Telangana State Seed Certification Agency, Hyd, Hyderabad V. CIT(Exemptions), Hyd, Hyderabad

ITA 1021/HYD/2016

• Counselvise Citation: [2018] 126 COUNSELVISE.COM (IT) 2678 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 6 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-01-2018
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: misc
• Appeal Filed On: 15-07-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: J SIRI KUMAR
• Assessee Lawyers: S RAMA RAO
• Keywords: Charitable institution
• Section: 12A; 12AA; 10; 11

Judgement Text

ITA NO 1021 OF 2016 TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD. PAGE 1 OF 8 IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD A BENCH, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA NO.1021/HYD/2016 (A.Y. NOT APPLICABLE) TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD PAN: AADAT 9694 F VS COMMISSIONER OF INCOME TAX (EXEMPTIONS) HYDERABAD (APPELLANT) (RESPONDENT) FOR ASSESSEE : SHRI S. RAMA RAO FOR REVENUE : SHRI J. SIRI KUMAR, CIT (DR) O R D E R PER SMT. P. MADHAVI DEVI, J.M. THIS IS ASSESSEES APPEAL AGAINST THE ORDER OF THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), DATED 29.0 4.2016 REJECTING THE ASSESSEES APPLICATION FOR GRANT OF R EGISTRATION U/S 12AA OF THE ACT. 2. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE IS A SOCIETY REGISTERED AS THE A.P. STATE SEED CERTIFICATION AGE NCY. IT FILED AN APPLICATION FOR REGISTRATION U/S 12AA OF THE ACT BY FILING FORM NO.10A ON 30.10.2015 ALONG WITH (I) THE CERTIFIED C OPY OF THE INSTRUMENT UNDER WHICH THE TRUST WAS ESTABLISHED; ( II) LIST OF TRUSTEES; (III) COPY OF PAN; AND (IV) A BRIEF NOTE ON ACTIVITIES OF THE ORGANIZATION. THE CIT (E) REQUIRED THE ASSESSEE TO PRODUCE THE DATE OF HEARING: 21.12.2017 DATE OF PRONOUNCEMENT: 2 5 . 0 1 .2018 ITA NO 1021 OF 2016 TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD. PAGE 2 OF 8 ORIGINAL TRUST DEED/MOU FOR VERIFICATION AND TO FUR NISH DETAILED REPLY ON SPECIFIC POINTS. THOUGH THE LEARNED REPRES ENTATIVE OF THE ASSESSEE APPEARED FROM TIME TO TIME, HE FAILED TO F ILE THE REQUIRED DETAILS. ON GOING THROUGH THE INFORMATION ALREADY F ILED BY THE SOCIETY, THE CIT (E) OBSERVED THAT THE HON'BLE HIGH COURT OF ANDHRA PRADESH HAS HELD THAT THE OBJECTS OF A.P. ST ATE SEED CERTIFICATION AGENCY ARE NOT FOR ADVANCEMENT OF AN Y OTHER OBJECT OF GENERAL PUBLIC UTILITY AND HENCE NOT FOR CHARI TABLE PURPOSES AND DISMISSED THE WRIT FILED BY THE A.P. STATE SEED CERTIFICATION AGENCY. OBSERVING THAT THE SAID CASE LAW IS SQUAREL Y APPLICABLE TO THE ASSESSEE SOCIETY, HE REJECTED THE ASSESSEES AP PLICATION, AGAINST WHICH, THE ASSESSEE IS IN APPEAL BEFORE US. 3. THE LEARNED COUNSEL FOR THE ASSESSEE SUBMITTED T HAT THE ASSESSEE HAS BEEN FORMED AFTER THE FORMATION OF THE STATE OF TELANGANA, BUT THE AIMS AND OBJECTS OF THE ASSESSEE SOCIETY ARE THE SAME AS IN THE CASE OF A.P. STATE SEED CERTIFIC ATION AGENCY. HE SUBMITTED THAT THE ISSUE BEFORE THE HON'BLE A.P. HI GH COURT IS DIFFERENT FROM THE ISSUE OF REGISTRATION U/S 12AA O F THE ACT BEFORE THE CIT (E). THEREFORE, ACCORDING TO HIM, THE CIT(E ) OUGHT NOT TO HAVE RELIED UPON THE DECISION OF THE HON'BLE HIGH C OURT TO DENY THE REGISTRATION. HE SUBMITTED THAT IN THE CASE OF A.P. STATE SEED CERTIFICATION AGENCY, THE ISSUE BEFORE THE HON'BLE HIGH COURT WAS THE REGISTRATION U/S 10(23)C(IV) OF THE ACT AND THE HON'BLE HIGH COURT, AFTER CONSIDERING THE AMENDED PROVISO TO SEC TION 2(15) OF THE ACT, OBSERVED THAT THE ASSESSEE WAS ENGAGED IN THE ACTIVITY OF TRADE/BUSINESS/COMMERCE AND THAT ITS INCOME WAS MOR E THAN RS.25.00 LAKHS FOR THE RELEVANT A.YS, HAS DENIED TH E REGISTRATION U/S 10(23)(C)(IV) OF THE ACT, WHEREAS ACCORDING TO HIM, THE HON'BLE ITA NO 1021 OF 2016 TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD. PAGE 3 OF 8 HIGH COURT HAS AGREED THAT THE ACTIVITIES CARRIED O N BY THE ASSESSEE WERE TOWARDS THE ADVANCEMENT OF GENERAL PU BLIC UTILITY. HE SUBMITTED THAT VIDE REGISTRATION U/S 10(23)(C) O F THE ACT, THE INCOME OF THE ASSESSEE WOULD GO ENTIRELY OUT OF THE TAX AMBIT WHEREAS THE REGISTRATION U/S 12A WOULD ONLY ENABLE THE ASSESSEE TO CLAIM THE DEDUCTION U/S 11 OF THE ACT WHICH IS A GAIN SUBJECT TO VERIFICATION BY THE AO YEAR AFTER YEAR. THEREFORE, ACCORDING TO HIM, BOTH THE SECTIONS ARE INDEPENDENT AND STAND PART AN D THE DECISION OF THE HON'BLE HIGH COURT WITH RESPECT TO ALLOWABILITY OF SECTION 10(23)(C) CANNOT BE APPLIED TO A CASE OF RE JECTION OF REGISTRATION U/S 12AA OF THE ACT. HE HAS ALSO DRAWN OUR ATTENTION TO THE MAIN OBJECTS OF THE ASSESSEE SOCIETY TO DEMO NSTRATE THAT THE SEED CERTIFICATION IS FOR THE PURPOSE OF THE BENEFI T OF THE FARMERS OF THE STATE AND THEREFORE, THE WORK INVOLVES ADVANCE MENT OF GENERAL PUBLIC UTILITY. HE SUBMITTED THAT SECTION 2(15) HAS SINCE UNDERGONE AN AMENDMENT, WHEREBY THE CUT OFF BENCH M ARK HAS BEEN FIXED AT 20% OF THE TOTAL RECEIPTS INSTEAD OF THE FIXED LIMIT OF RS.25.00 LAKHS W.E.F. 1.4.2016. HE REFERRED TO THE CIRCULAR OF CBDT DATED 27.05.2016 WHICH CLARIFIED THAT IT SHALL NOT BE MANDATORY TO CANCEL THE REGISTRATION ALREADY GRANTE D U/S 12AA TO A CHARITABLE INSTITUTION, MERELY BECAUSE THE CUT OF F SPECIFIED IN THE PROVISIONS OF SECTION 2(15), IS EXCEEDED IN A PARTI CULAR YEAR WITHOUT THERE BEING ANY CHANGE IN THE NATURE OF THE ACTIVITIES OF THE INSTITUTION AND THAT IF IN ANY PARTICULAR YEAR, THE SPECIFIED CUT OFF IS EXCEEDED, THE TAX EXEMPTION WOULD BE DENIED TO THE INSTITUTION IN THAT YEAR AND CANCELLATION OF REGIST RATION WOULD NOT BE MANDATORY UNLESS SUCH CANCELLATION BECOMES NECES SARY ON THE GROUND(S) PRESCRIBED UNDER THE ACT. THUS, HE SUBMIT TED THAT THE ELIGIBILITY OF THE ASSESSEE TO CLAIM EXEMPTION U/S 11 OF THE ACT IS TO BE VERIFIED BY THE AO EVERY YEAR, EVEN THOUGH TH E REGISTRATION IS ITA NO 1021 OF 2016 TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD. PAGE 4 OF 8 GRANTED U/S 12A OF THE ACT UNLIKE THE REGISTRATION GRANTED U/S 10(23)(C) OF THE ACT UNDER WHICH THE EXEMPTIONS SHA LL BE ALLOWED TILL SUCH REGISTRATION IS REVOKED. THUS, HE PRAYED THAT THE ASSESSEE SHOULD BE GRANTED REGISTRATION U/S 12AA OF THE ACT. HE HAS ALSO PLACED RELIANCE UPON THE VARIOUS CASE LAW TO THE EF FECT THAT SECTION 12A REGISTRATION SHALL NOT BE CANCELLED IN VIEW OF THE APPLICABILITY OF THE AMENDED PROVISO TO SECTION 2(15) OF THE I.T. ACT. 4. THE LEARNED DR, ON THE OTHER HAND, SUPPORTED THE ORDERS OF THE CIT (E) AND ALSO PLACED RELIANCE UPON THE DECISION OF THE HON'BLE HIGH COURT OF ANDHRA PRADESH IN THE CAS E OF A.P. STATE SEED CERTIFICATION AGENCY REFERRED TO BY THE CIT (E). 5. HAVING REGARD TO THE RIVAL CONTENTIONS AND THE M ATERIAL ON RECORD, WE FIND THAT THE ASSESSEE EARLIER KNOWN AS A.P. STATE SEED CERTIFICATION AGENCY, ON FORMATION OF THE STAT E OF TELANGANA IN THE YEAR 2014, HAD BEEN FORMED AS TELANGANA STAT E SEED CERTIFICATION AGENCY AND SUBMITTED AN APPLICATION F OR REGISTRATION U/S 12AA OF THE ACT IN FORM NO.10A. WE FIND THAT TH E CIT (E), WITHOUT VERIFYING THE AIMS AND OBJECTS OF THE ASSES SEE SOCIETY, HAS REJECTED THE SAME BY FOLLOWING THE DECISION OF THE HON'BLE A.P. HIGH COURT IN THE CASE OF A.P. STATE SEED CERTIFICA TION AGENCY VS. CHIEF COMMISSIONER OF INCOME TAX & OTHERS, REPORTED IN (2013) 356 ITR 0360 (A.P). WE HAVE GONE THROUGH THE DECISI ON OF THE HON'BLE HIGH COURT AND WE FIND THAT THE GRIEVANCE O F THE ASSESSEE THEREIN WAS AGAINST THE REJECTION OF THE ASSESSEES APPLICATION FOR APPROVAL U/S 10(23)(C) OF THE ACT. WHILE CONSIDERIN G THE ASSESSEES APPLICATION FOR RENEWAL OF REGISTRATION U/S 10(23)(C)(IV) OF THE ACT FOR THE A.Y 2010-11, THE HON'BLE HIGH CO URT HAS ALSO ITA NO 1021 OF 2016 TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD. PAGE 5 OF 8 CONSIDERED THE AUDITED ACCOUNTS OF THE ASSESSEE FOR THE FINANCIAL YEAR 2009-10 RELEVANT FOR THE A.Y 2010-11 AND OBSER VED THAT THE ASSESSEE IS CARRYING ON THE ACTIVITY OF RENDERING T HE SERVICE IN RELATION TO ANY TRADE, COMMERCE OF BUSINESS UNDER T HE PROVISIONS OF SECTION 2(15) OF THE ACT AND THEREFORE, SUCH AN ACTIVITY FALLS WITHIN THE ADVANCEMENT OF ANY OTHER OBJECT OR GENE RAL PUBLIC UTILITY INCLUDED IN THE TERMS CHARITABLE PURPOSE A S DEFINED IN SECTION 2(15) OF THE ACT. THE HON'BLE HIGH COURT HE LD THAT, IN VIEW OF THE FACT THAT THE CERTIFICATION OF THE SEED BY T HE PETITIONERS FACILITATES TRADE, COMMERCE OR BUSINESS IN THE CERT IFYING THE SEEDS OF THE CLIENTS OF THE PETITIONER, THE PROVISO TO SU B-SECTION WOULD COME INTO OPERATION AND THEREFORE, ITS ACTIVITIES C ANNOT BE HELD TO BE FOR CHARITABLE PURPOSES AND THEREFORE, UPHELD TH E REJECTION OF THE PETITIONERS APPEAL FOR RENEWAL OF REGISTRATION U/S 10(23(C)(IV) OF THE ACT. THE RELEVANT PORTION OF THE DECISION IS REPRODUCED HEREUNDER FOR READY REFERENCE: 17. SECTION 8 OF THE SEEDS ACT, 1966 EMPOWERS THE STATE GOVERNMENT OR THE CENTRAL GOVERNMENT IN CONSULTATION WITH THE STATE GOVERNMENT TO ESTABLISH , BY NOTIFICATION IN THE OFFICIAL GAZETTE, A CERTIFIC ATION AGENCY FOR THE STATE TO CARRY OUT THE FUNCTIONS ENTRUSTED TO THE CERTIFICATION AGENCY BY OR UNDER THE SEEDS ACT. THE PETITIONER WAS REGISTERED UNDER THE ANDHRA PRADESH (TELANGANA AREA) PUBLIC SOCIETIES REGISTRATION ACT, 1350 FASLI WITH REGISTRATION NO. 334/76. BY G.O.MS.NO.435 FOOD AND AGRICULTURE (EP- II) DEPARTMENT DATED 01-06- 1977, THE STATE GOVERNMENT APPROVED THE PROPOSAL OF THE DIRECTOR OF AGRICULTURE AND DIRECTED THAT THE PETITIONER SHALL CARRY ON THE FUNCTIONS OF THE CERTIFICATION AGENCY UNDER THE SEEDS ACT, 1966 IN THE ANDHRA PRADESH STA TE WITH EFFECT FROM 01-06-1977. THE OBJECTS OF THE PETITIONER HAVE ALREADY BEEN SET OUT ABOVE. THE PETITIONER THUS CERTIFIES THE SEEDS WHICH MEET THE MINIMUM SEEDS CERTIFICATION STANDARDS AS PER INDIAN MINIMUM SEED CERTIFICATION STANDARDS, 1988. SEED GROWERS ENTER INTO CONTRACT WITH A SOCIETY/AGENT, W HO APPROACHES THE PETITIONER FOR CERTIFICATION OF THE SEEDS ITA NO 1021 OF 2016 TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD. PAGE 6 OF 8 AND AFTER SECURING CERTIFICATION, THEY SELL THE CER TIFIED SEEDS TO THE FARMERS AT A MARKET PRICE DETERMINED B Y THEM. THE PETITIONER COLLECTS A FEE FOR PROVIDING CERTIFICATION AS THE PROCESS OF CERTIFICATION INVOL VES TECHNICAL AND SCIENTIFIC EVALUATION OF THE SEEDS ALTHOUGH THE FEE COLLECTED BY IT WOULD BE ENOUGH TO ENABLE IT TO SUSTAIN ITS ACTIVITIES AND MAY NOT RES ULT IN MUCH PROFIT. THE TERM 'ADVANCEMENT OF ANY OTHER OBJECT OF GENERAL PUBLIC UTILITY' USED IN SECTION 2 (15) OF THE ACT INCLUDES ALL OBJECTS TO PROMOTE THE WELF ARE OF THE PUBLIC PARTICULARLY WHEN THE OBJECT IS TO PROMOTE OR PROTECT THE INTEREST OF A PARTICULAR TRA DE OR INDUSTRY. THE ACTIVITY OF THE PETITIONER WHICH FACILITATES SALE OF CERTIFIED SEEDS TO FARMERS THER EFORE FALLS WITHIN 'ADVANCEMENT OF ANY OTHER OBJECT OF GENERAL PUBLIC UTILITY' INCLUDED IN THE DEFINITION OF THE TERM 'CHARITABLE PURPOSE' AS DEFINED IN SECTION 2 ( 15) OF THE ACT BUT IN VIEW OF THE FACT THAT CERTIFICATI ON OF SEEDS BY THE PETITIONER FACILITATES TRADE, COMMERCE OR BUSINESS IN THE CERTIFIED SEEDS BY THE CLIENT OF TH E PETITIONER, THE PROVISO TO THE SAID SECTION WOULD C OME INTO OPERATION. THUS THE PETITIONER'S ACTIVITY ASSI STS THE SALE OF CERTIFIED SEEDS AND IS 'IN RELATION TO ANY TRADE, COMMERCE OR BUSINESS' AND THEREFORE ITS ACTIVITY CANNOT BE HELD TO BE A 'CHARITABLE PURPOSE '. IN THIS VIEW OF THE MATTER, WE HOLD THAT THE 1ST RESPONDENT RIGHTLY REJECTED THE APPLICATION OF THE PETITIONER FOR APPROVAL UNDER SECTION 10 (23C) (IV) OF THE ACT. 6. WE THUS, FIND THAT THE HON'BLE HIGH COURT HAS HE LD THAT THE ASSESSEE IS RENDERING SERVICES IN RELATION TO TRADE COMMERCE OR BUSINESS AND SINCE ITS INCOME EXCEEDED RS.25.00 LAKHS, IT CANNOT BE TREATED AS A CHARITABLE INSTITU TION. THIS DECISION OF THE HON'BLE HIGH COURT IS DATED17.12.20 12. WE FIND THAT THERE ARE AMENDMENTS TO SECTION 2(15) SUBSEQUE NT TO THIS DATE. VIDE FINANCE ACT OF 2015 W.E.F. 1.4.2016, THE CUT OFF BENCHMARK HAS BEEN CHANGED TO 20% OF THE TOTAL RECE IPTS INSTEAD OF THE FIXED LIMIT OF RS.25.00 LAKHS AS IT EXISTED EARLIER. FURTHER, WE ALSO OBSERVE THAT VIDE FINANCE ACT OF 2012, A NE W SUB-SECTION 8 HAS BEEN INSERTED U/S 13 TO PROVIDE THAT SUCH ORG ANIZATION ITA NO 1021 OF 2016 TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD. PAGE 7 OF 8 WOULD NOT GET THE BENEFIT OF TAX EXEMPTION IN THE P ARTICULAR YEAR IN WHICH ITS RECEIPTS FROM THE COMMERCE ACTIVITIES EXCEEDS THE THRESHOLD LIMIT WHETHER OR NOT THE REGISTRATION GRA NTED IS CANCELLED AND THE AMENDMENT HAS BEEN MADE RETROSPEC TIVELY FROM 1.4.2009 AND THEREFORE, IT APPLIES TO A.YS 2009-10 ONWARDS. THE CBDT HAS ALSO CLARIFIED THAT IN VIEW OF THIS POSITI ON, IT SHALL NOT BE MANDATORY, FOR THE REGISTRATION GRANTED U/S 12AA OF THE ACT TO A CHARITABLE INSTITUTION, TO BE CANCELLED MERELY ON T HE GROUND THAT THE CUT OFF SPECIFIED IN THE PROVISO TO SECTION 2(1 5) OF THE ACT IS EXCEEDED IN A PARTICULAR YEAR WITHOUT THERE BEING A NY CHANGE IN THE NATURE OF THE ACTIVITIES OF THE INSTITUTION AND THAT, IF IN ANY PARTICULAR YEAR, THE SPECIFIED LIMIT EXCEEDS, THE T AX EXEMPTION WOULD BE DENIED TO THE INSTITUTION IN THAT YEAR AND CANCELLATION OF THE REGISTRATION WOULD NOT BE MANDATORY UNLESS SUCH CANCELLATION BECOME NECESSARY ON THE GROUND(S) PRESCRIBED UNDER THE ACT. THUS, IT CAN BE SEEN THAT THE ASSESSEE IS CARRYING ON ACTIVITY FOR ADVANCEMENT OF ANY OTHER OBJECT OR GENERAL PUBLIC U TILITY, FALLING WITHIN THE DEFINITION OF CHARITABLE PURPOSE AS DE FINED U/S 2(15) OF THE ACT AND MAY BE ELIGIBLE FOR EXEMPTION U/S 2( 15) OF THE ACT, IN A YEAR WHERE IT DOES NOT CROSS THE CUT-OFF PERCE NTAGE AND MAY NOT BE ELIGIBLE FOR EXEMPTION IN THE YEAR, IN WHICH IT CROSSES THE CUT-OFF MARK. THEREFORE, IT CANNOT BE MADE TO SEEK REGISTRATION U/S 12AA OF THE ACT IN EACH OF THE YEAR WHERE IT SH ALL BECOME ELIGIBLE TO CLAIM EXEMPTION. THE HON'BLE HIGH COURT WAS CONSIDERING THE APPLICATION U/S 10(23)(C) OF THE AC T WHICH WOULD ULTIMATELY TAKE THE ASSESSEE OUT OF THE TAX AMBIT, UNLESS IT VIOLATES THE TERMS & CONDITIONS OF SUCH EXEMPTION. 7. THE CIT (E) IS SUPPOSED TO CONSIDER THE AIMS AND OBJECTS OF THE SOCIETY FOR GRANT OF REGISTRATION U/ S 12AA OF THE ACT. ITA NO 1021 OF 2016 TELANGANA STATE SEED CERTIFICATION AGENCY HYDERABAD. PAGE 8 OF 8 THE HON'BLE HIGH COURT HAS HELD THAT THE ASSESSEES ACTIVITIES FALLS UNDER THE ACTIVITY OF ADVANCEMENT OF ANY GENERAL PU BLIC UTILITY AND WE ARE OF THE OPINION THAT THE REGISTRATION U/S 12AA OF THE ACT SHOULD BE CONSIDERED ON ITS OWN MERITS. IF THE ASSESSEE IS CARRYING ON OR IS RENDERING ANY SERVICES WITH RESPE CT TO ANY TRADE, COMMERCE OR BUSINESS AND CROSSES THE THRESHOLD LIMI T PROVIDED U/S 2(15) OF THE ACT, THEN ITS INCOME SHALL NOT BE EXEMPT FROM TAX U/S 11 OF THE ACT IN THE RELEVANT A.Y. THEREFORE, W E DIRECT THE CIT (E) TO CONSIDER THE AIMS AND OBJECTS OF THE SOCIETY AND GRANT REGISTRATION U/S 12AA OF THE ACT IF THE ASSESSEES ACTIVITIES FALLS UNDER THE DEFINITION OF CHARITABLE PURPOSE U/S 2(15 ) OF THE ACT WITHOUT REFERENCE TO THE PROVISO THEREUNDER. THEREF ORE, ASSESSEES APPEAL IS TREATED AS ALLOWED FOR STATISTICAL PURPOS ES. 8. IN THE RESULT, ASSESSEES APPEAL IS TREATED AS A LLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 25 TH JANUARY, 2018. SD/- SD/- (S.RIFAUR RAHMAN) ACCOUNTANT MEMBER (P. MADHAVI DEVI) JUDICIAL MEMBER HYDERABAD, DATED 25 TH JANUARY, 2018. VINODAN/SPS COPY TO: 1 SHRI S. RAMA RAO, ADVOCATE, FLAT NO.102, SHRIYAS ELEGANCE, 3-6- 643, STREET NO.9, HIMAYATNAGAR, HYDERABAD 500029 2 COMMISSIONER OF INCOME TAX (EXEMPTIONS) POSHNET B HAVAN, RAMKOTI HYDERABAD 3 ITO (HQRS.)(EXEMPTIONS), O/O CIT HYDERABAD 4 ITO (EXEMPTIONS)WARD - 3 HYDERABAD 5 THE DR, ITAT HYDERABAD 6 GUARD FILE BY ORDER