Dy. Commissioner of Income Tax , Circle-1(1), Hyderabad V. Astha Sterling Crane Private Limited, Hyderabad

ITA 111/Hyd/2018

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 1534 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 5 month(s) 3 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-06-2019
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB-A
• Next Hearing Date: 14-05-2019
• Assessment Year: 2012-2013
• Appeal Filed On: 11-01-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: Y V S T SAI
• Assessee Lawyers: A V RAGHURAM
• Keywords: Deemed dividend; TDS
• Section: 43B; 143(3); 2(22)(e)

Judgement Text

IN 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. 111/ HYD/201 8 ASSESSMENT YEAR: 20 12 - 13 DY. COMMISSIONER OF INCOME - TAX, CIRCLE 1(1), HYDERABAD. VS. ASTHA STERLING CRANE PVT. LTD., HYDERABAD. PAN AAICA8779K A PPELLANT RESPONDENT REVENUE BY: S H RI YVST SAI ASSESSEE BY: S HRI AV RAGHURAM DATE OF HEARING: 14 / 0 5 / 201 9 DATE OF PRONOUNCEMENT: 14 / 0 6 /201 9 O R D E R PER S. RIFAUR RAHMAN , AM: T H IS APPEAL FILED BY THE REVENUE IS DIRECTED AGAINST THE ORDER OF CIT(A) 1 , HYDERABAD, DATED, 12 /0 9 /201 7 FOR AY 20 12 - 13 . 2. BRIEF FACTS OF THE CASE ARE, THE ASSESSEE COMPANY ENGAGED IN THE BUSINESS OF RENTING OF CRANES ON LEASE , FILED ITS RETURN OF INCOME FOR THE AY 20 12 - 13 ON 26 / 1 1 /20 12 DECLARING INCOME OF ( - ) RS. 51,72,944/ - UNDER NORMAL PROVISIONS AND RS. 4,53,40,494/ - UNDER THE PROVISIONS OF SECTION 115JB. THE CASE WAS SELECTED FOR SCRUTINY UNDER CASS AND NOTICES WERE ISSUED U/S 143(2) & 142(1). THE AO COMPLETED THE ASSESSMENT U/S 143(3) ON 18/03/2016 BY DETERMINING TOTAL INCOME AT RS. 7,25,58,770/ - , BY MAKING VARIOUS ADDITI ONS. I.T.A. NO. 111 /HYD/1 8 ASTHA STERLING CRANE PVT. LTD., HYD. 2 3. WHEN THE ASSESSEE CARRIED THE MATTER IN APPEAL BEFORE THE CIT(A), CIT(A) DELETED THE ADDITION OF RS. 8, 25,00,000/ - TOWARDS DEEMED DIVIDEND U/S 2(22)(E) OF THE ACT AND DELETION OF DISALLOWANCE MADE U/S 43 B TOWARDS PF AMOUNTING TO RS. 30,208/ - , WHICH ARE THE SUB JECT MATTER IN THIS APPEAL. 4. AGGRIEVED BY THE ORDER OF CIT(A), THE REVENUE IS IN APPEAL BEFORE US RAISING THE FOLLOWING GROUNDS OF APPEAL: (I) THE ORDER OF THE LD. CIT (A) IS ERRONEOUS ON FACTS AS WELL AS IN LAW. (II) THE LD. CIT(A) ERRED IN DELETING THE ADDITION OF RS.8,25,00,000 / - MADE BY INVOKING THE PROVISIONS OF SEC. 2(22)(E). (III) THE LD. CIT(A) HAD NOT GIVEN ANY FINDINGS OF FACTS AND NO REASON WAS GIVEN FOR ALLOWING THE RELIEF. (IV) THE LD. CIT(A) FAILED TO APPRECIATE THE FACTS BROUGHT ON RECORD AND IGNORED THE PROVISIONS OF LAW. (V) THE LD. CIT (A) ERRED IN DELETING THE DISALLOWANCE MADE U / S 43B TOWARDS PF AMOUNTING TO RS.30,2 08 / - IN RESPECT OF CONTRIBUTIONS MADE BY THE EMPLOYEES BECAUSE OF LATE PAYMENTS INTO THE GOVERNMENT ACCOUNT, WITHOUT APPRECIATING THE DISALLOWANCE WAS MADE IN ACCORDANCE WITH THE CBDT CIRCULAR NO.22 / 20 15 DTD:17 - 12 - 2015. (VI) ANY OTHER GROUND THAT MAY BE URGED AT THE TIME OF HEARING OF APPEAL. 5. AS REGARDS GROUND NOS. I) TO IV) REGARDING DELETION OF ADDITION OF RS. 8,25,00,000/ - MADE BY THE AO U/S 2(22)(E) OF THE ACT, DURING THE ASSESSMENT PROCEEDINGS, THE AO NOTICED THAT THE ASSESSEE HAD AVAILED LOAN OF RS. 8,25,00,000/ - FROM M/S RADIANT RSCC SPECIALITY CABLE PVT. LTD. THE FOLLOWING ARE THE COMMON SHAREHOLDERS AND THEIR SHAREHOLDING PATTERN IS AS UNDER: I.T.A. NO. 111 /HYD/1 8 ASTHA STERLING CRANE PVT. LTD., HYD. 3 S.NO. NAME OF THE COMPANY NAME OF THE SHAREHOLDER /SHRI/SMT/MISS SHAREHOLDING PATTERN 1 RADIANT RSCC SPECIALITY CABLE P. LTD. ASHOK KUNDALIA 12.25% PREETI KUNDALI 12.25% SAMBHAV KUNDALIA 12.25% RAVI KUNDALIA 12.25% 2 ASTHA STERLING CRANE PVT. LTD. ASHOK KUNDALIA 21.09% PREETI KUNDALI 15.85% SAMBHAV KUNDALIA 6.03% RAVI KUNDALIA 6.03% 5.1 THE AO OBSERVED THAT SRI ASHOK KUNDALIA AND OTHERS ARE COMMON SHAREHOLDERS AND ARE HAVING MORE THAN 10% SHAREHOLDING. APART FROM THIS, M/S. RADIANT RSCC SPECIALITY CABLE PVT LTD HAS ACCUMULATED PROFITS OF RS.109,34,23,820 / - DURIN G THE FY 2011 - 12. THEREFORE, THE ASSESSING OFFICER CONCLUDED THAT THE PROVISIONS OF DEEMED DIVIDEND U/S.2(22)(E) ARE ATTRACTED IN THE HANDS OF THE ASSESSEE COMPANY. IN VIEW OF THIS, THE ASSESSING OFFICER ASKED THE ASSESSEE TO EXPLAIN AS TO WHY THE RS.8,25, 00,000 / - SHALL NOT BE TREATED AS DEEMED DIVIDEND IN THE HANDS OF THE COMPANY WITHIN THE MEANING OF SECTION 2(22)(E). IN RESPONSE THE ASSESSEE SUBMITTED AS FOLLOWS: THE ASSESSEE COMPANY WAS ESTABLISHED IN THE FINANCIAL YEAR 2011 - 12 WITH A MAIN OBJECT FOR RENTING OF SPECIALIZED CRANES TO VARIOUS COMPANIES ON MONTHLY RENTALS. M / S. ASTHA STERLING CRANE PVT LTD AND M / S. RADIANT - RSCC ARE TWO SEPARATE AND INDEPENDENT LEGAL ENTITIES, INCORPORATED UNDER THE COMPANIES ACT AND THE MERE FACT THAT THEY HAVE COMMON SHAREHOLDERS DOES NOT BLUR THIS DISTINCTION. M / S. ASTHA STERLING CRANE, IN THE SCN, IS NOT SHOWN TO BE ONE OF THE PERSONS BEING A REGISTERED SHAREHOLDER OF RADIANT - RSCC, ONLY TWO INDIVIDUALS SHRI ASHOK KUNDALIA AND SMT. PREETI KUNDALIA ARE THE COMMON PERSONS, HOLDING MORE THAN REQUISITE AMOUNT OF SHAREHOLDING. DEEMED DIVIDEND UNDER SECTION 2(22)(E) OF THE ACT CAN BE ASSESSED ONLY IN THE HANDS OF SHAREHOLDER OF THE I.T.A. NO. 111 /HYD/1 8 ASTHA STERLING CRANE PVT. LTD., HYD. 4 LENDER COMPANY AND NOT IN THE HANDS OF ANY OTHER PERSONS. THE INTER - CORPORATE DEPOSIT TAKEN BY US FROM M/S. RADIANT RSCC, A BUSINESS TRANSACTIONS IN ORDINARY COURSE OF BUSINESS, AS A DEEMED DIVIDEND I N TERMS OF SECTION 2(22)(E) IS NOT LE G AL AND TENABLE. AT THE OUTSET, THE INTER - CORPORATE DEPOSIT AMOUNT CANNOT BE TAXED AS DEEMED DIVIDEND IN OUR HANDS AS WE ARE NOT A SHAREHOLDER IN RADIANT RSCC. DURING THE YEAR UNDER CONSIDERATION, THE ASSESSEE HAD T AKEN INTER - CORPORATE DEPOSIT FROM M / S. RADIANT RSCC AND UTILIZED THE SAME FOR THE PURPOSES OF THE ASSESSEE'S BUSINESS. M / S. RADIANT RSCC WAS HAVING SURPLUS FUNDS WITH THEM. IN ORDER TO EARN INTEREST ON THE SURPLUS FUND, THE M / S. RADIANT RSCC HAVE IN NORMAL COURSE OF BUSINESS GIVEN INTER - CORPORATE DEPOSIT TO US. THE ASSESSEE COMPANY HAD PAID INTEREST ON THE INTER - CORPORATE TAKEN FROM MIS. RADIANT RSCC ON WHICH TDS HAD BEEN DEDUCTED AND DEPOSITED. SINCE THE AMOUNT RECEIVED IS INTER - CORPORATE DEPOSIT, IT CANN OT BE TERMED AS DIVIDEND UNDER SECTION 2(22)(E) OF THE ACT. DURING THE YEAR, THE ENTIRE INTER - CORPORATE DEPOSIT TOGETHER WITH INTEREST WAS REPAID BY US TO RSCC. THUS, AS EXPLAINED THIS BUSINESS TRANSACTION IS IN THE NATURE OF INTER - CORPORATE DEPOSIT AN D EXTENDED BY THE M / S. RADIANT RSCC TO THE APPELLANT COMPANY FOR BUSINESS EXPEDIENCY AND THEREFORE OUT OF THE PURVIEW OF SECTION 2(22)(E) OF THE ACT. THE ASSESSEE SUBMITTED THAT THE ASSESSEE COMPANY IS NEITHER HOLDING ANY SHARES IN M / S. RADIANT RSCC, F ROM WHOM INTER - CORPORATE DEPOSIT V.AS RECEIVED NOR DID MIS. RADIANT RSCC FROM WHOM THE INTER - CORPORATE WAS RECEIVED, HELD ANY SHARES IN THE ASSESSEE COMPANY. THUS, IT IS TO BE NOTED THAT THE ASSESSEE IS NOT A REGISTERED SHARE HOLDER OF RADIANT WHO HAS GIVE N THE INTER - CORPORATE DEPOSIT TO THE ASSESSEE, IN THE NATURE OF NORMAL BUSINESS TRUNCATION. IN ORDER TO ATTRACT THE PROVISIONS OF SECTION 2(22)(E), THE IMPORTANT CONSIDERATION IS THAT THERE SHOULD BE LOAN/ADVANCE BY A COMPANY TO IT SHAREHOLDER. THE ASS ESSEE HAS RELIED ON THE DECISION OF HON'BLE AP & TELANGANA HC IN THE CASE OF M /S SIDDESWARI POWER GENERATION PVT LTD IN ITA NO.635 - 637/H/2013 DATED 06.12.2013. I.T.A. NO. 111 /HYD/1 8 ASTHA STERLING CRANE PVT. LTD., HYD. 5 5.2 THE ASSESSING OFFICER CONCLUDED THAT THE ARGUMENT OF THE ASSESSEE IS NOT TENABLE FOR THE F OLLOWING REASONS: A) THE DECISION OF THE HON'BLE HIGH COURT IN THE CASE OF SIDDESWARI POWER GENERATION PVT LTD IN I T A NO.705 , 400 &541 HAS BEEN CONTESTED BY THE DEPARTMENT BEFORE THE SUPREME COURT. THE SLP FILED BY THE DEPARTMENT IS ADMITTED IN THE APEX C OURT VIDE CASE NO.2805 OF 2015. B) AS PER SECTION 2(22)(E), DIVIDEND INCLUDES ANY PAYMENT BY A COMPANY, NOT BEING A COMPANY IN WHICH THE PUBLIC ARE SUBSTANTIALLY INTERESTED, OF ANY SUM BY WAY OF ADVANCE OR LOAN TO ANY CONCERN IN WHICH SUCH SHARE - HOLDER. IS A MEMBER OR A PARTNER AND IN WHICH HE HAS A SUBSTANTIAL INTEREST OR ANY PAYMENT BY ANY SUCH COMPANY ON BEHALF, OR FOR THE INDIVIDUAL BENEFIT OF ANY SUCH SHAREHOLDER, TO THE EXTENT TO WHICH COMPANY IN EITHER CASE POSSESSES ACCUMULATED PROFITS. A PLAIN RE ADING OF THE SECTION, IT IS CLEAR THAT ANY PAYMENT BY A COMPANY BY WAY OF ADVANCE OR LOAN TO ANY CONCERN ATTRACT THE PROVISIONS OF DEEMED DIVIDEND. C) IN THIS CASE, THE ASSESSEE COMPANY HAD TAKEN A LOAN OF RS.8,25,00,000/ - FROM M/S.RADIANT RSCC SPECIALI TY CABLE PVT LTD IN WHICH SRI ASHOK KUNDALIA AND OTHERS ARE COMMON SHAREHOLDERS AND ARE HAVING MORE THAN 10% SHAREHOLDING. APART FROM THIS M / S. RADIANT RSCC SPECIALTY CABLE PVT LTD HAS ACCUMULATED PROFITS OF RS.109,34,23,8201 - DURING THE FINANCIAL YEAR 201 1 - 12. IN VIEW OF THE ABOVE, THE ASSESSING OFFICER TREATED RS.8,25, 00,000/ - AS DEEMED DIVIDEND IN THE HANDS OF THE COMPANY. 6. BEFORE THE CIT(A), THE ASSESSEE SUBMITTED THE FOLLOWING: A) M / S. RADIANT - RSCC SPECIALTY CABLE (P) LTD HAS GIVEN INTER - CORPOR ATE DEPOSIT OF RS.8,25, 00,000/ - TO THE APPELLANT OUT OF SURPLUS FUNDS AVAILABLE WITH THEM, IN ORDER TO EARN INTEREST. B) THE APPELLANT SUBMITTED THAT THEY HAD UTILIZED THE SAID FUNDS FOR ITS BUSINESS PURPOSES AND RETURNED BACK THE MONEY ALONG WITH INTEREST DURING THE YEAR ITSELF AFTER DEDUCTING TDS THEREON. I.T.A. NO. 111 /HYD/1 8 ASTHA STERLING CRANE PVT. LTD., HYD. 6 C) THE APPELLANT SUBMITTED THAT THIS TRANSACTION IS PURELY A BU SINESS TRANSACTION AND IT CANNOT BE TREATED AS DIVERSION OF PROFITS TO THE APPELLANT. D) THE APPELLANT SUBMITTED THAT THE APPELLANT COMPANY AND M/S.RADIANT - RSCC SPECIALTY CABLE (P) LTD ARE INDEPENDENT COMPANIES, REGISTERED UNDER INDIAN COMPANIES ACT. E ) APPELLANT COMPANY IS NOT A REGISTERED SHAREHOLDER OF M / S. RADIANT RSCC SPECIALTY CABLE (P) LTD, THE LENDER COMPANY. F) THE TRANSACTION BETWEEN APPELLANT AND M / S. RADIANT - RSCC SPECIALTY CABLE(P) LTD WAS A NORMAL BUSINESS TRANSACTION. G) THE APPELLANT SUBMITTED THAT THE ASSESSING OFFICER MADE THE ADDITION ON THE GROUND THAT THE DECISION OF THE HON'BLE HIGH COURT IN THE CASE OF SIDDESWARI POWER GENERATION (P) LTD IN ITAT NO.705,400 AND 541 HAS BEEN CONTESTED BY THE DEPARTMENT BEFORE THE HON'BLE SUPREME C OURT VIDE CASE NO.2805 OF 2015. THE APPELLANT SUBMITTED THAT TILL THE HON'BLE APEX COURT HEARS THE CASE AND PRONOUNCES ITS JUDGMENT, THE DECISION OF THE HON'BLE A.P. HIGH COURT HOLDS GOOD AND IS BINDING ON THE DEPARTMENT . H) THE APPELLANT SUBMITTED THAT THE ASSESSING OFFICER WAS NOT JUSTIFIED IN MAKING THE AFORESAID ADDITION OF RS.8,2 5 ,00,000/ - . I) THE APPELLANT SUBMITTED ANNUAL ACCOUNT FOR THE FY 2011 - 12. 7. AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESSEE, THE CIT(A) DELETED THE ADDITION MADE BY THE AO BY OBSERVING AS UNDER: 5 . 4 THE SUBMISSIONS OF THE APPELLANT HAVE BEEN CAREFULLY CONSIDERED. THE APPELLANT HAS TA KEN INTEREST FREE LOAN FROM ITS RELATED COM PA NY. THE ASSESSING OFFICER H AS RAISED THE ISSUE OF DEEMED DIVIDEND IN THIS CASE. THE ASSESSING OFFICER FOUND THAT APPELLANT HAS TAKEN LOAN OF RS.8,2 5 ,00,000 / - FROM MIS. RADIANT - RSCC SPECIALTY CABLE (P) LTD. HOWEVER, THE ASSESSING OFFICER IS INCORRECTLY I NVOKED THE PROVISIONS 2(2)(E) WHERE THE APPELLANT IS NOT PAYING INTEREST. IF AT ALL, 2(22)(E) HAS TO I.T.A. NO. 111 /HYD/1 8 ASTHA STERLING CRANE PVT. LTD., HYD. 7 BE RAISED, IT IS TO BE RAISED IN THE HANDS OF M/S .RADIANT - RSCC SPECIALTY CABLE (P) LTD NOT IN THE HANDS OF THE APPELLANT'S CASE. THE ADDITION IS DISMISSED . 8. CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL ON RECORD . WE NOTICED THAT ASSESSEE HAS TAKEN LOAN/ADVANCE FROM M/S RADIANT - RSCC SPECIALITY CABLE (P) LTD. AS OBSERVED BY THE AO, THERE ARE COMMON SHAREHOLDERS IN BOTH THE COMPANIES, I.E. RA DIANT - RSCC AND ASSESSEE COMPANY. JUST BECAUSE, THERE ARE COMMON SHAREHOLDERS, ANY TRANSACTION BETWEEN TWO COMPANIES CANNOT BROUGHT UNDER DEEMED DIVIDEND. AO HAS TO ESTABLISH THAT SUCH TRANSACTIONS ARE FOR THE INDIVIDUAL BENEFIT OF SUCH SHAREHOLDERS. IF IT IS IN THE NATURE OF INTER CORPORATE TRANSACTIONS ON COMMERCIAL TERMS OR ON MUTUAL BENEFITS, THEN DEEMED DIVIDEND UNDER THE PROVISIONS OF SECTION 2(22)(E) ARE NOT ATTRACTED UNLESS IT IS ESTABLISHED THAT SUCH TRANSACTIONS ARE FOR THE INDIVIDUAL BENEFITS OF S UCH COMMON SHAREHOLDERS. AS PER THE PROVISIONS OF SECTION 2(22)(E), THE ADDITION CAN BE MADE IN THE HANDS OF SHAREHOLDERS AS THE TRANSACTIONS ARE CONSIDERED AS DEEMED DIVIDEND. SUCH TREATMENT OF DEEMED DIVIDEND CANNOT BE INVOKED IN THE HANDS OF UNREGISTERE D SHAREHOLDER. IN THE GIVEN CASE, THE AO CAN IF AT ALL HAS TO INVOKE DEEMED DIVIDEND PROVISIONS, HE CAN INVOKE ONLY IN THE HANDS OF COMMON SHAREHOLDERS NOT IN THE HANDS OF ASSESSEE. WE ARE NOT IN A POSITION TO ADJUDICATE ON MERIT OF INVOKING SECTION 2(22)( E), BUT, IT CANNOT BE INVOKED IN THE HANDS OF ASSESSEE, WHO IS NOT THE SHAREHOLDER AS PER PROVISIONS OF SECTION 2(22)(E) OF THE ACT. THEREFORE, WE ARE IN AGREEMENT WITH THE FINDINGS OF LD. CIT(A). HENCE, THE GROUND RAISED BY THE REVENUE IS DISMISSED. I.T.A. NO. 111 /HYD/1 8 ASTHA STERLING CRANE PVT. LTD., HYD. 8 11. AS REGARDS GROUND NO. (V) REGARDING DELETION OF DISALLOWANCE MADE U/S 43B TOWARDS PF AMOUNTING TO RS. 30,208/ - , DURING THE ASSESSMENT PROCEEDINGS, THE AO NOTICED THAT THE ASSESSEE HAD PAID THE CONTRIBUTION OF EMPLOYEES PROVIDENT FUND BEYOND THE DUE DAT E AS PRESCRIBED U/S 36(VI)(A) AMOUNTING TO RS. 30,208/ - AND, HENCE, THE SAME WAS DISALLOWED. 12. BEFORE THE CIT(A) THE ASSESS EE SUBMITTED THAT THE PAYMENT WAS MADE BEFORE THE DUE DATE FOR FILING OF THE RETURN OF INCOME UNDER SECTION 139(1) OF THE ACT, HENCE, THE SAME IS ALLOWABLE DEDUCTION U/S 43(B) OF THE ACT. FOR THIS PROPOSITION, IT RELIED ON VAR IOUS CASES INCLUDING THE DECISION OF CIT VS. ALOM EXTRUSIONS LD. [2009] 319 ITR 306 (SC). 13. AFTER CONSIDERING THE SUBMISSIONS AND RELYING ON THE DECISIONS, ON WHICH RELIANCE PLACED BY THE ASSESSEE, THE CIT(A) DELETED THE DISALLOWANCE ON THE GROUND THAT THE ASSESSEE PAID THE CONTRIBUTION BEFORE FILING OF THE RETURN OF INCOME, HENCE, THE SAME CANNOT BE DISALLOWED. 14. AGGRIEVED, THE REVENUE IS IN APPEAL BEFORE US. 15. CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL ON RECORD. THE HON'BLE SUPR EME COURT IN THE CASE OF CIT VS. ALOM EXTRUSIONS LTD. [2009] 319 ITR 306 (SC) HELD THAT THE AMENDMENTS TO SECTION 43 B BROUGHT OUT BY THE FINANCE ACT, 2003 WITH EFFECT FROM 01/04/2004 ARE RETROSPECTIVE IN NATURE AND WOULD OPERATE FROM 01/04/1988. VARIOUS BE NCHES OF ITAT AND COORDINATE BENCHES OF THIS TRIBUNAL HAVE FOLLOWED THE ABOVE DECISION AND HELD THAT THE AMENDMENT TO SECTION 43 B BROUGHT OUT BY THE FINANCE ACT, 2003 IS RETROSPECTIVE IN NATURE AND JUSTIFIED IN DELETING THE I.T.A. NO. 111 /HYD/1 8 ASTHA STERLING CRANE PVT. LTD., HYD. 9 ADDITIONS MADE ON ACCOUNT OF DEL AYED PAYMENT OF PROVIDENT FUND OF EMPLOYEES CONTRIBUTION. ACCORDINGLY, WE UPHOLD THE ORDER OF CIT(A) AND DISMISS THE GROUND RAISED BY THE REVENUE ON THIS ISSUE. 16. IN THE RESULT, APPEAL OF THE REVENUE IS DISMISSED. PRONOUNCED IN THE OPEN COURT ON 14 TH JUNE , 201 9. SD/ - ( P. MADHAVI DEVI ) JUDICIAL MEMBER SD/ - ( S. RIFAUR RAHMAN ) ACCOUNTANT MEMBER HYDERABAD, DATED 14 TH JUNE , 201 9. KV COPY FORWARDED TO: 1. DCIT , CIRCLE 1(1), 8 TH FLOOR, C - BLOCK, ROOM NO. 836, IT TOWERS, HYDERABAD 500 0 04 . 2 . M/S ASTHA STERLING CRANE PVT. LTD., B - 1, INDUSTRIAL ESTATE, SANATHNAGAR, HYDERABAD 500 018 3 . CIT (A) - 1 , HYDERABAD 4. PR. CIT - 1 , HYDERABAD 5. THE DR, ITAT, HYDERABAD 6. GUARD FILE