Appeal Details
Counselvise Citation
[2016] 132 COUNSELVISE.COM (IT) 6656 (ITAT-HYDERABAD)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
1 year(s) 2 month(s) 9 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
07-04-2016
Appeal Filed By
Assessee
Order Result
Partly Allowed
Bench Allotted
A
Next Hearing Date
22-03-2015
Assessment Year
2010-2011
Appeal Filed On
29-01-2015
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES A : HYDERABAD BEFORE SHRI D. MANMOHAN, VICE PRESIDENT AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA.NO.103/HYD/2015 ASSESSMENT YEAR 2010-2011 C3I SUPPORT SERVICES P. LTD., HYDERABAD. PAN AACCC2082P VS. DCIT, CIRCLE - 1(2) HYDERABAD. (APPELLANT) (RESPONDENT) FOR ASSESSEE : MR. TARUN CHATURVEDI FOR REVENUE : SMT. PALLAVI AGARWAL DATE OF HEARING : 29 .03.2016 DATE OF PRONOUNCEMENT : 07 .0 4 .2016 ORDER PER D. MANMOHAN, V.P. THIS APPEAL BY THE ASSESSEE COMPANY IS DIRECTED AGAINST THE ORDER PASSED BY THE DCIT BASED ON THE DRP PROCEEDINGS AND THE ADJUSTMENTS PROPOSED BY THE TPO. 2. THE ASSESSEE COMPANY IS A WHOLLY OWNED SUBSIDIARY OF C3I INC., USA AND ENGAGED IN PROVIDIN G BUSINESS PROCESS OUTSOURCING SERVICES (BPO) IN THE FIELD OF HEALTHCARE ADMINISTRATION TO ITS A.E. IT IS REGIST ERED UNDER THE SOFTWARE TECHNOLOGY PARK OF INDIA SCHEME. FOR T HE YEAR UNDER CONSIDERATION, IT DECLARED NIL INCOME UNDER THE NORMAL PROVISIONS OF THE ACT AND ADMITTED 2 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. RS.1,74,90,433 UNDER SECTION 115JB OF THE ACT. THOU GH THE RETURN OF INCOME WAS PROCESSED ORIGINALLY UNDER SECTION 143(1) OF THE ACT IT WAS LATER ON TAKEN-UP FOR SCRUTINY WHEREIN IT WAS NOTICED THAT THE ASSESSEE E NTERED INTO INTERNATIONAL TRANSACTIONS AND THEREFORE, IT W AS REFERRED TO THE TPO, AFTER OBTAINING THE APPROVAL O F THE COMMISSIONER OF INCOME TAX. THE TPO DETERMINED THE ARMS LENGTH PRICE OF TRANSACTION, UNDER SECTION 92C A OF THE ACT, AT RS.25,33,73,111 AND DETERMINED THE SHOR T FALL OF RS.3,92,59,897 FOR THE PURPOSE OF MAKING ADJUSTM ENT UNDER SECTION 92CA(3) OF THE ACT. 3. WHILE SELECTING THE COMPARABLE COMPANIES THE TPO INCLUDED CERTAIN COMPANIES WHOSE OPERATING MARG INS ARE VERY HIGH ; THE TPO SOUGHT TO MAKE ADJUSTMENTS BY TAKING INTO CONSIDERATION THE FOLLOWING COMPARABLES . SL.NO. NAME OF THE COMPARABLE COMPANY OP/OC 1. ACCENTIA TECHNOLOGIES LTD., 43.62% 2. ECLERX SERVICE S LTD., 42.17% 3. INFOSYS BPO LTD., 31.63% 4. TCS ESERVE INTERNATIONAL LTD., 51.51% 5. TCS ESERVE LIMITED 67.58% 3.1. THE ASSESSEE FILED OBJECTIONS TO THE DRAFT ASSESSMENT ORDER AND THUS THE MATTER WAS CONSIDERED BY THE DISPUTES RESOLUTION PANEL. THE CASE OF THE ASSE SSEE WAS THAT THE TPO HAD REJECTED T.P. STUDY MADE BY TH E ASSESSEE AND CONDUCTED A NEW SEARCH FOR COMPARABLES AND SELECTED 11 COMPANIES AS COMPARABLES AFTER ANALYSING THE DATA BASE, ANNUAL REPORTS ETC., THE T PO 3 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. CHOSE TNMM AS THE MOST APPROPRIATE METHOD AND ARRIV ED AT ARMS LENGTH PRICE. 3.2. THE DRP OBSERVED THAT SOME OF THE COMPANIES ARE NOT COMPARABLE IN TERMS OF FUNCTIONS PERFORMED, ASSETS EMPLOYED AND RISKS ASSUMED (FAR). IT IS ALSO THE CONTENTION OF THE ASSESSEE THAT THE ASSESSEE OPERAT ES IN A RISK MITIGATED ENVIRONMENT AND HENCE THE PROFIT MAR GIN WOULD BE LESS. 4. HAVING REGARD TO THE OBJECTIONS AGAINST INCLUSION OF COMPANIES HAVING ABNORMAL TURNOVER AND PROFITS, THE DRP EXCLUDED INFOSYS BPO, (HAVING HIGH TURNOVER OF RS.1130 CRORES) AND ALSO TCS ESERVE LTD ., (WHICH HAS TURNOVER OF RS.1405 CRORES). THEY HOWEVE R DID NOT ACCEPT THE CONTENTION OF THE ASSESSEE THAT ACCE NTIA TECHNOLOGIES AND ECLERX SERVICES LTD., ARE NOT COMP ARABLE AS HELD BY THE ITAT IN ASSESSEES OWN CASE FOR THE A.YS. 2007-08 AND 2008-09. IN THIS REGARD, IT OBSERVED TH AT THE TRIBUNAL HAD NOTED THAT THERE ARE EXTRAORDINARY EVE NTS LIKE MERGER AND DEMERGER DURING THE RELEVANT FINANC IAL YEAR WHICH MIGHT HAVE AFFECTED THE FINANCIAL RESULT S OF THE COMPANY WHEREAS, IN THIS YEAR, THE ASSESSEE DID NOT BRING OUT ANY FACT TO SHOW THAT THERE ARE EXTRAORDINARY E VENTS IN THOSE COMPANIES. HENCE, THE SAID COMPANIES WERE NOT EXCLUDED. IN SHORT, WITH REGARD TO THREE COMPANIES I.E., ACCENTIA TECHNOLOGIES LTD., ECLERX SERVICES LTD., A ND TCS ESERVE INTERNATIONAL LTD., THE DRP REJECTED THE CON TENTION OF THE ASSESSEE AND UPHELD THE VIEW TAKEN BY THE TP O 4 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. THAT THE PROFITS EARNED BY THOSE COMPANIES CAN BE T AKEN AS COMPARABLES. 4.1. HAVING REGARD TO THE DIRECTIONS OF THE DRP TH E T.P. ADJUSTMENTS WERE MADE IN RESPECT OF THE INTERNATIONAL TRANSACTIONS. 5. AGGRIEVED, ASSESSEE PREFERRED AN APPEAL BEFORE THE TRIBUNAL. THE CASE OF THE ASSESSEE WAS THAT THE INTERNATIONAL TAXATION (EXPORT OF SERVICE) DOES N OT SATISFY THE ARMS LENGTH PRINCIPLE ENVISAGED UNDER THE I.T. ACT. IT WAS FURTHER CONTENDED THAT THE DIRECTIONS ISSUED BY THE DRP ARE NOT ADEQUATELY REASONED AND HENCE, UNSUSTAINABLE IN LAW. IT WAS ALSO CONTENDED THAT TH E ASSESSEE SELECTED UN-CONTROLLED COMPARABLE COMPANIE S BASED ON A DETAILED STUDY I.E., FUNCTIONS PERFORMED , ASSETS EMPLOYED AND RISK ANALYSIS (FAR ANALYSIS), FOLLOWIN G THE METHODICAL BENCHMARKING PROCESS AND ACCORDINGLY EXCLUDED CERTAIN COMPANIES HAVING DIMINISHING REVENUES/PERSISTENT LOSS AND ALSO THOSE COMPANIES W HICH ARE HAVING ABNORMAL MARGINS, MUCH VOLUME, PECULIAR ECONOMIC CIRCUMSTANCES ETC., IT WAS MAINLY CONTENDE D THAT THE ASSESSEE IS ENGAGED IN PROVIDING ITES TO I TS OVERSEAS AE AND IT HAD NO UNTOWARD MOTIVE OF DERIVI NG ANY TAX ADVANTAGE BY MANIPULATING ITS PRICE. 5.1. DURING THE COURSE OF HEARING, THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THOUGH SEVERAL GROU NDS WERE URGED BEFORE THE TRIBUNAL, THE ARGUMENTS ARE L IMITED TO TAKING INTO CONSIDERATION OF THREE COMPARABLES I .E., 5 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. ACCENTIA TECHNOLOGIES LTD., ECLERX SERVICES LTD., A ND TCS E-INTERNATIONAL LTD. HE ADVERTED OUR ATTENTION TO T HE ORDER PASSED BY THE ITAT IN ASSESSEES OWN CASE FOR THE E ARLIER YEARS. IT WAS SUBMITTED THAT THESE COMPARABLES WERE ALREADY CONSIDERED AND HAVING REGARD TO THE CIRCUMSTANCES OF THE CASE, THEY WERE HELD TO BE NOT COMPARABLE. HE ADVERTED OUR ATTENTION TO PAGES 150 OF THE PAPER BOOK (PARA-12.5 OF ITA.NO.2183/HYD/2011) TO HIGHLIGHT THAT FOR THE A.Y. 2007-08, THE ASSESSEE SUBMITTED THAT BESIDES BEING FUNCTIONALLY DIFFERENT FROM THE ASSESSEE, ECLERX SERVICES LTD., HAS SHOWN EXTRAORDINARILY HIGH PROFIT AND HENCE CANNOT BE TRE ATED AS COMPARABLE. IT WAS ALSO CONTENDED THAT THE ASSESSEE WAS A BPO WHEREAS ECLERX SERVICES LTD., WAS ENGAGED IN PROVIDING KNOWLEDGE PROCESS OUTSOURCING SERVICES (K PO) AND THUS IT WAS FUNCTIONALLY DIFFERENT FROM THE ASS ESSEE. THIS PLEA WAS ACCEPTED BY THE ITAT. 5.2. SIMILARLY, ACCENTIA TECHNOLOGIES LTD., CANNOT BE CONSIDERED AS COMPARABLE SINCE MORE THAN 64% OF THE OPERATING COST OF THE COMPANY IS TOWARDS OVERSEAS BUSINESS EXPENSES. FURTHER, THE COMPANY HAS SUBSTAN TIAL MARKETING EXPENSES AND THUS IT WAS FUNCTIONALLY DIF FERENT. THIS PLEA OF THE ASSESSEE WAS ALSO ACCEPTED BY THE ITAT VIDE ITS ORDER DATED 28 TH MAY, 2015. WHILE DEALING WITH THE APPEAL PERTAINING TO THE A.Y. 2008-09 (ITA.NO.1794/HYD/2012) THE ITAT OBSERVED THAT WITH REGARD TO ACCENTIA TECHNOLOGIES LTD., THERE WERE EXTRAORDINARY EVENTS APART FROM THE FACT THAT IT WA S 6 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. FUNCTIONALLY DIFFERENT ; ANNUAL REPORT OF THE SAID COMPANY SHOWS THAT IT PROVIDES HEALTHCARE RECEIVABLES, MANAGEMENT SERVICES, MEDICAL CODING, BILLING AND COLLECTIONS, DATA MIGRATION SERVICES AND ALSO ENGAG ED IN DEVELOPMENT OF SOFTWARE PRODUCTS AND SOFTWARE SERVI CES AND SOME INNOVATIVE PRODUCTS LIKE GSR AND MEDICAL TRANSCRIPTION AUTOMATION SYSTEM WHICH STREAMLINES W ORK FLOW FOR HOSPITALS. HOWEVER, THE ASSESSEE I.E., C3I SUPPORT SERVICES IS ENGAGED IN PROVIDING BPO SERVICES. SIMI LARLY, THE NATURE OF BUSINESS OF ECLERX SERVICES LTD., WAS ALSO HIGHLIGHTED AND THE BENCH OBSERVED THAT THE COMPANY OFFERS SOLUTIONS THAT INCLUDE DATA ANALYTICS, OPERA TIONS MANAGEMENT, AUDITS AND RECONCILIATION WHICH NEED TO BE CLASSIFIED AS HIGH END KPO WHEREAS THE ASSESSEE IS A BPO. IT WAS FURTHER OBSERVED THAT THERE ARE CERTAIN EXTRAORDINARY EVENTS AND PECULIAR CIRCUMSTANCES PREVAILING IN THE CASE OF THAT COMPANY SINCE THAT C OMPANY ACQUIRED UK BASED COMPANY WHICH HAS SIGNIFICANTLY CONTRIBUTED TO THE INCREASE OF THE CUSTOMER REVENUE BASE OF THE COMPANY. THUS, THE BENCH CONCLUDED THAT THE COMPANY CANNOT BE REGARDED AS COMPARABLE FOR THE REASON THAT IT WAS HAVING EXTRAORDINARY AND ABNORMA L PROFITS. AT THE SAME TIME, IT HAD ALSO TAKEN INTO CONSIDERATION THE FACT THAT THE SAID COMPANY WAS EN GAGED IN THE KPO SERVICES. 5.3. IN ADDITION THERETO, THE LD. COUNSEL FOR THE ASSESSEE PLACED BEFORE US A COPY OF THE ORDER OF TH E DRP FOR THE A.Y. 2011-2012 TO SUBMIT THAT IN THE SUBSEQ UENT 7 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. YEAR THE DRP EXCLUDED ACCENTIA TECHNOLOGIES LTD., E CLERX SERVICES LTD., ON THE GROUND THAT THEY ARE NOT FUNC TIONALLY SIMILAR TO THE SERVICES RENDERED BY THE ASSESSEE CO MPANY. 6. WITH REGARD TO TCS ESERVE INTERNATIONAL LTD., THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE EXTRAORDINARY PROFITS OF THE SAID COMPANY WERE ON A CCOUNT OF BRAND VALUE OF TATAS. LD. COUNSEL FOR THE ASSESS EE ADVERTED OUR ATTENTION TO PAGE 175 OF THE PAPER BOO K (PARA 14.7 IN ITA.NO.1794/HYD/2012) TO SUBMIT THAT WHILE DEALING WITH THE COMPARABLE I.E., INFOSYS BPO LTD., THE PLEA OF THE ASSESSEE WAS THAT THIS COMPANY HAS A HIGH BRAND VALUE AND THEREFORE, THERE WOULD BE SIGNIFICA NT INFLUENCE IN THE PRICING POLICY WHICH WILL IMPACT T HE MARGINS AND INFOSYS BPO BEING A SUBSIDIARY OF INFOS YS IT HAS AN ELEMENT OF BRAND VALUE ASSOCIATED WITH IT. PRESENCE OF BRAND COMMANDS PREMIUM PRICE AND THE CUSTOMERS WOULD BE WILLING TO PAY FOR THE SERVICES OF THE COMPANY. THIS PLEA WAS ACCEPTED BY THE TRIBUNAL BY OBSERVING THAT THE PRESENCE OF THE AFORESAID FACTOR S WILL TAKE INFOSYS BPO LTD., OUT OF THE LIST OF COMPARABL ES. DRAWING SUPPORT FROM THE RATIO LAID DOWN THEREIN, L D. COUNSEL FOR THE ASSESSEE SUBMITTED THAT EVEN IN THE CASE OF TCS ESERVE INTERNATIONAL LTD., THE BRAND VALUE P LAYS A KEY ROLE IN EARNING EXTRAORDINARY PROFITS AND HENCE , IT SHOULD NOT BE TAKEN INTO CONSIDERATION. IN THIS REG ARD, HE ADVERTED OUR ATTENTION TO PAGES 237 AND 238 OF PAPE R BOOK I.E., DIRECTORS REPORT OF TCS ESERVE INTERNAT IONAL LTD., WHEREIN IT WAS STATED THAT F.Y. 2009-10 IS TH E 8 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. SECOND YEAR OF OPERATIONS FOR THE COMPANY AND FIRST FULL YEAR AS A STEP DOWN SUBSIDIARY OF TCS. IT ALSO OBS ERVED THAT OPERATING INCOME IS HIGHER BY 173% OVER PREVIO US YEAR BECAUSE IT BECAME PART OF TCS WHICH HAS LARGE CLIENT BASE. LD. COUNSEL FOR THE ASSESSEE ALSO ADVERTED OU R ATTENTION TO PAGES 260 OF THE PAPER BOOK TO SUBMIT THAT TATA BRAND MAKES A SIGNIFICANT DIFFERENCE AND THERE FORE, ANY COMPANY WORKING WITH THAT BANNER HAS TO PAY EQU ITY CONTRIBUTION AND IN THIS CASE, ASSESSEE MADE PAYMEN T OF RS.3738 TOWARDS TATA BRAND EQUITY CONTRIBUTION. 6.1. IT WAS THUS CONTENDED THAT IN RESPECT OF THE COMPANIES WHICH ARE TAKEN AS COMPARABLES, THEY WERE EITHER FUNCTIONALLY DIFFERENT OR HIGHER PROFIT MARG IN WAS ON ACCOUNT OF ITS BRAND VALUE AND HENCE THEY SHOULD BE TAKEN OUT OF THE PURVIEW OF COMPARABLES. 7. ON THE OTHER HAND, LD. D.R. SUBMITTED THAT IN RESPECT OF ACCENTIA TECHNOLOGIES LTD., AND ECLERX S ERVICES LTD., THE DRP IN PARA 9.4.3 OBSERVED THAT THE EARLI ER ORDERS OF THE TRIBUNAL ARE DISTINGUISHABLE INASMUCH AS THE DECISION WAS RENDERED ON THE GROUND THAT THERE ARE EXTRAORDINARY CIRCUMSTANCES WHEREAS NOTHING WAS DON E IN THIS YEAR. THEREFORE, THE RATIO OF THE ORDERS OF TH E TRIBUNAL DO NOT APPLY IN THIS YEAR. AS REGARDS TCS ESERVE INTERNATIONAL LTD., THE LD. D.R. ADVERTED OUR ATTEN TION TO PAGE 40 OF THE TPO ORDER TO SUBMIT THAT THE TPO HAS GIVEN VALID REASONS WHILE TAKING INTO CONSIDERATION TCS ESERVE INTERNATIONAL PROFITS AS COMPARABLE AND THE 9 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. ASSESSEE DID NOT RAISE ANY OBJECTIONS BEFORE THE TP O AND THUS, HE SUPPORTED THE ORDER PASSED BY THE TPO/DRP. 8. JOINING THE ISSUE, LD. COUNSEL FOR THE ASSESSEE REFERRED TO PAGES 150 AND 173 OF THE PAPER BOOK TO SUBMIT THAT THE TRIBUNAL HAS EXCLUDED ECLERX SERVICES LTD. , MAINLY ON THE GROUND THAT IT IS FUNCTIONALLY DIFFER ENT BEING KPO WHEREAS THE ASSESSEE IS A BPO. SIMILARLY, HE RE FERRED TO PAGE 223 OF THE PAPER BOOK TO SUBMIT THAT IN THE CASE OF ACCENTIA TECHNOLOGIES LTD., ALSO THE ASSESSEE PERSISTENTLY CONTENDED THAT THE ASSESSEE IS AN END TO END BPO WHEREAS ACCENTIA TECHNOLOGIES LTD., IS INTO KPO AND THE COST PROFIT MATRIX OF BPO IS TOTALLY DISTINCT F ROM THE OTHER COMPARABLES. IN ADDITION THERETO, IT WAS SUBM ITTED THAT THERE WERE UNUSUAL ECONOMICAL ACTIVITIES WHICH WAS AN ADDITIONAL REASON TO SUPPORT ITS CLAIM THAT THE PROFITS OF ACCENTIA TECHNOLOGIES LTD., CANNOT BE TAKEN AS COMPARABLE. IN PARTICULAR, HE HAS REFERRED TO THE ORDER PASSED BY THE DRP IN THE SUBSEQUENT YEAR TO HIGHLIG HT THAT ON THE SAME SET OF FACTS THE DRP HAS EXCLUDED THE ABOVE TWO COMPANIES WHILE MAKING THE ADJUSTMENTS. 9. WE HAVE CAREFULLY CONSIDERED THE RIVAL CONTENTIONS AND PERUSED THE RECORD. AS RIGHTLY POIN TED OUT BY THE LD. COUNSEL FOR THE ASSESSEE, REGARDING ACCENTIA TECHNOLOGIES LTD., AND ECLERX SERVICES LT D., THE ACTIVITY OF THOSE COMPANIES ARE FUNCTIONALLY DIFFER ENT SINCE THEY ARE INTO KPO AND IN FACT THE DRP, WHILE CONSID ERING THE NATURE OF ACTIVITIES OF THOSE TWO COMPANIES, HA D 10 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. EXCLUDED THOSE TWO COMPANIES IN THE A.Y. 2011-2012. IN FACT THE TRIBUNAL HAD TAKEN NOTICE OF THE FACT THAT THE ASSESSEE BEING A BPO IT CANNOT BE COMPARED WITH A COMPANY WHICH WAS INTO KPO SERVICES. HAVING REGARD TO THE FACTS AND CIRCUMSTANCES OF THE CASE, WE ACCEPT THE CONTENTION OF THE ASSESSEE THAT THESE COMPANIES CAN NOT BE REGARDED AS COMPARABLES. 10. IN SO FAR AS TCS ESERVE INTERNATIONAL LTD., AS RIGHTLY POINTED OUT BY THE LD. COUNSEL FOR THE ASSE SSEE, THE SUDDEN TURN AROUND OF THE SAID COMPANY, BY EARN ING HIGH PROFIT MARGIN, WAS MAINLY ON ACCOUNT OF THE BR AND VALUE THAT TATA GROUP CARRIES. UNDER IDENTICAL CIRCUMSTANCES, WHILE CONSIDERING COMPARABLE CASE OF INFOSYS BPO, THE ITAT A BENCH, HYDERABAD IN THE ASSESSEES OWN CASE FOR THE A.Y. 2008-09 OBSERVED T HAT BRAND DEFINITELY COMMANDS PREMIUM PRICE AND THE CUSTOMER WOULD BE WILLING TO PAY FOR THE SERVICES O F A COMPANY WHICH HAS A BRAND IMAGE. THUS, IT WAS CONCLUDED THAT SUCH COMPANY CANNOT BE REGARDED AS A COMPARABLE COMPANY. IN THE INSTANT CASE ALSO CIRCUMSTANCES BEING IDENTICAL, WE ARE OF THE VIEW T HAT TCS ESERVE INTERNATIONAL LTD., CANNOT BE TREATED AS COMPARABLE HAVING REGARD TO THE BRAND VALUE IT COMMANDS. WE, THEREFORE, DIRECT THE A.O. TO EXCLUDE THE SAME AS COMPARABLE. 11. THE OTHER GROUNDS URGED BY THE ASSESSEE HAVING NOT PRESSED, WE DISMISS THOSE GROUNDS AND 11 ITA.NO.103/HYD/2015 C3I SUPPORT SERVICES P. LTD., HYDERABAD. ACCORDINGLY HOLD THAT THE APPEAL FILED BY THE ASSES SEE IS PARTLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 07.04.201 6. SD/- SD/- (S. RIFAUR RAHMAN) (D. MANMOHAN) ACCOUNTANT MEMBER VICE PRESIDENT HYDERABAD DATED 07 TH APRIL, 2016 VBP/- COPY TO 1. C3I SUPPORT SERVICES P. LTD., 2 ND FLOOR, ORION BLOCK, PLOT NO.17, VANENBURG IT PARK, SOFTWARE UNITS LAYOUT, MADHAPUR, HYDERABAD 500 081. 2. DY. COMMISSIONER OF INCOME TAX, CIRCLE - 1(2), HYDERABAD. 3. DISPUTES RESOLUTION PANEL, 2 ND FLOOR, I.T. TOWERS, 10 - 2-3, A.C. GUARDS, HYDERABAD 500 004. 4. CIT(A) - 1/MEMBER DRP, HYDERABAD. 5. CIT - IV/MEMBER DRP, HYDERABAD. 6 . DY. COMMISSIONER OF INCOME TAX, TRANSFER PRICING - II, HYDERABAD 4. 7 . THE DIRECTOR OF INCOME TAX, INTERNATIONAL TA XATION, I.T. TOWERS, 10-2-3, A.C. GUARDS, HYDERABAD-4. 8 . THE COMMISSIONER OF INCOME TAX - 1, HYDERABAD - 004. 9 . D.R. ITAT A BENCH, HYDERABAD. 10. GUARD FILE
