ITO, Ward-16(2), Hyd, Hyderabad V. Prasanthi Breeders Pvt.Ltd., Hyd, Hyderabad

ITA 1066/HYD/2015

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 98741 (ITAT-HYDERABAD)
• Duration Of Justice: 3 month(s) 1 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 19-11-2015
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 10-12-2015
• Assessment Year: 2006-2007
• Appeal Filed On: 17-08-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: B KURMI NAIDU
• Keywords: Reopening of assessment; Depreciation; Audit objection; Additional evidence
• Section: 43B; 143(3)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES B : HYDERABAD BEFORE SHRI D. MANMOHAN, VICE PRESIDENT AND SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER ITA.NO.1066 & 1067/HYD/2015 ASSESSMENT YEARS 2006-2007 & 2008-2009 THE INCOME TAX OFFICER, WARD 16(2), HYDERABAD. VS. M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD. PAN AABCP4280D (APPELLANT) (RESPONDENT) FOR REVENUE : MR. B. KURMI NAIDU FOR ASSESSEE : - NONE - DATE OF HEARING : 16.11.2015 DATE OF PRONOUNCEMENT : 16 .11.2015 ORDER PER D. MANMOHAN, V.P. THESE TWO APPEALS ARE FILED AT THE INSTANCE OF THE REVENUE AND THEY ARE DIRECTED AGAINST THE ORDER S PASSED BY THE LD. CIT(A)-IV, HYDERABAD. SINCE ISSUE S INVOLVED IN BOTH THESE APPEALS ARE IDENTICAL, WE P ROCEED TO DISPOSE OF THESE APPEALS BY A COMMON ORDER FOR T HE SAKE OF CONVENIENCE. 2. THE ASSESSEE IS A COMPANY ENGAGED IN THE BUSINESS OF POULTRY FARMING. IT FILED RETURN OF INC OME ADMITTING LOSS OF RS.21,94,068 AND RS.35,10,926 FOR THE A.YS. 2006-07 AND 2008-09 RESPECTIVELY. 2 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD 2.1. FOR THE A.Y. 2006-07 ASSESSMENT WAS ORIGINALLY COMPLETED UNDER SECTION 143(3) OF THE AC T BY DETERMINING TOTAL INCOME OF RS.17,770 BUT LATER ON REOPENED ON THE GROUND THAT THE ASSESSEE CLAIMED DEPRECIATION ON POULTRY SHEDS SAID TO HAVE BEEN TRANSFERRED FROM A GROUP COMPANY BY NAME M/S. PARAG ON TECHNICAL SOLUTIONS P. LTD., ( IN SHORT PTSPL) TH OUGH, AS PER THE BALANCE SHEET OF THE PTSPL, THERE IS NO OPE NING BALANCE OF THE POULTRY SHED, WHICH WAS SAID TO HAVE BEEN TRANSFERRED TO THE ASSESSEE COMPANY. THE ASSESSING OFFICER ALSO NOTICED THAT THE ASSESSEE CLAIMED TRAN SFER OF LOAN FROM PTSPL AND CLAIMED INTEREST ON THE LOAN TRANSFERRED, WITHOUT PROVING THAT PTSPL HAD NOT CLA IMED DEDUCTION TOWARDS INTEREST ON THE SAID LOAN. IN RES PONSE TO THE SAID NOTICE, THE ASSESSEE CONTENDED THAT THE ASSESSMENT WAS COMPLETED UNDER SECTION 143(3) OF TH E ACT AND THE ASSESSEE HAS DISCLOSED ALL THE FACTS AND TH US THE A.O. WAS NOT JUSTIFIED IN SEEKING TO DISALLOW THE C LAIM OF DEPRECIATION AND INTEREST ON LOAN. 2.2. REJECTING THE CONTENTION OF THE ASSESSEE, THE A.O. OBSERVED THAT IN THE ABSENCE OF OPENING BALANC E OF POULTRY SHEDS IN THE ASSETS SCHEDULE OF PTSPL FOR T HE YEAR ENDING 31.03.2006 THE CLAIM OF DEPRECIATION WOULD AMOUNT TO CLAIM ON NON-EXISTING ASSET AND ACCORDING LY, DISALLOWED A SUM OF RS.8,78,414. SIMILARLY, WITH RE GARD TO INTEREST, THE A.O. OBSERVED THAT ASSESSEE HAD NOT SUBMITTED ANY EVIDENCE WITH REGARD TO TRANSFER OF L OAN 3 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD AND THEREFORE, CONCLUDED THAT THE CLAIM OF EXPENDIT URE ON ACCOUNT OF INTEREST IS NOT TENABLE. 3. SIMILARLY FOR THE A.Y. 2008-09, THE A.O. CALLED FOR THE BOOKS OF ACCOUNT AND OTHER DETAILS DURING T HE COURSE OF REGULAR ASSESSMENT PROCEEDINGS. THOUGH TH E ASSESSEES COUNSEL MR. PRABHAKAR, FCA APPEARED AND FURNISHED BOOKS OF ACCOUNT AND OTHER DETAILS CALLED FOR, HE WAS NOT CONVINCED WITH THE EXPLANATION. HE OBSERVED THAT AS PER COLUMN NO.21 OF THE AUDITORS REPORT, INTERE ST ON CASH CREDIT, AMOUNTING TO RS.31,29,346, WAS NOT PAI D BY THE DUE DATE. ACCORDING TO HIM, SECTION 43B COMES I NTO PLAY IN THE EVENT OF NON-PAYMENT OF INTEREST BY THE DUE DATE. ACCORDINGLY, HE DISALLOWED THE SAME. 3.1. AGGRIEVED BY THE ORDERS PASSED BY THE A.O., ASSESSEE PREFERRED APPEALS BEFORE THE CIT(A). IN RE SPECT OF A.Y. 2006-07, IT WAS CONTENDED THAT REOPENING OF ASSESSMENT, BASED ON AUDIT OBJECTION, IS NOT VALID IN LAW SINCE THE ASSESSEE FURNISHED ALL THE DETAILS BEFORE THE A.O. DURING THE COURSE OF REGULAR ASSESSMENT PROCEEDINGS . EVEN ON MERITS, IT WAS CONTENDED THAT DISALLOWANCE REFERABLE TO DEPRECIATION OF RS.8,78,414 AND INTERE ST ON LOAN OF RS.5,41,562 IS NOT IN ACCORDANCE WITH LAW. 3.2. THE LD. CIT(A) OBSERVED THAT ASSESSMENT WAS REOPENED BY THE A.O. ON THE BASIS OF THE REASONS RE CORDED AND HENCE, HE CONCLUDED THAT THE RE-ASSESSMENT PROCEEDINGS ARE IN ACCORDANCE WITH LAW. AS REGARDS THE DISALLOWANCE MADE BY THE A.O., THE CASE OF THE ASSE SSEE 4 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD WAS THAT THE ASSETS WERE EXISTING IN THE BALANCE SH EET AS OPENING BALANCE IN THE BOOKS OF PTSPL AS PART OF C APITAL- WORK-IN-PROGRESS WHICH HAS BEEN TRANSFERRED BY THE ASSESSEE DURING THE YEAR WHEREAS, THE A.O. WAS WRON GLY OF THE OPINION THAT THERE WAS NO ASSET IN EXISTENCE. W ITH REGARD TO THE INTEREST ON LOAN TRANSFERRED FROM SIS TER CONCERN, THE CASE OF THE A.O. WAS THAT THE ASSESSEE HAD NOT DEMONSTRATED TRANSFER OF LOAN FROM SISTER CONCE RN WHEREAS THE AUDITED ACCOUNTS OF PTSPL AND THAT OF T HE ASSESSEE CLEARLY DEPICTS THAT THE LOAN IS TRANSFERR ED AND THE SAME IS DULY MENTIONED. IT WAS THEREFORE SUBMIT TED THAT THE DISALLOWANCE MADE BY THE A.O. IS NOT IN ACCORDANCE WITH LAW. 3.3. THE LD. CIT(A) VERIFIED THE FACTUA L POSITION FROM THE RECORD AND FOUND THAT THE POULTRY SHED WAS SHOWN AS CAPITAL-WORK-IN-PROGRESS WHICH WAS TRANSFERRED TO THE ASSESSEE AND THUS ALLOWED THE CL AIM OF DEPRECIATION ON THE VALUE OF THE POULTRY SHEDS. SIM ILARLY, HE ALSO NOTICED FROM THE AUDITED ACCOUNTS THAT THE LOAN IN THE BOOKS OF PTSPL WAS TRANSFERRED TO THE ASSESSEE AND HENCE, INTEREST WAS RIGHTLY CLAIMED AS DEDUCTION BY THE ASSESSEE. HE ACCORDINGLY, ACCEPTED THE PLEA OF THE ASSESSEE ON BOTH THE ISSUES ON MERITS. 4. AGGRIEVED, REVENUE CONTENDS BEFORE US THAT THE LD. CIT(A) ERRED IN ADMITTING ADDITIONAL EVIDEN CE FILED BY THE ASSESSEE IN COMPLETE DISREGARD TO THE PROVIS IONS OF RULE 46A OF THE I.T. RULES. IT WAS ALSO CONTENDED T HAT THE 5 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD TRANSFEREE COMPANY CLAIMED DEPRECIATION OF RS.7,79, 592 ON THE POULTRY SHEDS @ 10% OF THE COST OF RS.7,95,9 18 IN A.Y. 2006-07 AND THEREFORE, DEPRECIATION ON THE SAM E ASSETS CANNOT BE CLAIMED IN THE HANDS OF THE TRANSF EREE COMPANY. IT WAS ALSO CONTENDED THAT THE ASSESSEE CL AIMED DEPRECIATION OF RS.8,78,414 AND HENCE, THE DIFFEREN CE BETWEEN RS.7,79,592 AND RS.8,78,414 WAS NOT EXPLAIN ED. SIMILARLY, WITH REGARD TO INTEREST ON LOAN TRANSFER RED, THE CASE OF THE REVENUE IS THAT THE LD. CIT(A) HAS NOT GIVEN DETAILS OF THE INTEREST PAID BY THE TRANSFEROR TILL THE DATE OF TRANSFER OF THE LOAN TO THE ASSESSEE COMPANY. 5. AT THE TIME OF HEARING, LD. D.R. STRONGLY RELIE D UPON THE GROUNDS URGED BEFORE US AND SUBMITTED THAT ASSESSEE HAS WRONGLY CLAIMED DEPRECIATION AND ALSO THE INTEREST ON LOAN TRANSFERRED AND ALSO SUBMITTED THA T THE LD. CIT(A) ERRED IN ADMITTING ADDITIONAL EVIDENCE. WHEN CALLED UPON TO FURNISH DETAILS AS TO WHAT WAS THE ADDITIONAL EVIDENCE THAT WAS FILED BEFORE THE LD. C IT(A), THE LD. D.R. FAIRLY ADMITTED THAT THE BALANCE SHEET ETC., WERE ALSO FILED BEFORE THE A.O. AS COULD BE NOTICED FROM THE ASSESSMENT ORDER. IN FACT IN THE ORDER PASSED B Y THE LD. CIT(A), NOWHERE IT IS SPECIFIED THAT THE ASSESS EE REQUESTED FOR ADMISSION OF ADDITIONAL EVIDENCE OR T HE FIRST APPELLATE AUTHORITY THOUGHT FIT TO SUO MOTU ADMIT ADDITIONAL EVIDENCE; ON THE CONTRARY, THE DECISION WAS RENDERED PURELY ON THE FACTS AVAILABLE ON RECORD. THEREFORE, IN THE ABSENCE OF FURNISHING ANY EVIDENC E TO SUPPORT THE CONTENTION OF THE REVENUE, WE ARE OF TH E VIEW 6 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD THAT THE APPELLANT/A.O. HAS ROUTINELY RAISED A GROU ND WITHOUT ANY VALID BASIS. GROUND NO.2 IN FACT READS AS UNDER : 2. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CASE, LD. CIT(A) ERRED IN ADMITTING ADDITIONAL EVIDENCE FILED BY THE ASSESSEE IN COMPLETE DISREGARD TO THE PROVISIONS OF RULE 46A OF THE I.T. RULES, 1962. 2.1. THE LD. CIT(A) HAS ERRED IN ADMITTING THE ADDITIONAL EVIDENCE WITHOUT RECORDING ANY REASONS ABOUT THE SUFFICIENCY OF CAUSE WITH THE ASSESSEE FROM PROVIDING THE EVIDENCE BEFORE THE ASSESSING OFFICER. 2.2. THE LD. CIT(A) HAS ERRED IN ADMITTING THE ADDITIONAL EVIDENCE AND BASING HIS DECISION THEREUPON WITHOUT AFFORDING ANY OPPORTUNITY TO THE A.O. TO EXAMINE THE SAME IN CONTRAVENTION TO THE PROVISIONS OF RULE 46A(3) OF THE I.T. RULES, 1962. 5.1. SINCE NO EVIDENCE WAS FILED TO SUBSTANTIATE T HE CONTENTION OF THE REVENUE, WE REJECT GROUND NO.2 OF THE REVENUE. 6. SIMILARLY, VIDE GROUND NO.3, THE REVENUE CONTENDS THAT THE LD. CIT(A) ERRED IN ACCEPTING THE CLAIM OF DEPRECIATION. HOWEVER, CAREFUL PERUSAL OF THE ASSESSMENT ORDER INDICATES THAT THE A.O. OVERLOOKED THE FACT THAT THE VALUE OF THE POULTRY SHED WAS SHOWN U NDER THE HEAD CAPITAL-WORK-IN-PROGRESS AND ASSUMED THA T DEPRECIATION WAS CLAIMED ON NON-EXISTING ASSET. LD. CIT(A) HAVING VERIFIED THE BALANCE SHEET OBSERVED THAT THE CLAIM OF DEPRECIATION IS IN ACCORDANCE WITH LAW SINCE THE 7 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD ASSESSEE IS ENTITLED TO CLAIM DEPRECIATION ON THE V ALUE OF POULTRY SHEDS. FOR THE FIRST TIME, BEFORE THE TRIBU NAL, THE REVENUE SUBMITS THAT COST OF POULTRY SHEDS WAS RS.77,95,918 AND 10% OF THE SAME WAS CLAIMED AS DEDUCTION IN A.Y. 2006-07 WHICH, IN ITSELF, CONTRAD ICTS THE STAND TAKEN IN THE ASSESSMENT ORDER. IT WAS ALSO CL AIMED IN GROUND NO.3 THAT AT BEST ASSESSEE CAN CLAIM DEPRECIATION OF RS.7,79,512 BEING 10% OF THE TOTAL VALUE OF POULTRY SHEDS I.E., RS.77,95,978 WHEREAS, NO MATERI AL WAS PLACED EVEN AT THIS STAGE BY THE REVENUE TO SHOW AS TO FROM WHICH MATERIAL PAPER THIS FIGURE IS WORKED OUT . 6.1. AS CAN BE NOTICED FROM THE ORDER PASSED BY TH E LD. CIT(A), HE CATEGORICALLY OBSERVED THAT IN THE B ALANCE SHEET OF PTSPL THE VALUE OF POULTRY SHEDS WERE SHOW N AT RS.1,78,68,284 AND IT WAS ALSO REFLECTED AS CAPITAL -WORK- IN-PROGRESS. FINDING OF A SUPERIOR AUTHORITY TAKES PRECEDENCE OVER THE VIEW TAKEN BY THE A.O. UNLESS OTHERWISE REBUTTED BY THE APPELLANT BY ADDUCING SUF FICIENT EVIDENCE. IN THE INSTANT CASE, THOUGH THE REVENUE PREFERRED APPEAL, NO MATERIAL WHATSOEVER WAS FURNIS HED TO SUBSTANTIATE ITS GROUNDS. UNDER THESE CIRCUMSTANCES , WE REJECT GROUND NO.3 OF THE REVENUE. 7. VIDE GROUND NO.4, THE APPELLANT CONTENDS THAT THE LD. CIT(A) ERRED IN DELETING THE DISALLOWANCE O F INTEREST ON LOAN TRANSFERRED BY THE TRANSFEREE. AS CAN BE NOTICED FROM THE ASSESSMENT ORDER, THE A.O. OBSERVE D THAT THE CLAIM OF DEDUCTION TOWARDS INTEREST WAS NOT TEN ABLE 8 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD ON ACCOUNT OF THE FACT THAT THE ASSESSEE HAS NOT SUBMITTED ANY EVIDENCE WITH REGARD TO TRANSFER OF L OAN FROM PTSPL WHEREAS THE LD. CIT(A) VERIFIED THE MATE RIAL ON RECORD TO NOTICE THAT AN AMOUNT OF RS.1,01,72,11 5 IS SHOWN AS BALANCE IN INDIAN OVERSEAS BANK AS TERM LO AN TAKEN BY PTSPL WHICH WAS TRANSFERRED TO THE ASSESSE E COMPANY WHICH IS EVIDENT FROM THE FACT THAT THE ACC OUNT HAS BECOME NIL FOR THE YEAR ENDING 31.03.2006 IN TH E NAME OF PTSPL BY TRANSFER OF LOAN IN THE NAME OF TH E ASSESSEE COMPANY. HAVING REGARD TO THE CIRCUMSTANCE S OF THE CASE, THE LD. CIT(A) OBSERVED THAT THE ASSESSEE IS ENTITLED TO DEDUCTION TOWARDS INTEREST. 7.1. THOUGH THE REVENUE CONTENDS BEFORE US THAT THE LD. CIT(A) DELETED DISALLOWANCE OF INTEREST WIT HOUT VERIFYING THE CLAIM OF INTEREST PAYMENTS BY THE TR ANSFEROR, TILL THE DATE OF TRANSFER OF LOAN TO THE ASSESSEE C OMPANY, NO MATERIAL WHATSOEVER WAS PLACED ON RECORD TO SHOW THAT THE LD. CIT(A) HAS NOT VERIFIED FACTUAL MATRIX I.E. , TERM LOAN ACCOUNT OF INDIAN OVERSEAS BANK. IN THE ABSENC E OF ANY EVIDENCE PLACED ON RECORD, WE ARE UNABLE TO APPRECIATE THE STAND OF THE REVENUE. WE, THEREFORE, AFFIRM THE ORDER OF THE LD. CIT(A) AND REJECT GROUND NO.4 OF THE REVENUE. 8. IN RESPECT OF A.Y. 2008-09 ALSO THE MAIN CONTENTION OF THE REVENUE IS THAT THE LD. CIT(A) ER RED IN ADMITTING ADDITIONAL EVIDENCE IN COMPLETE DISREGARD TO THE PROVISIONS OF RULE-46A OF THE I.T. RULES. WHEN POIN TED OUT 9 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD THAT THERE IS NO MENTION IN THE ORDER PASSED BY THE LD. CIT(A) WITH REGARD TO ADMISSION OF ADDITIONAL EVIDE NCE, LD. D.R. WAS UNABLE TO PLACE ANY MATERIAL ON RECORD TO SUPPORT THE STAND TAKEN BY THE REVENUE. UNDER THESE CIRCUMSTANCES, WE REJECT GROUND NO.2 OF THE REVENUE . VIDE GROUND NO.3 THE REVENUE CONTENDS THAT TDS PARTICULARS CREDITED IN FEBRUARY WERE NOT PLACED BE FORE THE A.O. BUT PLACED ONLY BEFORE THE LD. CIT(A) AND THUS THE LD. CIT(A) ADMITTED ADDITIONAL EVIDENCE WHEREAS THE LD. CIT(A) NOWHERE INDICATED THAT THESE FACTS WERE FILED FOR THE FIRST TIME BEFORE HIM. RATHER, THE LD. CIT(A) O BSERVED THAT TDS WAS REMITTED DURING THE YEAR, BASED ON THE DETAILS PLACED ON RECORD. IN THE ABSENCE OF FURNISH ING OF ANY MATERIAL BEFORE US TO CONTRADICT THE FINDINGS O F THE LD. CIT(A), WE ARE UNABLE TO ACCEPT THE PLEA OF THE REV ENUE AND THEREFORE, GROUND NO.3 IS HEREBY REJECTED. 9. VIDE GROUND NO.4 (A.Y. 2008-09) THE REVENUE CONTENDS THAT THE INTEREST DISALLOWANCE UNDER SECTI ON 43B WAS WRONGLY SET ASIDE BY THE LD. CIT(A) WITHOUT GIV ING A DETAILED ACCOUNT OF FACTUAL SUBMISSIONS. IT WAS ALS O CONTENDED THAT THE LD. CIT(A) DID NOT EXAMINE THE B ALANCE SHEET WHERE THE LIABILITY ON ACCOUNT OF CASH CREDIT HAS INCREASED FROM (-) RS.1,13,34,510 TO (-) RS.1,34,29 ,766 ESTABLISHING THAT ANY REPAYMENT HAS BEEN AGAINST OUTSTANDING OD ACCOUNT AND NOT INTEREST PAYABLE BY THE ASSESSEE. THE LD. CIT(A), IN PARA-4(II) OF HIS ORDE R, OBSERVED AS UNDER : 10 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD (II) REGARDING THE DISALLOWANCE OF INTEREST U/S.43B, IT IS SEEN THAT THE LOAN ACCOUNT IS CASH CREDIT ACCOUNT AND THE DEBITS AUTOMATICALLY ARE ADJUSTED AGAINST THE DRAWING POWER IN THE CASH CREDIT ACCOUNT. THE A.O. DISALLOWED THE INTEREST U/S.43B HOLDING THAT THE APPELLANT HAS NOT DEMONSTRATED HOW THE REPAYMENTS MADE ARE TOWARDS INTEREST. THE OPERATION OF CASH CREDIT ACCOUNT IS SUCH THAT THE DEBITS OF INTEREST GET ADJUSTED AGAINST DRAWING LIMIT SANCTIONED TO THE APPELLANT. FROM THE COPY OF THE CASH CREDIT ACCOUNT COPY, IT IS SEEN THAT THERE ARE REGULAR TRANSACTION IN THE ACCOUNT AND APPLYING THE PRINCIPLE OF FIRST IN FIRST OUT WITH REFERENCE T O THE DEBITS IN THE ACCOUNT, THE INTEREST STANDS PAID. IN VIEW OF THE ABOVE, THE DISALLOWANCE MADE U/S.43B IS DELETED. 10. HERE ALSO NO MATERIAL WHATSOEVER WAS PLACED BEFORE US TO CONTRADICT THE FINDINGS OF THE LD. CIT (A). UNDER THESE CIRCUMSTANCES, WE HAVE NO ALTERNATIVE E XCEPT TO AFFIRM THE ACTION OF THE LD. CIT(A). ACCORDINGLY WE DISMISS THE PLEA RAISED BY THE REVENUE. THUS GROUND NO.4 OF THE REVENUE IS HEREBY REJECTED. 11. IN THE RESULT, APPEALS FILED BY THE REVENUE FO R BOTH THE ASSESSMENT YEARS ARE DISMISSED AS PRONOUNC ED IN THE OPEN COURT ON 16 TH NOVEMBER, 2015. SD/- SD/- (B. RAMAKOTAIAH) (D.MANMOHAN) ACCOUNTANT MEMBER VICE PRESIDNET HYDERABAD, DATED 16 TH NOVEMBER, 2015 VBP/- 11 ITA.NOS.1066 & 1067/HYD/2015 M/S. PRASANTHI BREEDERS P. LTD., HYDERABAD COPY TO 1. THE INCOME TAX OFFICER, WARD 16(2), ROOM NO.5, BLOCK-B, 7 TH FLOOR, AAYAKAR BHAVAN, BASHEERBAGH, HYDERABAD 500 004. 2 . M/S. PRASANTHI BREEDERS P. LTD., PLOT NO.4 - 2/1, BLOCK A, H.NO.2-99/8, STREET NO.2, KAKATIYANAGAR, HABSIGUDA, HYDERABAD. 3 . C OMMISSIONER OF I NCOME T AX (A) - 4 , 3 RD FLOOR ANNEXE, AAYAKAR BHAVAN, BASHEERBAGH, HYDERABAD - 004. 4 . CIT - IV, HYDERABAD 5 . D.R. ITAT B BENCH, HYDERABAD 6 . GUARD FILE