ITO, Ward-7(1), Hyderabad V. Shri L.R.Bhuvaneshwara Reddy, Hyderabad

ITA 1086/HYD/2013

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 77994 (ITAT-HYDERABAD)
• Duration Of Justice: 11 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-07-2014
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2009-2010
• Appeal Filed On: 22-07-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: D VIJAYA KUMAR; G PURUSHOTHAM
• Keywords: Unexplained cash credit; Additional evidence
• Section: 68

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES B : HYDERABAD BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER AND SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER ITA.NO.1086/HYD/2013 ASSESSMENT YEAR 2009-10 INCOME TAX OFFICER WARD 7 (1) HYDERABAD. VS. SHRI L.R. BHUVANESHWARA REDDY, HYDERABAD PAN ACOPL-0621-Q (APPELLANT) (RESPONDENT) FOR REVENUE MR. SOLGY JOSE T. KOTTARAM FOR ASSESSEE MR. D. VIJAYA KUMAR & MR. G. PURUSHOTHAM DATE OF HEARING 03.07.2014 DATE OF PRONOUNCEMENT 09.07.2014 ORDER PER B. RAMAKOTAIAH, A.M. THIS APPEAL BY REVENUE IS DIRECTED AGAINST THE ORDERS OF THE CIT(A)-VI, HYDERABAD DATED 18.04.2013 . THE ISSUE IN THIS APPEAL IS WITH REFERENCE TO DELETION OF ADDITIONS MADE BY THE A.O. PARTLY. REVENUE RAISED THE GROUND CONTESTING AN AMOUNT OF RS.20,11,100/- WHEREAS, LD. CIT(A) GAV E RELIEF OF RS.26,02,100/-. IT IS NOT SURE WHICH OF THE AMOUNTS GIVEN RELIEF BY THE LD. CIT(A) ARE CONTESTED AND LEARNED D.R. FA IRLY ADMITTED THAT THERE SEEMS TO BE MISTAKE IN TAKING T HE AMOUNT WHICH WAS CONTESTED. LEARNED D.R. ALSO PLACED ON RE CORD THREE REMAND REPORTS SENT IN THE COURSE OF APPELLANT PROC EEDINGS TO THE LD. CIT(A). 2 ITA.NO.1086/HYD/2013 MR. L.R. BHUVANESHWARA REDDY, HYDERABAD. 2. BRIEFLY STATED, ASSESSEE IS AN INDIVIDUAL AND F ILED RETURN OF INCOME SHOWING CONSULTANCY RECEIPTS ADMIT TING TOTAL INCOME OF RS.2,94,080/-. A.O. WAS IN RECEIPT OF AIR DATA WHEREIN CASH DEPOSITS AGGREGATING TO RS.14,29,400/- APPEARING IN HDFC BANK WERE RECEIVED. CONSEQUENT TO THAT ASSESSEE WAS ASKED TO EXPLAIN THE AMOUNTS DEPOSITED IN THE BANK ACCOUNT. AFTER CONSIDERING THE EXPLANATION OF THE ASSESSEE, A.O. HAS MADE AN ADDITION OF RS.13,18,400 /-, RS.12,45,000/- STATED TO HAVE RECEIVED FROM THREE P ERSONS AND RS.73,500/- AS CASH DEPOSITS UNDER SECTION 68 OF TH E ACT. 3. IN THE COURSE OF ASSESSMENT PROCEEDINGS, ASSESSEES ACCOUNT WITH ICICI BANK WAS ALSO CALLED FOR AND EXAMINED AND A.O. NOTICED THAT THERE ARE TRANSFERS/ CREDITS IN THE ACCOUNT TO AN EXTENT OF RS.13,83,700/-. THESE A MOUNTS ARE ALSO TREATED AS UNEXPLAINED CREDITS AND TOTAL OF RS .27,02,100/- WAS BROUGHT TO TAX AS UNEXPLAINED CASH CREDITS. 4. IT WAS CONTENDED BEFORE THE LD. CIT(A) THAT ASSESSEE HAS FURNISHED VARIOUS DETAILS BEFORE THE A .O. BUT THEY WERE NOT ACCEPTED AND FURTHER ADDITIONAL EVIDENCE W AS ALSO FILED EXPLAINING VARIOUS DEPOSITS IN THE BANK ACCOU NT. LD. CIT(A) SENT THE MATTER ON REMAND AND A.OS (TWO DIF FERENT OFFICERS) SUBMITTED REPORTS VIDE LETTER DATED 12.11 .2012, WHICH WAS FORWARDED BY THE ADDL. COMMISSIONER ON 15.11.20 12 AND FURTHER REPORT ON 25.02.2013. CONSIDERING THE REMAN D REPORTS BY THE A.O. AND EXPLANATION BY THE ASSESSEE, LD. CI T(A) GAVE RELIEF IN PARA 5.5 OF THE ORDER AS UNDER : 5.5 I HAVE GONE THROUGH THE OBSERVATIONS OF THE ASSESSING OFFICER AND THE SUBMISSIONS OF THE APPELL ANT. AS COULD BE SEEN FROM THE FACTS OF THE CASE, THE ASSESSING OFFICER HAS EXAMINED THE SOURCES OF CASH DEPOSITS OF RS.14,29,400/- MADE IN TO HDFC ACCOUNT OF 3 ITA.NO.1086/HYD/2013 MR. L.R. BHUVANESHWARA REDDY, HYDERABAD. THE APPELLANT, OUT OF WHICH RS.1,49,490/- REPRESENT ED THE CONSULTANCY CHARGES TO THE APPELLANT AND AS SUC H THE SAME WERE ACCEPTED AS EXPLAINED, BY THE ASSESSI NG OFFICER IN THE ASSESSMENT ORDER. REGARDING THE BALA NCE OF AMOUNTS OF RS.12,45,000/-, THE REMAND REPORT OF THE ASSESSING OFFICER WAS DEALING WITH THE SUBJECT MATT ER. AS PER THE SAME THE AMOUNTS OF RS. 5,00,000 REPRESENTED THE CASH DEPOSITED BY THE APPELLANT'S F ATHER MR. RAMA CHENNA REDDY, IN THE BANK ACCOUNT OF THE APPELLANT AT CHENNIA, AND THE EXPLANATION OFFERED B Y THE APPELLANT IS ACCEPTABLE TO THE ASSESSING OFFICER AN D NO ADVERSE COMMENTS WERE MADE. SIMILARLY, RS. 6,45,000 /- REPRESENT THE LOANS OBTAINED FROM MR. N.H. BHASKAR REDDY, THE BROTHER-IN-LAW OF THE APPELLANT, WHO IS ASSESSED TO TAX AT BANGALORE AND THE CONFIRMATIONS FURNISHED BY THE APPELLANT IN THIS REGARD APPEARS T O BE ACCEPTABLE TO THE ASSESSING OFFICER, AS PER THE REM AND REPORT AND NO ADVERSE COMMENTS ARE MADE IN THIS REGARD. IT IS PERTINENT TO MENTION THAT, THE IDENTI TY OF THE CREDITORS, GENUINENESS OF THE TRANSACTIONS ARE EXPL AINED, AS SUCH THE SAID AMOUNTS ARE NOT TREATED AS UNEXPLAINED CREDITS. REGARDING THE LOAN OF RS. 1,00 ,000 (RS. 50,000 + RS. 50,000) SHOWN TO HAVE OBTAINED FROM MR. BHARAT KUMAR, THE CONFIRMATION LETTER WAS SHOWN TO HAVE BEEN EXAMINED BY THE ASSESSING OFFICER IN REMA ND PROCEEDINGS, AS PER WHICH THE LOAN WAS CONFIRMED, WHICH WAS SHOWN TO HAVE BE EN GIVEN OUT OF HIS AGRICULTURAL INCOME, FOR WHICH NO EVIDENCE WAS FURN ISHED. THE OTHER FACT REMAINS THAT MR. BHARAT KUMAR IS NOT A FAMILY MEMBER, A PRIVATE EMPLOYEE, NOT ASSESSED TO TAX, PRESUMABLY HAVING A BANK ACCOUNT, BUT HAS CHOSEN TO LEND THE MONEY BY CASH. FURTHER, THE DATE AND MODE OF REPAYMENT OF LOAN ETC. WERE NOT CLEARLY EXPLAINED. UNDER THE CIRCUMSTANCES, IT MAY BE REASONABLE TO HOLD THA T THE CLAIMED LOAN REPRESENT THE UNEXPLAINED CREDIT, IN T HE HANDS OF THE APPELLANT. REGARDING THE AMOUNT OF RS.73,400/- WHICH REPRESENTED THE CASH DEPOSITS INT O HDFC BANK, IT MAY BE RELEVANT TO OBSERVE THAT THE S AID AMOUNTS WERE DEPOSITED IN SCATTERED MANNER I.E. RS.20,000 ON 12.2.2009, RS.4400 ON 6.3.2009, RS.14,000 ON 23.3.2009 AND RS.35,000 ON 25.3.2009 AND THE SAID AMOUNTS ARE SHOWN TO BE DEPOSITS OUT O F PERSONAL FUNDS WHICH ARE EXPLAINABLE THROUGH ACCOUN TS. THE ASSESSING OFFICER HAS MADE THE ADDITIONS, WITHO UT OFFERING ANY SPECIFIC REMARKS ABOUT EACH OF SUCH EN TRY AND NOT WITHSTANDING THE FACT THAT THERE ARE REGULA R 4 ITA.NO.1086/HYD/2013 MR. L.R. BHUVANESHWARA REDDY, HYDERABAD. WITHDRAWALS FROM THE SAID ACCOUNT AT REGULAR INTERV ALS. UNDER THE CIRCUMSTANCES, I AM OF THE OPINION THAT T HERE IS NO BASIS FOR THE ASSESSING OFFICER TO COME TO THE CONCLUSION THAT THE EXPLANATION OF THE ASSESSEE ARE BEREFT OF ANY MERIT. ACCORDINGLY, OUT OF THE TOTAL ADDITION OF RS. 13,18,400/- MADE UNDER THE HEAD 'UNEXPLAINED CREDITS FOR LOAN CREDITS', AN AMOUNT OF RS. 12,18,400/- STAND EXPLAINED WITH A BALANCE OF RS. 1,00,000/- BEING THE LOANS IN THE NAME OF MR. BHARAT KUMAR REMAIN TO BE UNEXPLAINED. ACCORDINGLY, THIS GROUND OF APPEAL IS PARTLY ALLOWED, WITH THE ADDITION OF RS. 12,18,400/- HELD TO BE UNSUSTAINABLE AND RS. 1,00,000/- STAND CONFIRMED. 5. WITH REFERENCE TO UNEXPLAINED CREDITS IN ICICI BANK, ORDER IN PARA 6.6 IS AS UNDER : 6.6. I HAVE GONE THROUGH THE OBSERVATIONS OF THE ASSESSING OFFICER IN THE ASSESSMENT ORDER AS WELL A S THE REMAND REPORT, ALONG WITH THE SUBMISSIONS OF THE APPELLANT. AT THE OUTSET, THE ADDITION OF RS. 13,83 ,700/- RELATED TO THE FUNDS TRANSFERRED THROUGH BANKING CH ANNEL TO THE TWO BANK ACCOUNTS MAINTAINED BY THE APPELLAN T WITH HDFC BANK AND ICICI BANK. AN AMOUNT OF RS. 4,41,000/- REPRESENT THE CREDITS INTO HDFC BANK AND RS.9,42,700/- REPRESENT CREDITS INTO ICICI BANK. AS REGARD TO THE CREDITS IN HDFC BANK, THE AO HAS ACCE PTED THE EXPLANATION OF THE APPELLANT FOR RS. 2,50,000/- , BEING THE TRANSFER FROM ICICI BANK ACCOUNT. REGARDING RS.50,000/ - WHICH IS A CREDIT ON 13.04.2008, IT HA S BEEN SUBMITTED BY THE APPELLANT THAT THE AMOUNT REPRESENT THE TRANSFER FROM THE BANK ACCOUNT OF MR. DINESWARA REDDY, HIS BROTHER, AND THE BANK ACCOUNT EXTRACT FURNISHED IN THIS REGARD CONFIRM THE TRANSA CTION. IN THIS REGARD, IT MAY BE RELEVANT TO MENTION THAT THE ASSESSING OFFICER NOT ACCEPTED THE EXPLANATION OF T HE APPELLANT, SINCE THERE WAS CASH DEPOSITS IN THE BAN K ACCOUNT OF DINESWAR REDDY. THIS CONCLUSION MAY NOT BE CORRECT TO REJECT THE EXPLANATION OF THE APPELLANT, WITHOUT EXAMINING THE ACCOUNT HOLDER IN WHOSE ACCOUNT THE C ASH WAS DEPOSITED. FURTHER, SINCE THE CREDITOR IS IDENT IFIED, TRANSACTION IS EXPLAINED THROUGH BANK ACCOUNT, I AM OF THE CONSIDERED OPINION THAT THERE IS NO GROUND FOR THE ASSESSING OFFICER TO TREAT THE AMOUNT OF RS. 50,000 /- AS UNEXPLAINED CREDIT. 5 ITA.NO.1086/HYD/2013 MR. L.R. BHUVANESHWARA REDDY, HYDERABAD. 6. 6.1 TO 6. 7. . . . . . . . . . . . . . .. . . . .. . 6.9. DURING THE COURSE OF THE APPELLATE PROCEEDING S, THE APPELLANT FURNISHED THE NEEDED EVIDENCE IN THE FORM OF CONFIRMATION LETTERS, EXTRACTS OF THE BANK ACCOU NTS INDICTING THE TRANSFER OF FUNDS, WHICH CONSTITUTED THE ADDITIONAL EVIDENCE, AND A REPORT WAS CALLED FOR FR OM THE ASSESSING OFFICER ON THE SAID GROUND. THE REPORT OF THE ASSESSING OFFICER REJECTED THE CLAIMS OF THE APPELL ANT, QUOTING THE FOLLOWING REASONS : DATE AMOUNT RS. FROM/SOURCE REMARKS A. 16.05.2008 5,00,000 MR. BHASKAR REDDY (BROTHER-IN- LAW OF ASSESSEE) AS AGAINST RS.5,00,000 TRANSFERRED TO THE ACCOUNT OF ASSESSEE, BHASKAR REDDY DIRECTED TO PAY RS.4,15,000/- TO AUTOMOTIVE MFRS AND REASON FOR PAYING LESSER AMOUNTS NOT KNOWN. FURTHER, THE TRANSACTION WAS NOT REFLECTED IN BALANCE SHEET OF BHASKAR REDDY. B. 16.10.2008 18.10.2008 09.02.2008 1,00,000 10,000 5,000 NEERAJA REDDY (SISTER OF ASSESSEE) NO BANK ACCOUNT, CAPITAL ACCOUNT OR BALANCE SHEET OF NEERAJA REDDY FILED. C 13.02.2009 48,700 FROM USA NO PROOF FILED. D. 07.01.2009 30.03.2009 95,000 49,000 CONSULTANCY CHARGES NO PROOF SUBMITTED 6.9 THE APPELLANT SUBMITTED HIS COMMENTS/EXPLANATION W.R.F. THE REMARKS OF THE ASSESSING OFFICER IN REMAND REPORT. AS COULD BE SEE N FROM THE INFORMATION BROUGHT ON RECORD, THE AMOUNT OF RS. 5,00,000/- RECEIVED FROM MR. BHASKAR REDDY, THROUGH BANKING CHANNEL, AND A CONFIRMATION FOR THE TRANSACTION AND THE PURPOSE OF TRANSACTION WAS ALSO CONFIRMED/INDICATE. IN THIS REGARD IT IS RELEVANT T O REFER TO THE OBSERVATIONS OF THE ASSESSING OFFICER THAT NO MATCHING AMOUNT WAS TRANSFERRED TO AUTOMOTIVE MANUFACTURERS BY THE APPELLANT ON BEHALF OF MR. BHASKAR REDDY AND SUCH REMARK IS NOT A RELEVANT TO DOUBT THE GENUINENESS OF TRANSACTION. THE OTHER REA SON 6 ITA.NO.1086/HYD/2013 MR. L.R. BHUVANESHWARA REDDY, HYDERABAD. QUOTED FOR DISBELIEVING OF THE TRANSACTION WAS NOT NON FURNISHING OF CAPITAL ACCOUNT, BALANCE SHEET OF BHA SKAR REDDY. HOWEVER, IN THIS REGARD, IT IS RELEVANT TO R EFER TO THE REPORT OF THE ASSESSING OFFICER DT. 12.11.2012, WHEREIN THE CREDITWORTHINESS OF MR. BHASKAR REDDY W AS NOT DOUBTED WITH FURTHER INDICATION OF THE ASSETS I N THE FORM OF DEBTORS THAT HAVE BEEN QUANTIFIED AT AS HIG H AS RS. 22,20,94,439/-. IN LIGHT OF THE ABOVE FACTS, TH E OBSERVATION OF THE ASSESSING OFFICER IN REMAND REPO RT, FOR DISBELIEVING THE TRANSACTION, FOUND TO BE MISPLACED AND CONTRADICTORY. HENCE, IT IS HELD THAT THERE IS NO GROUND FOR THE ASSESSING OFFICER TO REJECT THE CLAIM OF TH E APPELLANT IN EXPLAINING THE TRANSACTION OF RS. 5,00,000/- FROM MR. BHASKAR REDDY. 6.9.1 REGARDING THE AMOUNT OF RS. 2,50,000/- OBTAINED FROM MRS. NEERAJA REDDY, THE TRANSACTIONS ARE CONFIRMED AND THE SAID TRANSACTIONS ARE ROUTED THRO UGH BANKING CHANNELS. FURTHER, MRS. NEERAJA REDDY IS ASSESSED TO TAX WHOSE DETAILS ARE AVAILABLE, TO SUP PORT THE CLAIM OF THE APPELLANT. THE BANK STATEMENTS OF MRS. NEERAJA REDDY ARE SHOWN TO HAVE BEEN SUBMITTED BEFO RE THE ASSESSING OFFICER, WHICH WERE APPARENTLY NOT CONSIDERED BY THE ASSESSING OFFICER, FOR FURNISHING THE REMAND REPORT. HENCE, NON-FURNISHING OF BANK ACCOUNT FOR REJECTING THE CLAIM OF THE APPELLANT IN EXPLAIN ING A TRANSACTION ROUTED THROUGH BANK ACCOUNT IS NOT TENABLE AND THE ADDITION TO THE EXTENT OF RS.2,SO,000/- ON THIS GROUND, IS NOT SUSTAINABLE. 6.9.2 FURTHER, THE AMOUNTS OF RS. 95,000/- AND RS. 49,000/- REPRESENT THE CONSULTANCY CHARGES RECEIVED BY THE APPELLANT, WHICH WERE CONSIDERED FOR COMPUTING THE TAXABLE INCOME FROM THE SAID SOURCE. IT IS NOT KNOWN WHAT WAS THE EXACT REQUIREMENT AS PROOF, AS DESIRED BY THE ASSESSING OFFICER IN PROVING THAT SU CH RECEIPTS ARE FORMING PART OF THE WERE CONSIDERED FO R COMPUTING THE TAXABLE INCOME FROM THE SAID SOURCE. IT IS NOT KNOWN WHAT WAS THE EXACT REQUIREMENT AS PROOF, AS DESIRED BY THE ASSESSING OFFICER IN PROVING THAT SU CH RECEIPTS ARE FORMING PART OF THE CONSULTANCY CHARGE S. HENCE, TREATING THE CONSULTANCY CHARGES, WHICH WERE ALREADY FORMING PART OF THE GROSS RECEIPTS OF CONSULTANCY CHARGES, AS UNEXPLAINED CREDIT IS NOT JUSTIFIED. 7 ITA.NO.1086/HYD/2013 MR. L.R. BHUVANESHWARA REDDY, HYDERABAD. 6.9.3 THE AMOUNT OF RS. 48,700/- IS SHOWN TO HAVE BEEN TRANSFERRED FROM THE BANK ACCOUNT MAINTAINED BY THE APPELLANT HIMSELF IN USA AND THE SAID TRANSACTION IS ROUTED THROUGH THE BANK ACCOUNT , WHOSE DETAILS ARE AVAILABLE ON RECORD. HENCE, IT IS HELD THAT THE ADDITION MADE, TREATING SUCH AMOUNTS AS UNEXPLAINED CREDIT, WITH THE COMMENT THAT 'NO PROOF FURNISHED', IS NOT SUSTAINABLE. SINCE, IT IS APPELLANT'S OWN TRANSACTION ROUTED THROUGH BANKING CHANNEL, THE SAME CANNOT BE TREATED AS UNEXPLAINED CREDIT IN THE HANDS OF APPELLANT. ACCORDINGLY, THE ADDITION OF RS . 13,83,700/-, ON ACCOUNT OF TREATING THE CREDITS THROUGH HDFC BANK AND ICICI BANK ETC. STAND DELETED, BASED ON THE FACTS OF THE CASE. THIS GROUN D OF APPEAL IS TREATED AS ALLOWED. 6. AFTER CONSIDERING THE RIVAL CONTENTIONS, WE DO NOT SEE ANY REASON TO INTERFERE WITH THE ORDERS OF THE LD. CIT(A). IN FACT, THERE WERE TWO REMAND REPORTS FROM THE A.O. W HICH CLEARLY INDICATES THAT MOST OF THE CREDITS WERE ACC EPTED BY THE A.O. AS SEEN FROM THE ORDER OF THE LD. CIT(A), HE H AS USED HIS OWN DISCRETION ONLY WITH REFERENCE TO UNEXPLAINED C REDITS IN ICICI BANK WHEREAS THE CREDITS TO AN EXTENT OF RS.1 2,18,400/- IN THE BANK ACCOUNT OF HDFC WERE ACCEPTED BY THE A. O. ON THE BASIS OF WHICH LD. CIT(A) GAVE RELIEF. THUS, THERE SHOULD NOT BE ANY GRIEVANCE ON THE AMOUNTS, WHICH ARE CONSIDERED AS ADDITION OUT OF THE DEPOSITS OF HDFC BANK. 7. WITH REFERENCE TO CREDITS IN ICICI BANK, APART FROM TRANSFER OF FUNDS FROM ONE ACCOUNT TO ANOTHER, LD. CIT(A) USED HIS DISCRETION ONLY WITH REFERENCE TO RS.50,000/- C REDITED BY WAY OF TRANSFER FROM ASSESSEES BROTHER ACCOUNT AND RS.2,50,000/- BY WAY OF LOAN OBTAINED FROM MR. M. N EERAJA REDDY WHO IS AN ASSESSEE. REST OF THE AMOUNTS ARE A CCEPTED BY THE A.O. IN THE REMAND REPORTS. EVEN WITH THE ABOVE TWO AMOUNTS ALSO, THE ORDER OF THE LD. CIT(A) IS JUSTIF IABLE ON THE 8 ITA.NO.1086/HYD/2013 MR. L.R. BHUVANESHWARA REDDY, HYDERABAD. FACTS ON RECORD. WE DO NOT SEE ANY REASON TO CONSID ER THE REVENUE OBJECTIONS. ACCORDINGLY, GROUNDS ARE REJECT ED. 8. AS SEEN FROM THE GROUNDS RAISED BY THE REVENUE THERE SEEMS TO BE NON-APPLICATION OF MIND ON THE PA RT OF THE AUTHORITIES IN PREFERRING SECOND APPEAL. EVEN THE A CCEPTED AMOUNTS BY THE A.O. IN THE REMAND PROCEEDINGS SEEMS TO HAVE BEEN CONTESTED. FURTHER, AMOUNT OF RS.20,11,100/- M ENTIONED IN THE GROUND DOES NOT TALLY AT ALL WITH THE RELIEF GIVEN. WE CAN ONLY ADVISE THE SENIOR OFFICERS TO APPLY THEIR MIND AND ACCEPT THE ORDERS OF THE LD. CIT(A) TO THE EXTENT OF FACTS WHICH WERE VERIFIED AND ACCEPTED BY THE A.O. WITH THESE OBSERV ATIONS, REVENUE APPEAL IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 09.07.2014. SD/- SD/- (ASHA VIJAYARAGHAVAN) (B.RAMAKOTAIAH) JUDICIAL MEMBER ACCOUNTANT MEMBER HYDERABAD, DATED 09 TH JULY, 2014 VBP/- COPY TO 1. THE INCOME TAX OFFICER, WARD 7(1), 2 ND FLOOR, B BLOCK, I.T. TOWERS, A.C. GUARDS, HYDERABAD. 2. MR. L.R. BHUVANESHWARA REDDY, H.NO.11-04-646/D/4 , FLAT NO.202, VIJAYA HILLS, A.C. GUARDS, LAKADIKAPOO L, HYDERABAD. 3. CIT(A)-VI, 6A, I.T. TOWERS, A.C. GUARDS, HYDERABAD - 500 004. 4. CIT-VI, HYDERABAD 7. D.R. B BENCH, ITAT, HYDERABAD.