HASINI INFRA CONSTRUCTIONS AND DEVELOPERS, KAKINADA V. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJAHMUNDRY

ITA 11/VIZ/2023

AI Insights

The case involves Hasini Infra Constructions and Developers, a firm engaged in the real estate business, which faced scrutiny following a search and seizure operation under Section 132 of the Income Tax Act, 1961. The AO made additions to the assessee's income for the assessment years 2017-18, 2018-19, and 2019-20, based on alleged unrecorded receipts and adopted a uniform rate of Rs. 3,400 per sq ft for all transactions. The CIT(A) reduced the profit rate on unaccounted turnover but upheld some additions. The Tribunal, however, found that the additions were not substantiated by adequate evidence and that the agreements for additional works were separate and did not involve the assessee's income directly.

• Counselvise Citation: [2023] 140 COUNSELVISE.COM (IT) 135775 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 3 month(s) 29 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 03-05-2023
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Next Hearing Date: 17-04-2023
• Assessment Year: 2019-2020
• Appeal Filed On: 04-01-2023
• Other Referred Cases: M/s. Yugandhar Housing Pvt. Ltd vs. ACIT, Central Circle, Viajayawada in ITA Nos. 83 to 88/Viz/2022
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Section: 132; 142(1); 153A; 143(2)

Judgement Text

आयकरअपीलȣयअͬधकरण, ͪवशाखापटणमपीठ, ͪवशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM Įीदुåवूǽआरएलरेɬडी, ÛयाǓयकसदèयएवंĮीएसबालाकृçणन, लेखासदèयकेसम¢ BEFORE SHRI DUVVURU RL REDDY, HON’BLE JUDICIAL MEMBER & SHRI S BALAKRISHNAN, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./ I.T.A. Nos.9, 10 & 11/Viz/2023 (Ǔनधा[रणवष[/ Assessment Year: 2017-18, 2018-19 & 2019-20) Hasini Infra Constructions and Developers, D.No.2-27-23, Gokul Street, Kakinada. PAN: AAIFH 0895 E Vs. The Asst. Commissioner of Income Tax, Central Circle-1, Rajahmundry. (अपीलाथȸ/ Appellant) (Ĥ×यथȸ/ Respondent) आयकरअपीलसं./ I.T.A. Nos. 24 & 25/Viz/2023 (Ǔनधा[रणवष[/ Assessment Year : 2018-19 & 2019-20) The Asst. Commissioner of Income Tax, Central Circle-1, Rajahmundry. Vs. Hasini Infra Constructions and Developers, D.No.2-27-23, Gokul Street, Kakinada. PAN: AAIFH 0895 E (अपीलाथȸ/ Appellant) (Ĥ×यथȸ/ Respondent) अपीलाथȸकȧओरसे/ Assessee by : Sri M.V. Prasad, AR Ĥ×याथȸकȧओरसे/ Revenue by : Sri MN Murthy Naik, CIT-DR सुनवाईकȧतारȣख/ Date of Hearing : 18/04/2023 घोषणाकȧतारȣख/Date of Pronouncement : 04/05/2023 2 O R D E R PERS. BALAKRISHNAN, Accountant Member : The captioned three appeals (ITA Nos. 9, 10 & 11/Viz/2023) are filed by the assessee against the orders of the Ld. Commissioner of Income Tax (Appeals)-3, Visakhapatnam [Ld. CIT(A)] in DIN & Order No. ITBA/APL/S/250/2022- 23/1047514094(1), ITBA/APL/S/250/2022-23/1047514389(1) and ITBA/APL/S/2022-23/1047514632(1), dated 18/11/2022 for the AY: 2017-18, 2018-19 and 2019-20 respectively arising out of the orders passed U/s. 153A [AYs 2017-18 & 2018-19] and U/s. 143(3) [for the AY 2019-20] of the Income Tax Act, 1961 [the Act]. The Revenue has filed the Cross Appeals ( I.T.A. Nos. 24 & 25/Viz/2023 for the AYs 2018-19 & 2019-20). Since the issues raised in the assessee’s appeals as well as the Revenue’s appeals are interconnected therefore, for the sake of convenience, all these appeals are clubbed, heard together and disposed off in this consolidated order. Appeal wise adjudication is given in the following paragraphs. 3 I I.T.A. Nos.9, 10 & 11/Viz/2023 (AYs: 2017-18, 2018-19 & 2019-20) (Assessee’s appeals) 2. The assessee filed these appeals for the AYs 2017-18, 2018-19 & 2019-20. In these appeals, the assessee has raised six similar grounds of appeal therefore, for the sake of convenience, we shall take up ITA No. 09/Viz/2023 (AY 2017-18) as a lead appeal. 3. Brief facts pertaining to the assessee’s appeal for the AY 2017-18 are that the assessee is a firm deriving income from Real Estate business filed its original return of income for the AY 2017-18 on 27/10/2017 admitting a total income of Rs. 52,28,070/-. A search and seizure operation U/s. 132 of the Act was conducted on 28/03/2019 in the case of the assessee-firm at its registered premises wherein certain incriminating material was found and seized. Subsequently, the case was centralized by the order of the Ld. Principal Commissioner of Income Tax-2, Visakhapatnam vide order in F.No. Pr. CIT-2/SP/127/2019-20, dated 14/10/2019. Accordingly, notice U/s. 153A of the Act was issued on 04/01/2021 and served electronically. In response, the assessee filed return of income on 06/02/2021 admitting the same income of Rs. 52,28,080/-. Subsequently, notice U/s. 143(2) of the Act dated 4 13/2/2021 and notice U/s. 142(1) of the Act dated 17/3/2021 were issued and served on the assessee. In response to the notices, the assessee furnished the information as called for by the Ld. AO. Considering and examining the information furnished by the assessee, the Ld. AO found that the assessee-firm has suppressed its receipts for its various projects. The Ld. AO therefore framed the assessment by making an addition of Rs. 43,10,000/- to the returned income and determined the assessed income at Rs. 95,38,080/-. The Ld. AO while making the above addition, rejected the books of accounts of the assessee and adopted the uniform rate of Rs. 3,400/- per sq ft as sold by the assessee and estimated the net profit @ 12.5% considering the income admitted by the similar business concerns. Aggrieved by the order of the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). 4. Before the Ld. CIT(A), the assessee submitted various documents and pleaded that uniform rate of Rs. 3,400/- per sq ft cannot be adopted by the Ld. AO. After considering the submissions made by the assessee and on the basis of the various case laws relied on by the assessee, the Ld. CIT(A) observed that it is only the unrecorded receipts and net profit estimated thereon has to be brought to tax. Accordingly, the Ld. CIT(A) concluded that the assessee has already declared as turnover an amount of Rs. 2,000/- per sq ft sold by the assessee and therefore directed the 5 Ld. AO to tax the balance of Rs. 1,400/- per sq ft sold by the assessee adopting the estimated profit rate of 8% by relying on the decision of the ITAT, Visakhapatnam Bench in the case of M/s. Yugandhar Housing Pvt. Ltd vs. ACIT, Central Circle, Viajayawada in ITA Nos. 83 to 88/Viz/2022, dated,30/08/2022. Aggrieved by the order of the Ld. CIT(A), the assessee filed the present appeal before the Tribunal. 5. The assessee has raised the following grounds of appeal: “1. The Ld. CIT(A) is erred in facts and law while passing the order. 2. The Ld. CIT (A) ought to have appreciated that the Assessing Officer has made the addition without proper jurisdiction since the addition made on the basis of incriminating material found in the third party premises but not in the premises of the appellant. 3. The Ld. CIT(A) ought to have considered that the Assessing Officer has made additions on mere dumb documents and rough notings which do not have any evidentiary value and would have allowed the contention of the assessee firm. 4. The Ld.CIT (A) is not justified in holding that the assessment made by the Assessing Officer as valid without bringing any substantial evidence that the assessee has received the sale consideration over and above consideration received as per the sale. 5. The Ld. CIT(A) is not justified in upholding the assessment made as valid which was completed on mere surmises and conjectures. 6. The appellant craves to add to, amend or modify the above grounds of appeal either before or at the time of hearing of the appeal, if it is considered necessary.” 6 6. At the outset, the Ld. Authorized Representative [Ld. AR] submitted that the assessee has entered into two agreements with customers ie., one for sale of flats and another for additional works. The Ld. AR further submitted that as per the sale agreement the amount of Rs. 2,000/- per sq ft was received by the assessee for the flats sold during the impugned assessment year which was admitted while filing the return of income during the relevant AY. The additional works were carried out by either the employees of the assessee-firm or third party contractors for the completion of the flats. The Ld. AR therefore submitted that the amount of Rs. 1,400/- per sq ft has been paid directly by the customers to the contractors and the assessee has not derived any income out of such receipts. The Ld. AR further submitted that the agreements for sale of flats and the agreements for additional works have been placed in the paper books submitted before the Bench. The Ld. AR strongly objected to the decision of the Ld. AO in adopting the uniform rate of Rs. 3,400/- per sq ft. The Ld. AR also objected to the Ld. CIT(A)’s view in considering only the declared turnover and directing the Ld. AO to estimate the net profit @ 8% on the unaccounted turnover. The Ld. AR also invited our attention to the Paper Book-3 filed which is the compilation of the documents seized vide A/HICD/GNT/03 and 7 submitted that in these documents the names of the parties and the total value of the flats including the rate per sq ft were mentioned but there is no reference about the receipts from the various customers and therefore it is merely a dumb document. The Ld. AR further submitted that Ld. AO has merely estimated and relied on the rate of Rs.3,400/- per sq ft without any justification whereas the flats were sold for price ranging from Rs. 3,100/- to Rs. 3,400/- per sq ft inclusive of additional works. The Ld. AR also invited our attention to Page No.15 of the seized document A/HICD/GNT/02 wherein the Flat No.203 was sold to Mr. P. Ravi Kumar which was taken as example by the Ld. AO and stated that the document shows that the customer has directly paid to Mr. Sekhar an amount of Rs. 13,84,000/- for the additional works done by Mr. Sekhar. The Ld. AR also invited our attention to the agreement entered into with Mr. Sekhar as submitted in the Paper Book. The Ld. AR therefore pleaded that the assessee has not derived any income from the additional works and hence the addition made by the Ld. AO is unsustainable and may be deleted. Per contra, the Ld. DR submitted that in the sworn statements recorded by various contractors, they have denied 8 carrying out of any additional work as per the agreements and stated that these documents were signed as per the directions of the Managing Partner of the assessee-firm Mr. Chindripu Murali. The Ld. DR therefore submitted that the assessee has diverted its income through his employees and contractors and therefore pleaded that the order of the Ld. AO be upheld. The Ld DR also referred to sworn statements recorded by various contractors stating that they have not performed any work but has only acted only on the directions of the Managing Partner Shri Chindrippu Murali. Countering the arguments of the Ld. DR, the Ld. AR submitted that the details of agreement with contractors with whom it was entered into and who are in receipt of the funds directly from the customers have filed their return of income by admitting the Net Profit of 8% on the agreement values. The Ld. AR therefore pleaded that since the contractors have already admitted the income while filing their return of income, again it cannot be added in the hands of the assessee. 7. We have heard both the sides and perused the material available on record as well as the orders of the Ld. Revenue Authorities. It is the case of the Ld. AO that the assessee has sold various flats from various projects at a uniform rate of Rs. 9 3,400/- per sq ft but the assessee has failed to disclose the turnover as per the agreed rates. However, the Ld. AO has erred in giving credit to the turnover already declared by the assessee while framing the assessment. The Ld. AO has relied on the documents seized vide A/HICD/GNT/03, wherein no details about the amount of receipts from the customers, either by way of cash or cheque, are available in such documents. The Ld. AO merely relied on the total value of sales against each flat as mentioned in the documents but has failed to record how the total value was received by the assessee. Further, as demonstrated by the Ld. AR the assessee has entered into two agreements viz., one is sale agreement and another one is an agreement for carrying on the additional works. The sale agreement was entered into directly with the customers by the assessee adopting the rate of Rs. 2,000/- per sq ft whereas agreement for additional works was entered into with various employees of the firm / contractors directly by the customers. We also find that various customers have directly made the payments for the additional works done in their respective flats to the concerned contractors and subsequently the contractors have made the payments to the suppliers of the material for carrying out the additional works. From the sworn statements 10 recorded by various contractors, we find that there is no denial by the various contractors that the amounts were received by them, except for the fact that it was under the directions of the Managing Partner of the assessee-firm Mr. Chindripu Murali. The contractors / employees of the assessee-firm have also agreed that the amounts received from the customers for carrying out the additional works were directly paid to the suppliers of the material. Further, from the sworn statements we also find that the amounts for additional works were received by Cheque and various payments made to the suppliers of the material was also made through banking channels. The Ld.AO has also not brought on record any material to show that the amounts for additional works were received by the assessee. The Revenue is also not disputing the fact that the employees / contractors received the payments from the customers directly in their bank accounts. In the light of the discussions as above, we find that the Ld. AO has no material justification for adopting the uniform rate of Rs. 3,400/- per sq ft in the hands for the assessee as its turnover for the impugned assessment year. We also find from the arguments put forth by the Ld. AR as well as the material placed before us, there are two different agreements entered into by various customers ie., one for the sale of flat and another 11 agreement is for carrying out the additional works. It is also clearly demonstrated and established by the Ld. AR that the customers have directly made the payments to the contractors as per the additional works agreement. The only contention of the Revenue is that since the additional works are carried out through the employees of the assessee, therefore the Revenue considered it as diversion of turnover of the assessee. However, we find that since the customers have directly made the payments to the contractors for the additional works carried on by them and either the receipts or payments have not been passed through the assessee’s books of account, it cannot be considered as a turnover of the assessee. Therefore, considering the above facts and circumstances of the case, in our considered view, we are inclined to delete the addition made by the Ld. CIT(A) on the differential amount of Rs. 1,400/- sold by the assessee and direct the Ld. AO to delete the addition partially sustained by the Ld. CIT(A). Accordingly, Grounds No. 3, 4 & 5 are disposed off and allowed. 8. Ground No.2 raised by the assessee regarding the jurisdiction of the Ld. AO is not adjudicated since the other 12 grounds raised by the assessee are adjudicated in favour of the assessee on merits. 9. Grounds No.1 & 6 are general in nature and need no adjudication. 10. In the result, appeal of the assessee (ITA No.09/Viz/2023, AY: 2017-18) is allowed. 11. With respect to ITA Nos. 10 & 11/Viz/2023 (AYs: 2018-19 & 2019-20), since the assessee has raised the identical issue in both these appeals, which is similar to that of the issue adjudicated by us while deciding the assessee’s appeal in ITA No. 9/Viz/2023 (AY: 2017-18) in the above paragraphs of this order, our decision given therein in the assessee’s appeal for the AY 2017-18 mutatis mutandis applies to these appeals also. Thus, both the assessee’s appeals in ITA Nos. 10 & 11/Viz/2023 (AYs: 2018-19 & 2019-20) are allowed. II ITA Nos.24 & 25/Viz/2023 (AYs: 2018-19 & 2019-20) (Revenue’s Cross Appeals) 12. Both these cross appeals are filed by the Revenue against the orders of the Ld. CIT(A)-3, Visakhapatnam in DIN & Order No. 13 ITBA/APL/S/250/2022-23/1047514389(1) for the AY: 2018-19 & ITBA/APL/S/250/2022-23/1047514632(1) for the AY: 2019-20 dated 18/11/2022 arising out of the orders passed U/s. 153A & 143(3) of the Act respectively. 13. Brief facts pertaining to the Revenue’s appeal for the AY 2018-19 are that the assessee is a firm deriving income from Real Estate business filed its original return of income for the AY 2018-19 on 28/10/2018 admitting a total income of Rs. 81,46,560/-. A search and seizure operation U/s. 132 of the Act was conducted on 28/03/2019 in the case of the assessee-firm at its registered premises wherein certain incriminating material was found and seized. Subsequently, the case was centralized by the order of the Ld. Principal Commissioner of Income Tax-2, Visakhapatnam vide order in F.No. Pr. CIT-2/SP/127/2019-20, dated 14/10/2019. Accordingly, notice U/s. 153A of the Act was issued on 04/01/2021 and served electronically. In response, the assessee filed return of income on 06/02/2021 admitting the same income of Rs. 81,46,560/-. Subsequently, notice U/s. 143(2) of the Act dated 13/2/2021 and notice U/s. 142(1) of the Act dated 17/3/2021 were issued and served on the assessee. In response to the notices, the assessee furnished the information as called for by the Ld. AO. Considering and examining the information furnished by the assessee, 14 the Ld. AO found that the assessee-firm has suppressed its receipts for its various projects. The Ld. AO therefore framed the assessment by making an addition of Rs. 2,47,75,250/- to the returned income and determined the assessed income at Rs. 3,29,21,810/-. The Ld. AO while making the above addition, rejected the books of accounts of the assessee and adopted the uniform rate of Rs. 3,400/- per sq ft as sold by the assessee and proposed the net profit @ 12.5% considering the income admitted by the similar business concerns. Aggrieved by the order of the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). 14. Before the Ld. CIT(A), the assessee submitted various documents and pleaded that uniform rate of Rs. 3,400/- per sq ft cannot be adopted by the Ld. AO. After considering the submissions made by the assessee and on the basis of the various case laws relied on by the assessee, the Ld. CIT(A) concluded that the assessee has already declared an amount of Rs. 2,000/- per sq ft sold by the assessee and directed the Ld. AO to tax the balance of Rs. 1,400/- per sq ft sold by the assessee adopting the estimate rate of 8% by relying on the decision of the ITAT, Visakhapatnam Bench in the case of M/s. Yugandhar Housing Pvt. Ltd vs. ACIT, Central Circle, Viajayawada in ITA Nos. 83 to 88/Viz/2022, dated, 30/08/2022. Aggrieved by the order of the Ld. CIT(A), the Revenue filed the instant appeal before the Tribunal. 15 15. The Revenue has raised the following grounds for the AY: 2018-19 as follows: “1. The order of the Ld. CIT(A) is erroneous on ground s of facts and law. 2. The Ld. CIT(A) erred in restric ting the addition made to 8% of only the unaccounted turnover, since as regards the accounted turnover, the assessee could no t produce the updated books of account and the supporting evidences like bills, vouchers and o ther documents in suppor t of the entries made in the books of account. Besides, in view of the fact that the assessment co mple ted in this case was U/s. 153A of the Act to assess the total inco me of the assessee, the same is statutorily no t limited to only assess undisclosed inco me consequent to search action. Reference in this regard is made to the decision of the Hon’ble Kerala High Cour t in the case of E.N. Gopakumar vs. CIT (2016) 75 tax mann.co m 215 (Kerala), wherein it was held that assessmen t proceedings generated by issuance of a no tice U/s. 153A(1)(a) can be concluded against interest of the assessee including making additions even without any incriminating material being available agains t the assessee as a result of search U/s. 132 on the basis of which no tice was issued U/s. 153A(1)(a). 3. The Ld. CIT(A) erred in holding that the AO had adopted uniform rate of Rs. 3,400/- per sft on the basis of co mparative cases since, as can be seen from the assessment order, the rates adopted are done project / venture wise and are different for different projec ts and that too on the basis of seized material as also the state ments of the persons concerned. Besides, the Ld. CIT(A)’s observation that the AO had adopted the said rate on the basis of comparative cases is misplaced since the AO’s remark was actually in respect of profit percentage adopted at 12.5% and no t otherwise. Also the seized material contained de tails of cash receipts on sale of residential units in the venture Hasini Platinu m County in addition to the payments received through 16 banks, which was no t repudiated by the assessee firm. 4. The Ld. CIT(A) erred in overlooking the fac t that, the assessee fir m had entered into two agree ments with the custo mers for sale of each flat, one for sale of basic struc ture and o ther for additional works. The additional works agree ments were normally in the names of workers or e mployees of the assessee firm, who are receiving payments from custo mers and transferring the money to par ties to who m the payments were due from the firm as per the direc tions of the Managing Partner of the fir m. Sworn State ments were recorded from the e mployee s of the assessee firm and all of them had denied to have undertaken such works or even did no t have idea of any such agree ments. Thus, it was obvious that the receipts fro m additional works were effectively used by the fir m only, but that the same were not disclosed in the re turns. 5. The Ld. CIT (A) erred in no t appreciating the AO’s action of rejection of the books of account on valid grounds. 6. The Ld. CIT(A) erred in holding that only the ne t profit on unaccounted turnover can be brought to tax since, as regards the unaccounted turnover, the relatable expenditure would have already found its way into the regular books of account and it is onl y the suppressed receipts sans and expenditure that need to be taxed. Given such a situation, the question of estimation against unaccounted turnover will no t arise. 7. Any o ther ground urged at the time of hearing. 16. The Revenue has raised the following grounds for the AY: 2019-20 as follows: “1. The order of the Ld. CIT(A) is erroneous on ground s of facts and law. 2. The Ld. CIT(A) erred in restric ting the addition made to 8% of only the unaccounted turnover as this case 17 was taken up for co mple te scrutiny being the assessment year relevant to the year of search U/s. 132 and the books of account were rejec ted as the assessee could not produce the updated books of account and the suppor ting evidences like bills, vouchers and o ther documents in suppor t of the entries made in the books of account. 3. The Ld. CIT(A) erred in holding that the AO had adopted uniform rate of Rs. 3,400/- per sft on the basis of co mparative cases since, as can be seen from the assessment order, the rates adopted are done project / venture wise and are different for different projec ts and that too on the basis of seized material as also the state ments of the persons concerned. Besides, the Ld. CIT(A)’s observation that the AO had adopted the said rate on the basis of comparative cases is misplaced since the AO’s remark was actually in respect of profit percentage adopted at 12.5% and no t otherwise. Also the seized material contained de tails of cash receipts on sale of residential units in the venture Hasini Platinu m County in addition to the payments received through banks, which was no t repudiated by the assessee firm. 4. The Ld. CIT(A) erred in overlooking the fac t that, the assessee fir m had entered into two agree ments with the custo mers for sale of each flat, one for sale of basic struc ture and o ther for additional works. The additional works agree ments were normally in the names of workers or e mployees of the assessee firm, who are receiving payments from custo mers and transferring the money to par ties to who m the payments were due from the firm as per the direc tions of the Managing Partner of the fir m. Sworn State ments were recorded from the e mployee s of the assessee firm and all of them had denied to have undertaken such works or even did no t have idea of any such agree ments. Thus, it was obvious that the receipts fro m additional works were effectively used by the fir m only, but that the same were not disclosed in the re turns. 18 5. The Ld. CIT (A) erred in no t appreciating the AO’s action of rejection of the books of account on valid grounds. 6. The Ld. CIT(A) erred in holding that only the ne t profit on unaccounted turnover can be brought to tax since, as regards the unaccounted turnover, the relatable expenditure would have already found its way into the regular books of account and it is onl y the suppressed receipts sans and expenditure that need to be taxed. Given such a situation, the question of estimation against unaccounted turnover will no t arise. 7. Any o ther ground urged at the time of hearing. 17. From the above, the only issue raised by the Revenue in both the appeals is with respect to estimation of profit @ 8% by the Ld. CIT(A) as against the estimation of profit made by the Ld. AO @ 12.5% . 18. The assessee contested the additions made by the Ld. AO and sustained by the Ld. CIT(A) in its appeals for the AYs 2017- 18, 2018-19 & 2019-20 (I.T.A. Nos.9, 10 & 11/Viz/2023), which are adjudicated by us in favour of the assessee as discussed in the above paragraphs. 19. Now, with respect to the cross appeals of the Revenue for the AYs 2018-19 & 2019-20, contesting the estimation of net profit by the Ld. CIT(A), we hold that since the quantum sustained by the Ld. CIT(A) for the AYs 2018-19 & 2019-20 itself is deleted while adjudicating the 19 assessee’s appeals for the AYs 2018-19 & 2019-20 (supra), we are of the view that the grounds raised by the Revenue have no legs to stand. Accordingly, the grounds raised by the Revenue are dismissed. 20. In the result, both the Revenue’s appeals are dismissed. Pronounced in the open Court on the 04 th May, 2023. Sd/- Sd/- (दुåवूǽआर.एलरेɬडी) (एसबालाकृçणन) (DUVVURU RL REDDY) (S.BALAKRISHNAN) ÛयाǓयकसदèय/JUDICIAL MEMBER लेखासदèय/ACCOUNTANT MEMBER Dated :04.05.2023 OKK - SPS आदेशकȧĤǓतͧलͪपअĒेͪषत/Copy of the order forwarded to:- 1. Ǔनधा[ǐरती/ The Assessee–Hasini Infra Constructions and Developers, C/o. CA M.V. Prasad, D.No.60-7-13, Ground Floor, Siddhartha Nagar, 4 th Lane, Vijayawada. (ii) Hasini Infra Construction and Developers, D.No. 2- 7-23, Flat No. 301, Sitapathi’s Swapna Soudha, Gokul Street, Srinagar, Kakinada, East Godavari Dist, Andhra Pradesh. 2. राजèव/The Revenue –The Asst. Commissioner of Income Tax, Central Circle-1, Aayakar Bhavan, Dabagardens, Rajahmundry, Andhra Pradesh – 530020. (ii) ACIT, O/o. ACIT, Central Circle-1, Shiva Towers, 5 th Floor, Danavaipeta, Rajahmundry, Andhra Pradesh – 533103. 3. The Principal Commissioner of Income Tax (Central), Visakhapatnam. 4. आयकरआयुÈत (अपील)/ The Commissioner of Income Tax 5. ͪवभागीयĤǓतǓनͬध, आयकरअपीलȣयअͬधकरण, ͪवशाखापटणम/ DR,ITAT, Visakhapatnam 6. गाड[फ़ाईल / Guard file आदेशानुसार / BY ORDER Sr. Private Secretary ITAT, Visakhapatnam