMOUNTING TO RS.57,000/- (285 X 200) TOWARDS COST OF DEVELOPMENT AND THE EXCESS CLAIM OF RS.8,71,570/- (9,28,570 - 57,000/-) WAS SUBJECTED TO TAX UNDER SHORT TERM CAPITAL GAINS. 13 . BEFORE THE LD. CIT(A) IT WAS SUBMITTED THAT DISALLOWANCE MADE BY THE ASSESSING OFFICER IS NOT CORRECT. THE EXPENSES ARE INCURRED BY ENTERING AN AGREEMENT WITH THE THIRD PARTIES AND THEREFORE, SAME MAY BE ALLOWED. THE LD. CIT(A) AFTER CONSIDERING THE EXPLANATION OF THE 10 ITA NO. 100/VIZ/2015 (SAKHARI LAKSHMI PRASADA RAO) ASSESSEE HAS OBSERVED THAT THE ASSESSING OFFICER IS NOT JUSTIFIED IN ESTIMATION, HOWEVER, THE ESTIMATION AT 200/- PER SQ.YARD IS TOO LOW, THEREFORE, HE ESTIMATED THE DEVELOPMENT EXPENDITURE AT 600/- PER SQ.YARD., AMOUNTING TO 1,71,000/-. ACCORDINGLY, HE PARTLY ALLOWED THE GROUND RAISED BY THE ASSESSEE. 14. BEFORE THE TRIBUNAL, NO EVIDENCE IS FILED TO SUBSTANTIATE THE DEVELOPMENT EXPENDITURE INCURRED BY THE ASSESSEE. AFTER CONSIDERING THE FACTS AND CIRCUMSTANCES OF THE CASE, I AM OF THE OPINION THAT, LD.CIT(A) REASONABLY ESTIMATED THE DEVELOPMENT EXPENSES AT 600/- PER SQ. YARD, THEREFORE, NO INTERFERENCE IS CALLED FOR. THUS, THIS GROUND OF APPEAL RAISED BY THE ASSESSEE IS DISMISSED. 15 . IN THE RESULT, APPEAL FILED BY THE ASSESSEE IS DISMISSED. ORDER PRONOUNCED IN OPEN COURT ON THIS 30 TH DAY OF JUNE, 2017. SD/- (V. DURGA RAO) JUDICIAL MEMBER DATED : 30 TH JUNE, 2017. VR/- COPY TO: 1. THE ASSESSEE - SAKHARI LAKSHMI PRASADA RAO, D.NO. 9-93, ADIVARAMPETA, BALAGA, SRIKAKULAM. 2. THE REVENUE ITO, WARD-2, SRIKAKULAM. 3. THE CIT-2, VISAKHAPATNAM. 4. THE CIT(A)-2, VISAKHAPATNAM. 5. THE D.R., VISAKHAPATNAM. 6. GUARD FILE. BY ORDER (VUKKEM RAMBABU) SR.PS, ITAT, VISAKHAPATNAM.
