DCIT, Hyderabad V. Sri A.V.Surya Sastry, Hyderabad

ITA 1129/HYD/2013

• Counselvise Citation: [2016] 133 COUNSELVISE.COM (IT) 6019 (ITAT-HYDERABAD)
• Duration Of Justice: 2 year(s) 6 month(s) 22 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-02-2016
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: Not Allotted
• Next Hearing Date: 18-02-2016
• Assessment Year: 2009-2010
• Appeal Filed On: 01-08-2013
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: M SITARAM
• Assessee Lawyers: S RAMA RAO
• Keywords: Unexplained cash credit; Unexplained investment; Search and seizure; Salary income
• Section: 68; 69; 132

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES A : HYDERABAD BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER AND SHRI S.S. VISWANETRA RAVI, JUDICIAL MEMBER ITA.NO.1128 & 1129/HYD/2013 ASSESSMENT YEARS 2008-09 & 2009-10 THE DCIT, CENTRAL CIRCLE-3, HYDERABAD. VS. MR. V. SURYA SASTRY HYDERABAD. PAN AAVPV8373Q (APPELLANT) (RESPONDENT) FOR REVENUE : MR. M. SITARAM FOR ASSESSEE : MR. S. RAMA RAO DATE OF HEARING : 1 8 .02.2016 DATE OF PRONOUNCEMENT : 23 .02.2016 ORDER PER BENCH : THESE TWO ARE REVENUE APPEALS AGAINST THE SEPARATE ORDERS OF LD. CIT(A)-V, HYDERABAD DATED 28.03.2013. AT THE TIME OF HEARING, LD. D.R. ADMITT ED THAT GROUND NO.1 IN BOTH APPEALS DOES NOT PERTAIN TO THE FACTS OF THE CASE. THEREFORE, THE SAME WAS DISMISSED AS IRRELEVANT. 2. BRIEF FACTS LEADING TO THE PRESENT APPEALS ARE THAT ASSESSEE WAS COVERED UNDER SECTION 132 AS PART OF SEARCH AND SEIZURE OPERATION IN THE AMR GROUP, BEIN G CEO. ASSESSEE HAS ADMITTED CERTAIN INCOMES WHICH WA S FOLLOWED-UP BY FILING RETURNS OF INCOME AND PAYMENT OF TAXES IN THE IMPUGNED YEARS. SINCE, ASSESSEE BEING AN INDIVIDUAL AND HAS SALARY INCOME AS MAIN SOURCE, HE HAS NOT MAINTAINED BOOKS OF ACCOUNT AND AT THE TIME OF 2 ITA.NOS.1128 & 1129/H/2013 MR. V. SURYA SASTRY, HYDERABAD. SCRUTINY ASSESSMENT, ASSESSEE PREPARED CASH FLOW STATEMENT AND STATEMENT OF AFFAIRS (BALANCE SHEET). ON THE BASIS OF SUCH STATEMENTS, A.O. MADE CERTAIN ADDITIO NS WHICH LD. CIT(A) DELETED, HENCE THE PRESENT APPEALS BY REVENUE. 3. ONE COMMON GROUND IN BOTH ASSESSMENT YEARS IS THE ISSUE OF CREDITS (GROUND NO.2 IN BOTH THE ASSESSMENT YEARS). ASSESSEE HAS SHOWN CERTAIN ADVA NCES RECEIVED DURING THE YEAR AS RECOVERED AND SOME MORE AS OUTSTANDING AT THE END OF THE YEAR, WITHOUT EXAMINI NG THE NATURE OF SUCH RECEIPTS/YEAR OF RECEIPTS. A.O. HAS CONSIDERED BOTH AS INCOME OF UNEXPLAINED NATURE. TH E AMOUNT INVOLVED IN A.Y. 2008-09 WAS RS.7,50,000 AND IN A.Y. 2009-10 WAS RS.11,50,000. ON THE EXPLANATION O F ASSESSEE THE LD. CIT(A) HAS DELETED THE AMOUNTS. TH E ORDER OF LD. CIT(A) IN A.Y. 2008-09 IS AS UNDER : 5.3 HERE IT IS PERTINENT TO MENTION THAT THE ADDI TIONS SO MADE BY THE ASSESSING OFFICER ARE ALSO BASED ON SELF-MADE FLOW CHARTS AND THESE ADDITIONS DO NOT EMANATE FROM ANY SPECIFIC SEIZED MATERIAL. THE NEXT PART OF THE OBJECTION RAISED BY THE ASSESSING OFFIC ER IS THAT THE LOANS ARE GIVEN IN CASH. APPARENTLY ALL TH E LOANS/ADVANCES/AMOUNTS RECOVERED BACK ARE IN CASH. HOWEVER. AS SEEN FROM THE STATEMENT OF AFFAIR S FOR THE ASSESSMENT YEAR 2007-08. THE AMOUNT OF ADVANCES TO OTHERS IS A NEGATIVE FIGURE OF RS.50,00 0/- WHICH MEANS THAT THE APPELLANT IS TO RECEIVE RS.50.000/- FROM OTHERS. FOR THE NEXT YEAR, IT HAS GONE UP TO A POSITIVE FIGURE OF RS.3,50.000/- WHICH CORRESPONDS TO THE FIGURE OF RS. 4 LAKHS SHOWN AS ADVANCES RECOVERED. THEREFORE, THE LIABILITY SHOWN AT RS.3.5 LAKHS FOR THE YEAR INCLUDING THE OPENING NEGATIVE FIGURE OF RS.50.000/- CORRESPONDS TO THE RECEIPT OF LOAN RECOVERED AT RS.4 LAKHS AND THEIR REMAINS NO UNEXPLAINED CREDIT. ACCORDINGLY, THE ASSESSING OFFICER IS DIRECTED TO DELETE THE ADDITIO NS OF RS.3,50,000/- AND RS.4,00,000 MADE TOWARDS UNEXPLAINED CREDITS UNDER SECTION 68 OF THE ACT. 3 ITA.NOS.1128 & 1129/H/2013 MR. V. SURYA SASTRY, HYDERABAD. 4. ON HEARING THE BOTH PARTIES AND NOTICING THE RELEVANT CASH FLOW AND BALANCE SHEETS PLACED ON REC ORD, WHAT WE NOTICED IS THAT BOTH A.O. AND CIT(A) HAS ER RED IN THEIR ACTIONS. A.O. DID NOT EXAMINE WHETHER THE AMO UNTS OF ADVANCE SHOWN AS OUTSTANDING WAS RECEIVED DURING THE YEAR OR NOT. THE RECOVERIES WERE THERE BUT ASSESSEE SHOWN THEM AS ADVANCES IN EARLIER YEAR. THE ENTRIES IN CA SH FLOW DO NOT TALLY WITH THE STATEMENT OF AFFAIRS SHOWN. M OREOVER, THE STATEMENT SHOWN (-) RS.50,000 IN STATEMENT OF A FFAIRS. HOW A MINUS FIGURE CAN COME IN BALANCE SHEET COULD NOT BE EXPLAINED. THE LD. CIT(A) ALSO WITHOUT EXAMINING HAS DELETED THE AMOUNTS. LD. COUNSEL COULD NOT RECONCIL E THE AMOUNTS. A.O. ALSO HAS NOT LISTED THE AMOUNT OUTSTA NDING AS ON 01.03.2007 IN THE TABLE, WHICH SHOULD HAVE GI VEN A FAIR PICTURE OF OPENING FIGURE. THEREFORE, WE ARE O F THE OPINION THAT THIS ISSUE REQUIRE RE-EXAMINATION BY T HE A.O. IN DETAIL AFTER GIVING DUE OPPORTUNITY TO ASSESSEE TO EXPLAIN. WE MAKE IT CLEAR THAT A.O. SHOULD CONSIDER ONLY THE RECEIPTS DURING THE YEAR AND NOT THE OUTSTANDI NG AMOUNTS AT THE END OF THE YEAR. WITH THESE DIRECTI ONS, THE GROUNDS IN BOTH THE ASSESSMENT YEARS ARE CONSIDERED AS ALLOWED FOR STATISTICAL PURPOSES. 5. THE NEXT ISSUE IN A.Y. 2008-09 IS ABOUT ADVANCE RECEIVED FROM THE COMPANY TO AN EXTENT OF R S.34 LAKHS BY ASSESSEE. A.O. BROUGHT TO TAX THE SAME AS ADVANCE OF SALARY WHEREAS, LD. CIT(A) DELETED THE S AME ON THE REASON THAT THE SAME WAS RECOVERED FROM ASSESSE E AND SO TREATING THE SAME AS INCOME DOES NOT ARISE. 5.1. LD. D.R. RELIED ON THE PROVISIONS OF THE ACT TO TAX THE ADVANCE SALARY WHEREAS, LD. A.R. SUBMIT TED THAT THE AMOUNT, EVEN THOUGH CATEGORISED AS ADVANCE SALA RY, WAS IN FACT LOAN FROM THE COMPANY TO BE RECOVERED F ROM SALARY AND THE SAME WAS RECOVERED AT RS.2,00,000 PE R MONTH. 4 ITA.NOS.1128 & 1129/H/2013 MR. V. SURYA SASTRY, HYDERABAD. 5.2. ON CONSIDERING THE RIVAL SUBMISSIONS AND EXAMINING THE SO CALLED CASH FLOW AND STATEMENT OF AFFAIRS AND LEDGER COPIES PLACED ON RECORD, WE ARE OF THE O PINION THAT THIS ISSUE ALSO REQUIRES RE-EXAMINATION BY A.O . IN DETAIL. AS HELD BY THE CIT(A), IF THE AMOUNT IS ADV ANCE SALARY THE SAME IS TAXABLE IN THE YEAR OF RECEIPT A ND NECESSARY RELIEF HAS TO BE GIVEN TO THE EXTENT OF R ECOVERY FROM THE SALARY, SO THAT SAME AMOUNT IS NOT TAXED T WICE. IF THE AMOUNT IS LOAN, THEN AS SOURCE IS EXPLAINED THE SAME CAN NOT BE CONSIDERED AS UNEXPLAINED. HOWEVER, WHAT WE NOTICE FROM THE DOCUMENTS IS THAT THE RECEIPT IS NO T REFLECTED IN LEDGER COPY OF THE COMPANY PLACED ON R ECORD. IN THE CASH FLOW, THE AMOUNT WAS SHOWN AT RS.21,50, 000 ONLY. WHEN ENQUIRED, A.R. EXPLAINED THAT THE BALANC E AMOUNT WAS RECOVERED AND ONLY NET AMOUNT WAS SHOWN. ON FURTHER ENQUIRY, IT WAS EXPLAINED THAT APART FRO M RS. 2 LAKHS PER MONTH RECOVERY, FURTHER ADJUSTMENT WAS DO NE IN THE RUNNING ACCOUNT. SINCE THESE WERE NOT EXAMINED BY A.O. NOR BY LD. CIT(A), WE HAVE NO OPTION THAN TO S ET ASIDE FOR FRESH CONSIDERATION. IF THE AMOUNT WAS RE COVERED DURING THE YEAR AS CLAIMED ONLY, NET AMOUNT CAN BE BROUGHT TO TAX, AND NOT ENTIRE AMOUNT (OF RS.34 LAK HS AS WAS DONE BY A.O.) IF IT IS ADVANCE SALARY AND NO AD DITION CAN BE MADE, IF THE AMOUNT RECEIVED IS LOAN AND NOT ADVANCE OF SALARY. A.O. SHOULD EXAMINE THE NATURE O F AMOUNT AFTER GIVING DUE OPPORTUNITY TO ASSESSEE AND TO RECONCILE THE AMOUNTS REFLECTED IN STATEMENTS. FOR THIS PURPOSE THE GROUND IS CONSIDERED AS ALLOWED. 6. GROUND NO.3 IN A.Y. 2009-2010 IS ABOUT THE UNEXPLAINED CASH IN LIEU OF JEWELLERY BROUGHT TO TAX BY A.O. CONSEQUENT TO SEIZURE OF JEWELLERY FROM ASSESS EE PREMISES, ASSESSEE HAS DEPOSITED AN AMOUNT OF RS.25,00,000 FOR RELEASE OF JEWELLERY SEIZED. A.O. BROUGHT TO TAX THE CASH SUBSTITUTION AS UNEXPLAINED. BEFORE THE LD. CIT(A), ASSESSEE EXPLAINED THAT HE HAS TAKEN LO AN FROM MR. AUDINARAYANA REDDY OF AMRCL AND IN SUPPORT 5 ITA.NOS.1128 & 1129/H/2013 MR. V. SURYA SASTRY, HYDERABAD. FILED BANK STATEMENT OF M/S. AMRCL EVIDENCING BANKE R CHEQUES OF RS.13 AND RS.12 LAKHS WHICH WERE TAKEN O N 06.01.2009. LD. CIT(A) DELETED THE SAME BY STATING AS UNDER : 6.2. I HAVE GONE THROUGH THE ASSESSMENT ORDER, SUBMISSIONS OF THE APPELLANT AND THE EVIDENCES FILED. OUT OF THE TOTAL JEWELLERY OF RS.41,17,010/- FOUND DURING THE COURSE OF SEARCH, THE APPELLANT ADMITTED JEWELLERY VALUING RS.25 LAKH S AS MADE OUT OF UNEXPLAINED INCOME AND ACCORDINGLY INCLUDED RS/25 LAKHS AS UNEXPLAINED INCOME IN THE TOTAL INCOME OF RS.66,76,710/- FOR THE YEAR UNDER CONSIDERATION. HOWEVER, THE ASSESSING OFFICER QUESTIONED THE SOURCES FOR THE BANKER CHEQUES OF RS.25 LAKHS, SUBSTITUTED BY THE APPELLANT FOR UNEXPLAINED JEWELLERY DURING OPERATION OF PROHIBITO RY ORDERS. IT WAS SUBMITTED BY THE APPELLANT THAT THE AMOUNT OF RS.25 LAKHS WAS DRAWN FROM BANK ACCOUNT OF HIS EMPLOYER AND THE SAME WAS ADJUSTED AGAINST THE SALARY IN THE ENSUING MONTHS. BANK ACCOUNT COPY FURNISHED EVIDENCE THAT TWO BANKER CHEQUES, INTER- ALIA, WERE OBTAINED FOR RS.13 LAKHS AND RS.12 LAKHS . GOING BY THESE SUBMISSIONS AND EVIDENCES, THE SOURCES FOR SUBSTITUTED CASH IS EXPLAINED AND NO ADDITION ON THIS COUNT CALLED FOR. ACCORDINGLY, THE ASSESSING OFFICER IS DIRECTED TO DELETE THE ADDITIO N OF RS.25 LAKHS. 6.1. AFTER CONSIDERING THE RIVAL CONTENTIONS, WE D O NOT SEE ANY REASON TO DISTURB THE FINDING OF LD. CI T(A) EVEN THOUGH THE SAID TRANSACTION OF BORROWAL WAS NO T SPECIFICALLY SHOWN FROM MR A.REDDY/AMRCL IN THE CAS H FLOW STATEMENT. WHAT WE NOTICE IS THAT THE ASSESSE E HAS REFLECTED THE AMOUNT OF RS.25 LAKHS IN CASH FLOW STATEMENT AS INFLOW AND OUTFLOW. THEREFORE, THE GRO UND RAISED BY THE REVENUE IS NOT MAINTAINABLE ON FACTS. THE SAME IS REJECTED. 7. GROUND NO.4 IN A.Y. 2009-10 IS ABOUT AN AMOUNT OF RS. 30 LAKHS BROUGHT TO TAX IN A.Y. 2009- 10 ON 6 ITA.NOS.1128 & 1129/H/2013 MR. V. SURYA SASTRY, HYDERABAD. THE BASIS OF ADMISSION WHERE AS ASSESSEE HAS OFFERE D THE SAME IN A.Y. 2008-09. THE SAID AMOUNT WAS SEIZED FR OM THE LOCKER OF THE ASSESSEE AND ASSESSEE HAS ADMITTE D THE SAME DURING THE SEARCH ON THAT DAY. HOWEVER, WHILE FILING THE ROI, THE AMOUNT WAS OFFERED IN A.Y. 2008-09 AS THE SAID LOCKER WAS LAST OPERATED IN THE FINANCIAL YEAR RELEVANT FOR A.Y. 2008-09. A.O. HAS BROUGHT THE AMOUNT TO TA X IN A.Y. 2009-10 WHICH LD. CIT(A) DELETED STATING AS UN DER : 7.2. I HAVE GONE THROUGH THE ASSESSMENT ORDER, SUBMISSIONS OF THE APPELLANT AND THE EVIDENCES FILED. AS PER THE RETURN OF INCOME FILED BY THE APPELLANT FOR THE AY 2008-09, THE APPELLANT ADMITTED RS.30.00 LAKHS AS ADDITIONAL INCOME TOWARDS CASH FOUND. IN THE ASSESSMENT ORDER FOR AY 2008-09, IN PARA 1, THOUGH THE ASSESSING OFFICER DISCUSSED AT LENGTH ABOUT THE ADDITIONAL INCOME ADMITTED BY THE APPELLANT, IT IS INTRIGUING TO NOTE THAT NOWHERE IN THE ASSESSMENT THE ASSESSING OFFICER BROUGHT OUT THE NATURE OF ADDITIONAL INCOME ADMITTE D OR THE FINDINGS OF THE SEARCH THAT LED TO THE ADMIS SION OF TOTAL ADDITIONAL INCOME OF RS.36,72,656/- BY THE APPELLANT FOR THE AY 2008-09. GOING BY THE COMPUTATION OF INCOMES FOR AYS 2008-09 & 2009-10 AND THE AFFIDAVITS FILED BY THE APPELLANT BEFORE TH E WING DURING THE COURSE OF POST-SEARCH PROCEEDINGS, IT IS EVIDENT THAT THE APPELLANT, AS PER HIS ADMISSION , OFFERED RS.30 LAKHS AS ADDITIONAL INCOME FOR THE AY 2008-09. THOUGH THE PROVISIONS OF SECTION 69 SPEAK OTHERWISE REGARDING TAXING THE CASH / JEWELLERY FOU ND IN A PARTICULAR YEAR, GOING BY THE REASONS ADDUCED BY THE APPELLANT AND ALSO THE FACTS PERTAINING TO RECE IPT OF RS.30 LAKHS BY THE APPELLANT, THE OFFER MADE BY THE APPELLANT HOLDS GOOD AND THE AMOUNT OF RS.30 LAKHS CANNOT BE BROUGHT TO TAX AGAIN FOR THE SUBJECT ASSESSMENT YEAR. IF AT ALL THE PROVISIONS OF SECTIO N 69 HAD TO BE APPLIED SCRUPULOUSLY, THE ASSESSING OFFIC ER MAY REDUCE THE AMOUNT OF RS.30.00 LAKHS ADMITTED BY THE APPELLANT FOR THE A.Y. 2008-09 FROM THE TOTA L INCOME ADMITTED AND BRING THE SAME TO TAX FOR THE SUBJECT ASSESSMENT YEAR. 7 ITA.NOS.1128 & 1129/H/2013 MR. V. SURYA SASTRY, HYDERABAD. 7.1. ON CONSIDERING THE SUBMISSIONS AND EXAMINING THE FACTS, THERE IS NO DISPUTE THAT THE A MOUNT OF RS.30 LAKHS WAS OFFERED TO TAX. AS REGARDS THE Y EAR OF TAXATION, ASSESSEE HAS VALIDLY OFFERED IN A.Y. 2008 -09 AS THE LOCKER WAS LAST OPERATED IN THAT YEAR, BEFORE I T WAS OPENED DURING THE SEARCH, SO THE AMOUNT COULD HAVE BEEN EARNED IN THAT YEAR. WE DO NOT FIND ANY REASON TO D IFFER FROM THE FINDING OF THE LD. CIT(A). THIS BEING TAX NEUTRAL, NO ADVANTAGE IS ALSO FOUND IN BRINGING IT TO TAX IN THE YEAR OF SEIZURE. THE REVENUE GROUND IS ACCORDINGLY REJEC TED. 8. THE LAST GROUND NO.5 IN A.Y. 2009-10 IS ON THE DELETION OF AN AMOUNT OF RS.16,17,010 AS UNEXPLAINE D JEWELLERY. OUT OF THE JEWELLERY FOUND, ASSESSEE HAS ADMITTED AN AMOUNT OF RS. 25 LAKHS AS UNEXPLAINED A ND BALANCE OF RS.16,17,010 WAS TAKEN CREDIT/EXPLAINED AS BELONGING TO HIM AND HIS FAMILY MEMBERS AND SOURCES FROM PAST SAVINGS/THEIR SAVINGS. A.O. DID NOT ACCEP T THE EXPLANATION BUT THE LD. CIT(A) ACCEPTED AND DELETED BY STATING AS UNDER : 8.2. I HAVE GONE THROUGH THE ASSESSMENT ORDER AND THE SUBMISSIONS OF THE APPELLANT MADE DURING SEARCH, POST-SEARCH AND PRESENT APPEAL PROCEEDINGS, DURING THE SEARCH PROCEEDINGS ITSELF. THE APPELLANT HAD ADMITTED OVER 60% OF THE VALUE OF JEWELLERY AS UNEXPLAINED INVESTMENT. AS REGARDS THE BALANCE VALUE OF JEWELLERY OF RS.16,17 ,010/- THE CLAIM OF THE APPELLANT THAT GOING BY THE INCOME EARNING CAPACITY AND INCOMES ADMITTED OVER THE YEARS BY HIM, THE INVESTMENT CANNOT BE TREATED AS UNEXPLAINED, APPEARS TO BE REASONABLE. THE APPELLANT, AGED 55 YEARS, HAD HELD SENIOR MANAGERIA L POSITIONS IN PRESTIGIOUS COMPANIES SUCH AS ASHOK LEYLAND FINANCE LIMITED, ETC. BEFORE JOINING AMR GROUP AS CHIEF FINANCE OFFICER, AND HAD ADMITTED SUBSTANTIAL AMOUNTS AS SALARY, APART FROM ADMISSION OF UNDISCLOSED INCOMES. KEEPING ALL THESE FACTS IN VIEW, I DEEM IT PROPER TO CONSIDER THE BALANCE INVESTMENT IN JEWELLERY OF RS.16,17,010/- AS MADE 8 ITA.NOS.1128 & 1129/H/2013 MR. V. SURYA SASTRY, HYDERABAD. OUT OF EXPLAINED SOURCES. ACCORDINGLY, THE ASSESSIN G OFFICER IS DIRECTED TO DELETE THE ADDITION OF RS.16 , 17,010/-. 8.1. ON CONSIDERING THE SUBMISSIONS AND PERUSING THE ORDERS, WE DO NOT FIND ANY REASON TO INTERFERE WITH THE ORDER OF LD. CIT(A). IT WAS FAIRLY ADMITTED THAT TH E JEWELLERY WAS INVENTORISED AS BELONGING TO FAMILY M EMBERS ALSO. SO THERE IS NO JUSTIFICATION IN BRINGING TO T AX THE ABOVE AMOUNT IN ASSESSEE HANDS FULLY. EVEN OTHER WI SE ASSESSEE HAS ENOUGH PAST SAVING/INCOMES TO JUSTIFY THAT MUCH JEWELLERY. WE APPROVE THE ORDER OF CIT(A). THE GROUND IS ACCORDINGLY REJECTED. 9. IN THE RESULT, APPEAL IN A.Y. 2008-09 IS ALLOWE D FOR STATISTICAL PURPOSES. THE ORDER OF A.O. AND CIT (A) ON THE TWO ISSUES WERE SET ASIDE FOR FRESH EXAMINATION . THE APPEAL IN A.Y. 2009-10 IS PARTLY ALLOWED AND ORDER OF A.O. AND CIT(A) IS SET ASIDE ON THE ISSUE OF CREDITS (GR OUND NO.2) FOR RE-EXAMINATION AS DIRECTED ABOVE IN PARA- 4 ABOVE. ORDER PRONOUNCED IN THE OPEN COURT ON 23.0 2.2016. SD/- SD/- (S.S. VISWANETRA RAVI) (B. RAMAKOTAIAH) JUDICIAL MEMBER ACOUNTANT MEMBER HYDERABAD, DATED 23 RD FEBRUARY, 2016 VBP/- COPY TO : 1. THE DCIT, CENTRAL CIRCLE - 3, 8 TH FLOOR, AAYAKAR BHAVAN, BASHEERBAGH, HYDERABAD. 2. MR. V. SURYA SASTRY, 333/2RT, H.NO.7 - 1 - 621/405, 1 ST FLOOR, S.R. NAGAR, HYDERABAD. 3. CIT(A) - V, HYDERABAD. 4. CIT (CENTRAL), HYDERABAD. 5. D.R. ITAT A BENCH, HYDERABAD. 6. GUARD FILE