Padmaja Polymers Pvt. Ltd., R.R.Dist, Hyderabad V. DCIT, Circle-16(3), Hyderabad, Hyderabad

ITA 1104/HYD/2015

• Counselvise Citation: 110422514 RSA 2015
• Duration Of Justice: 3 month(s) 30 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-12-2015
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 14-12-2015
• Assessment Year: 2007-2008
• Appeal Filed On: 24-08-2015
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: SITA RAMA
• Assessee Lawyers: A V RAGHURAM
• Keywords: Capital asset; Depreciation; Revenue expenditure; Capital expenditure

Judgement Text

THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA NO. 1104/HYD/2015 ASSESSMENT YEAR: 2007-08 PADMAJA POLYMERS PVT. LTD., HYDERABAD PAN AABCP 2137 R VS. ASST. COMMISSIONER OF INCOME- TAX, CIRCLE 16(3), HYDERABAD (APPELLANT) (RESPONDENT) ASSESSEE BY : SHRI A.V. RAGHU RAM REVENUE BY : SHRI SITA RAMA DATE OF HEARING : 14/12/2015 DATE OF PRONOUNCEMENT : 23/12/2015 O R D E R PER S. RIFAUR RAHMAN, A.M.: THIS APPEAL IS PREFERRED BY THE ASSESSEE AGAINST T HE ORDER OF CIT(A)-4, HYDERABAD DATED 01/05/2015 FOR THE AY 200 7-08. 2. BRIEFLY THE FACTS OF THE CASE ARE, THE ASSESSEE COMPANY IS ENGAGED IN THE BUSINESS OF MANUFACTURING AND TRADIN G OF HDP/WOVEN SACS. FOR AY 2007-08, THE ASSESSEE FILED E-RETURN O N 26/10/2007 ADMITTING A TOTAL INCOME OF RS. 3,40,130/-, WHICH W AS PROCESSED U/S 143(1) ON 12/03/09. 3. ON PERUSAL OF THE BALANCE SHEET FILED ALONG WITH THE RETURN OF INCOME, THE AO OBSERVED THAT THE AUTHORIZED SHARE C APITAL OF THE ASSESSEE COMPANY HAD INCREASED FROM RS. 95 LAKHS TO RS. 4.40 CRORES. WHEN AO REQUESTED ASSESSEE COMPANY TO FURNI SH THE DETAILS OF THE FEE PAID TO THE REGISTRAR OF COMPANIES (ROC) FOR INCREASE OF THE AUTHORIZED SHARE CAPITAL AND IF SUCH EXPENDITUR E WAS CLAIMED AS 2 ITA NO. 1104 /HYD/2014 PADMAJA POLYMERS PVT. LTD. REVENUE EXPENDITURE, AND THE ASSESSEE VIDE ITS WRI TTEN SUBMISSIONS DATED 25/11/2009 HAD STATED AS UNDER: THE COMPANY HAD PAID AN AMOUNT OF RS. 1,17,500/- AS FEES FOR INCREASE IN SHARE CAPITAL FOR ROC. THE FEES PAID T O ROC SHOWN AS EXPENDITURE UNDER THE HEAD RATES AN TAXES PAID. WE HAVE NO OBJECTION TREATING THE SAME AS CAPITAL EXPENDITURE AND ALLOW 1/5 TH WRITING OF THE SAME DURING THE AY 2007-08 AS PER T HE PROVISIONS OF THE IT ACT. THE AO FOLLOWING THE JUDGMENT OF THE HONBLE SUPREM E COURT IN THE CASE OF M/S PUNJAB STATE INDUSTRIAL DEVELOPMENT COR PORATION LTD. VS. CIT, 220 ITR 792 REJECTED THE ABOVE SUBMISSIONS OF THE ASSESSEE AND DISALLOWED THE SAID EXPENDITURE INCURRED. 4. THE AO NOTICED FROM THE SCHEDULE GIVING DETAILS OF ADMINISTRATIVE EXPENSES THAT THE ASSESSEE HAD CLAIM ED AN EXPENDITURE OF RS. 7,67,196/- TOWARDS EDUCATIONAL E XPENSES. WHEN THE AO ASKED THE ASSESSEE TO EXPLAIN THE PURPOSE OF THE SAID EXPENDITURE, ASSESSEE FILED WRITTEN SUBMISSIONS ON 20/11/2009 WHEREIN IT WAS STATED THAT THE SAID EXPENDITURE WAS INCURRED FOR THE PURPOSE OF EDUCATION OF ONE OF ITS DIRECTORS OF THE COMPANY VIZ., K. SHREYA REDDY FOR PURSUING HER EDUCATION ABROAD. AS THE ASSESSEE COULD NOT FURNISH ANY EXPLANATION WITH REGARD TO RE LEVANCE OF THIS EXPENDITURE TOWARDS HIGHER EDUCATION OF ONE OF ITS DIRECTORS WITH THE BUSINESS ACTIVITY OF THE ASSESSEE, THE AO DISALLOWE D THE SAID EXPENDITURE TREATING THE SAME AS NOT IN CONNECTION WITH BUSINESS. 5. THE AO FURTHER NOTICED THAT THE ASSESSEE COMPANY HAD RECEIVED CAPITAL SUBSIDY OF RS. 40,00,000 I.E. RS. 20,00,000 IN M/S PADMAJA PLASTIC PRODUCT LTD. AND RS. 20 LAKHS IN M/ S PADMAJA POLYMERS LTD. THE CAPITAL SUBSIDY RECEIVED BY M/S P ADMAJA POLYMERS LTD. DURING FY 2004-05 IS NOT ADJUSTED AGAINST THE VALUE OF THE FIXED ASSETS THEREBY RESULTING IN EXCESS CLAIM OF DEPRECI ATION. HENCE, THE SAME WAS ADJUSTED IN AY 2005-06 AND THE DEPRECIATIO N ALLOWABLE WAS RECALCULATED. ACCORDINGLY, AO DISALLOWED THE EXCESS DEPRECIATION CLAIMED OF RS. 1,91,250/-. 3 ITA NO. 1104 /HYD/2014 PADMAJA POLYMERS PVT. LTD. 6. REFERRING TO THE ABOVE FACTS, THE AO OBSERVED TH AT THE ASSESSEE COMPANY HAS WILLFULLY MADE THE CLAIMS IN I TS COMPUTATION, VIZ., 1) RO CHARGES OF RS. 1,17,500, 2) EXPENDITURE TOWARDS EDUCATIONAL EXPENSES OF RS. 7,67,196/- AND 3) CONCE ALED THE RECEIPT OF CAPITAL SUBSIDY OF RS. 20 LAKHS RESULTING IN EXC ESS CLAIM OF DEPRECIATION OF RS. 1,91,250/-. THE AO, THEREFORE, INITIATED PENALTY PROCEEDINGS U/S 271(1)(C) ON THE GROUND THAT THE AS SESSEE COMPANY HAD FAILED TO FURNISH FULL AND COMPLETE PARTICULARS OF ITS INCOME BEFORE THE DEPARTMENT AND HELD THAT THE TAX THAT WAS SOUGH T TO BE EVADED ON THE CONCEALED INCOME OF RS. 10,75,946/- COMES TO RS . 3,62,163/- AND THE SAME WAS LEVIED AS PENALTY U/S 271(1)(C) OF THE ACT. 7. AGGRIEVED WITH THE ABOVE ORDER, ASSESSEE PREFERR ED AN APPEAL BEFORE THE LD. CIT(A). 8. THE CIT(A) AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESSEE, HELD AS FOLLOWS: 4. THE ASSESSMENT ORDER, THE PENALTY ORDER AND THE SUBMISSIONS OF THE ASSESSEE ARE PERUSED. IT IS SEE N THAT THE PENALTY IS LEVIED ON THREE ACCOUNTS CLAIM OF ROC C HARGES AS REVENUE EXPENSES, CLAIM OF EDUCATIONAL EXPENSES OF DIRECTOR ADMINISTRATION EXPENSES AND CLAIM OF DEPRECIATION ON SUBSIDY RECEIVED (NOT REDUCING SUBSIDY FROM WDV / COST). T HE AO IN THE PENALTY ORDER HAS DISTINGUISHED THE PRESENT CASE F ROM THE CASES RELIED ON BY THE ASSESSEE. WITH REGARD TO CLAIM OF ROC CHARGES, IT IS SEEN THAT THE SAME IS TO BE TREATED AS CAPITAL EXPENDITURE AND DEPRECIATION IS ALLOWABLE ON THE S AME. IN VIEW OF THE ABOVE, THE PENALTY ATTRIBUTABLE TO CLAIM OF ROC CHARGES, IS NOT LEVIABLE AND ACCORDINGLY IS DELETED. REGARD ING THE CLAIM OF EDUCATIONAL EXPENSES, NO EXPLANATION WAS FURNIS HED BY THE ASSESSEE DURING THE ASSESSMENT PROCEEDINGS AND PEN ALTY PROCEEDINGS. THE SAME WAS CLAIMED UNDER ADMINISTRA TIVE EXPENSES AND WAS FOUND OUT BY THE AO DURING THE AS SESSMENT PROCEEDINGS. THE RATIO OF CASES RELIED ON BY AR NO SPECIFIC CASE QUOTED, THOUGH CANNOT BE APPLIED TO PRESENT C ASE AS NO JUSTIFICATION WHATSOEVER HAS BEEN GIVEN BY THE ASS ESSEE. ACCORDINGLY, PENALTY LEVIED ON THIS ACCOUNT IS CON FIRMED. FURTHER THE CLAIM OF DEPRECIATION WITHOUT REDUCING SUBSIDY, CLEARLY AMOUNTS TO FURNISHING INACCURATE PARTICULA RS OF INCOME. NO EXPLANATION IS GIVEN EVEN DURING THE PRESENT AP PELLATE 4 ITA NO. 1104 /HYD/2014 PADMAJA POLYMERS PVT. LTD. PROCEEDINGS REGARDING THE SAME. ACCORDINGLY, THE P ENALTY LEVIED ON THIS ACCOUNT IS CONFIRMED. 9. AGGRIEVED BY THE ORDER OF CIT(A), ASSESSEE IS IN APPEAL BEFORE US AND RAISED THE FOLLOWING GROUNDS OF APPEAL: 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE ORDER OF THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) ALLOW ING THE APPEAL ONLY IN PART IS ERRONEOUS, ILLEGAL AND UNSUSTAINABLE. THE COMMISSIONER (APPEALS) OUGHT TO HAVE ALLOWED THE APPEAL IN ENTIRETY. 2. THE LEARNED COMMISSIONER (APPEALS) ERRED IN SUS TAINING THE PENALTY LEVIED ON THE CLAIM OF EDUCATIONAL EXPENSES WITHOU T APPRECIATING THE FACT THE SAME WAS APPEARING IN THE P & L A/C AND MERE D ISALLOWANCE OF CLAIM DOES NOT AMOUNT TO CONCEALMENT OF INCOME OR FURNIS HING INACCURATE PARTICULARS. 9.1 THE ASSESSEE ALSO FILED A PETITION FOR ADMISSIO N OF THE FOLLOWING ADDITIONAL GROUNDS: 1. ON THE FACTS AND IN. THE CIRCUMSTANCES OF THE CASE) THE LEARNED CIT(A) ERRED IN SUSTAINING THE LEVY OF PENALTY ON THE ALL EGED CONCEALMENT RESULTING ON ACCOUNT OF NOT REDUCING THE SUBSIDY A MOUNT OF RS.20 LAKHS BEFORE CLAIMING DEPRECIATION. 2. THE LEARNED CIT(A) FAILED TO APPRECIATE THAT TH E SUBSIDY OF RS.20 LAKHS GRANTED BY THE GOVERNMENT RELATES TO FY 2004-05) A ND FURTHER IT WAS NOT CLEAR AS TO WHETHER THE SAID SUBSIDY AT ALL COULD BE REDUCED FROM THE CAPITAL ASSETS IN AS MUCH AS THE GOVERNMENT ORDER WAS NOT CLEAR AS TO WHETHER IT IS ON CAPITAL SIDE OR ON REVENUE SIDE. THE LEARNED CIT(A) OUGHT TO HAVE APPRECIATED THAT THE ISSUE WHETHER THE GRA NT RECEIVED BY THE APPELLANT HAS TO BE REDUCED FROM THE ASSET IS HIGH LY DEBATABLE IN NATURE AND THEREFORE NO PENALTY CAN BE LEVIED ON THE SAID ISSUE AS ALL THE PARTICULARS ARE SUBMITTED IN THE COURSE OF ASSESSM ENT PROCEEDINGS AND THE APPELLANT ACCEPTED THE TREATMENT GIVEN BY THE ASSE SSING OFFICER. 3. THE LEARNED CIT(A) ERRED IN HOLDING THAT THE AP PELLANT DID NOT MAKE ANY SUBMISSIONS WITH RESPECT TO THE ABOVE ISSUE FAILIN G TO APPRECIATE THAT THE SUBMISSIONS MADE ON OTHER ISSUES ARE EQUALLY APPLI CABLE TO THE ABOVE ISSUE. 9.2 IN THE PETITION FOR ADMISSION OF THE ADDITIONAL GROUNDS, THE ASSESSEE STATED AS UNDER: 1. THE ABOVE APPEAL HAS BEEN FILED AGAINST THE ORD ER OF THE LEARNED CIT (APPEALS) CHALLENGING THE SUSTENANCE O F PENALTY LEVIED BY THE ASSESSING OFFICER. THE CIT(APPEALS) SUSTAINED PENALTY ON (I) DISALLOWANCE OF EDUCATIONAL EXPENSE S AND (II) ALLEGED CONCEALMENT RESULTING ON ACCOUNT OF NON- R EDUCTION OF SUBSIDY AMOUNT OF RS.20 LAKHS WHILE CLAIMING DEPRE CIATION. 5 ITA NO. 1104 /HYD/2014 PADMAJA POLYMERS PVT. LTD. 2. IN SO FAR AS THE ISSUE OF PENALTY ON DISALLOWA NCE OF EDUCATIONAL EXPENSES IS CONCERNED, THE APPELLANT H AS RAISED SPECIFIC GROUND IN THE MEMORANDUM OF APPEAL FILED BEFORE THE HON'BLE TRIBUNAL. HOWEVER, THE GROUND WITH RESPECT TO ALLEGED CONCEALMENT RESULTING ON ACCOUNT OF NON-REDUCTION OF SUBSIDY AMOUNT OF RS.20 LAKHS WHILE CLAIMING DEPRECIATION IS CONCERNED THERE IS NO SPECIFIC GROUND IN THE MEMORANDUM OF A PPEAL. IT IS SUBMITTED THAT THE OMISSION TO FILE GROUND WITH RE SPECT TO THE ABOVE ISSUE IS BY INADVERTENCE AND PURELY UNINTENT IONAL. THE HON'BLE TRIBUNAL WILL APPRECIATE THAT SUCH A GROUN D WAS RAISED BEFORE FIRST APPELLATE AUTHORITY AND WAS ADJUDICAT ED UPON. THE APPELLANT INTENDED TO AGITATE THE SAME BEFORE THE HON'BLE TRIBUNAL BUT BY INADVERTENCE DID NOT FILE A SPECIF IC GROUND IN THE APPEAL. 10. AFTER CONSIDERING THE SAID SUBMISSIONS OF THE A SSESSEE AND SINCE THE SAID GROUND WAS RAISED BEFORE THE CIT(A) AND WAS ADJUDICATED UPON AND ALSO LD. DR HAS NO OBJECTION T O SUCH ADDITIONAL GROUND, WE ADMIT THE AFORESAID ADDITIONAL GROUND. 11. BEFORE US, THE LD. AR CONTENDED THAT MERELY BEC AUSE THE ASSESSEE HAS ACCEPTED FOR DISALLOWANCE AT THE TIME OF ASSESSMENT IT DOES NOT AMOUNT TO CONCEALMENT AS IT IS NOT HELD TH AT THE EXPENDITURE IS NOT INCURRED FOR BUSINESS. THE LD. AR FURTHER CO NTENDED THAT THE ISSUE AS TO WHETHER PENALTY U/S 271(1)(C) COULD BE LEVIED ON MERE DISALLOWANCES OF ITEMS OF EXPENDITURE APPEARING IN PROFIT AND LOSS ACCOUNT EVEN IF DISALLOWED DOES NOT AMOUNT TO CONCE ALMENT OF INCOME OR FURNISHING OF INACCURATE PARTICULARS. FOR THIS P ROPOSITION, LD. AR PLACED RELIANCE ON THE JUDGMENT OF THE HONBLE SUPR EME COURT IN THE CASE OF RELIANCE PETRO PRODUCTS, 322 ITR 158 AND TH E JUDGMENT OF THE HONBLE AP HIGH COURT IN CASE OF TAHER ALI IN I TTA NO. 128 OF 2014, DATED 04/03/14. 6 ITA NO. 1104 /HYD/2014 PADMAJA POLYMERS PVT. LTD. 12. THE LD. DR, ON THE OTHER HAND, BESIDES RELYING ON THE ORDER OF CIT(A) SUBMITTED THAT ASSESSEE HAD NOT ESTABLISHED THE RELEVANCE OF SUCH EDUCATION BY DIRECTOR TO THE ASSESSEES BUSINE SS. EVEN THE SUBSIDY, THE DIRECTORS ARE SAME IN M/S PADMAJA PLAS TICS PRODUCTS LTD. AND PADMAJA POLYMERS PVT. LTD. IN THE LATTERS CASE, THE SUBSIDY WAS RECORDED IN THE FIXED ASSETS AS REDUCTION, BUT, THE SAME WAS NOT FOLLOWED IN THE ASSESSEES CASE. THE LD. DR PLACED RELIANCE ON THE FOLLOWING JUDGMENTS: 1.CIT VS. NG TECHNOLOGIES LTD., [2015] TAXMANN.COM 389 (DELHI) 2. GOURAV GOENKA VS. ACIT, [2015] 54 TAXMANN.COM 3 54 (CALCUTTA) 3. MAK DATA (P) LTD. VS. CIT [2013] 38 TAXMAN.COM 448 (SC). 13. WE HAVE HEARD THE ARGUMENTS OF BOTH THE PARTIES AND PERUSED THE ORDERS OF REVENUE AUTHORITIES AS WELL AS THE MA TERIAL FACTS ON RECORD. WE HAVE ALSO GONE THROUGH THE DECISIONS CIT ED BY BOTH THE COUNSELS AND UNDERSTAND THAT PENALTY WAS LEVIED ON TWO COUNTS, FIRST ONE BEING CLAIM OF EDUCATION EXPENSES OF A DIRECTOR , THE ASSESSEE HAD NOT SUBMITTED ANY DETAILS TO SUBSTANTIATE THE C LAIM OF EDUCATION EXPENSES FOR DIRECTOR WHICH IN FACT RELATING TO BEN EFIT OF THE BUSINESS. IT WAS NOT SUBSTANTIATED EITHER BEFORE THE AO NOR B EFORE THE CIT(A). IT WAS SUBMITTED BEFORE US THAT THE DIRECTOR HAS UPGRA DED THE KNOWLEDGE AND IT WILL BE BENEFICIAL TO THE BUSINESS AND THE EDUCATION WAS IN LINE WITH THE BUSINESS OF THE ASSESSEE. BUT, NO COGENT MATERIAL WAS SUBMITTED BEFORE US TO PROVE THAT THE EDUCATION EXPENSES WERE IN LINE OF THE BUSINESS OPERATION OF THE ASSESSEE. IT WAS SUBMITTED THAT MERE CLAIM OF THE EXPENSES IN THE P&L A/C NOT AMOUN TING TO FURNISHING OF INACCURATE PARTICULARS. THE RELIANCE WAS STRESSED IN THE CASE OF RELIANCE PETRO PRODUCTS (SUPRA) AND IN THE CASE OF TAHER ALI (SUPRA). IN THE ABOVE CASE, IT WAS HELD THAT MERE M AKING CLAIM, WHICH IS NOT SUSTAINABLE IN LAW, BY ITSELF, WILL NOT AMOU NT TO FURNISHING OF INACCURATE PARTICULARS. HOWEVER, THE PARTICULARS RE LATING TO THE 7 ITA NO. 1104 /HYD/2014 PADMAJA POLYMERS PVT. LTD. TRANSACTIONS WERE FULLY FURNISHED AND THE CLAIM WAS DEBATABLE AND ALSO REJECTED BY THE AO. WHEREAS, IN THE PRESENT CA SE, NO DOUBT THE CLAIM OF THE ASSESSEE WAS REJECTED BY THE AO BUT TH E ASSESSEE HAD FAILED TO FURNISH THE DETAILS OF THE EDUCATION EXPE NSES INCURRED ON THE DIRECTOR OF THE ASSESSEE. HENCE, IN OUR CONSIDERED VIEW, NON- FURNISHING OF INFORMATION RELATING TO EXPENDITURE W HICH WAS CLAIMED AS EXPENDITURE IN THE P&L A/C AMOUNTS TO FURNISHING OF INACCURATE PARTICULARS. 14. ON THE SECOND ISSUE RELATING TO CLAIM OF DEPREC IATION WITHOUT REDUCING SUBSIDY RECEIVED, IT WAS SUBMITTED THAT TH E SANCTION OF THE SUBSIDY AMOUNTS WERE NOT CLEAR AND THE ASSESSEE HAD TREATED THE SAID SUBSIDY AS CAPITAL SUBSIDY CHARGED THE SAME AS CAPITAL RESERVES IN THE BOOKS OF ACCOUNT. WE HAVE NOTICED THAT LD. D R SUBMITTED THAT THE ASSESSEE AND AE PADMAJA PLASTIC PRODUCTS LTD. R ECEIVED RS. 20 LAKHS SUBSIDY EACH AND AE HAD REDUCED THE SAME FROM ITS FIXED ASSETS WHERE AS THE AE HAD MERGED WITH THE ASSESSEE DURING THIS A.Y. AND THE SAID SUBSIDY WAS ALSO ADDED TO THE CAP ITAL SUBSIDY IN THE RESERVES OF THE ASSESSEE (REFER PAGE 15 OF THE PAPE R BOOK). IT IS CLEAR THAT ASSESSEE HAD TREATED THE ABOVE SUBSIDY AS CAPI TAL SUBSIDY AND INCLUDED THE SAME AS RESERVES. IT WAS TREATED ABOVE BECAUSE OF THE ACCOUNTING TREATMENT ADOPTED BY THE ASSESSEE CONSIS TENTLY. SINCE, THE ASSESSEE FOLLOWED THIS METHOD OF ACCOUNTING WHI CH IS DEBATABLE, WE ARE INCLINED TO ACCEPT THE SUBMISSION OF THE ASS ESSEE AS THIS CANNOT BE SAID THAT THE ASSESSEE HAS CONCEALED ANY INCOME OR FURNISHES INACCURATE PARTICULARS FOR EVASION OF TAX . HENCE, CANNOT BE LEVIED U/S 271(1)(C) OF THE ACT FOLLOWING THE RATIO LAID DOWN IN CIT VS. HARSHVARDHAN CHEMICALS & MINERALS LTD. [2003] 259 I TR 212 (RAJ.) 15. IN VIEW OF THE ABOVE OBSERVATIONS, THE AO IS DI RECTED TO RECOMPUTE THE PENALTY ACCORDINGLY. 8 ITA NO. 1104 /HYD/2014 PADMAJA POLYMERS PVT. LTD. 16. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. PRONOUNCED IN THE OPEN COURT ON 23 RD DECEMBER, 2015. SD/- SD/- (P. MADHAVI DEVI) (S. RIFAUR RAHM AN) JUDICIAL MEMBER AC COUNTANT MEMBER HYDERABAD, DATED: 23 RD DECEMBER, 2015 KV COPY TO:- 1) M/S PADMAJA POLYMERS (P) LTD., C/O K. VASANTKUMAR & A.V. RAGHURAM, ADVOCATES, 610, 6 TH FLOOR, BABHUKHAN ESTATE, BASHEERBAGH, HYDERABAD. 2) ACIT, CIRCLE 16(3), HYDERABAD 3 CIT(A)-4, HYDERABAD 4) PR. CIT- 4, HYDERABAD 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., H YDERABAD.