Dy.CIT, Circle-3(3), Hyderabad V. M/s Synergies Castings Limited, Hyderabad

ITA 117/HYD/2013

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 74648 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-02-2014
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2008-2009
• Appeal Filed On: 04-02-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: D SUDHAKAR RAODR
• Section: 43B; 10B

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B', HYDERABAD BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER ITA NO. ASSESSMENT YEAR APPELLANT RESPONDENT 2/HYD/2013 2008 - 09 M/ S.SYNERGIES CASTINGS LIMITED, HYDERABAD ( PAN - AAICS 7410 H ) DY. COMMISSIONER OF INCOME - TAX CIRCLE 3(3), HYDERABAD 117/HYD/2013 2008 - 09 DY. COMMISSIONER OF INCOME - TAX CIRCLE 3(3), HYDERABAD M/S.SYNERGIES CASTINGS LIMITED, HYDERABAD ( PAN - AAICS 7410 H ) APPELLANTS BY : SHRI P.V.S.S.PRASAD RESPONDENT BY : SHRI D.SUDHAKAR RAO DR - CIT DATE OF HEARING 26.2.2014 DATE OF PRONOUNCEMENT 26.2.2014 O R D E R PER SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER: THESE ARE CROSS APPEALS FO TREH ASSESSMENT YEAR 2008 - 09 AND THEY ARE DIRECTED AGAINST THE ORDER OF THE COMMISSIONER OF INCOME - TAX(APPEALS) IV, HYDERABAD DATED 19.11.2012. SINCE THE FACTUAL BACKGROUND AND THE ISSUES INVOLVED ARE COMMON, THESE APPEALS ARE B EIN G DISPOSED OF WITH THIS COMMON ORDER FOR THE SAKE OF CONVENIENCE. ASSESSEES APPEAL : ITA NO.2/HYD/2013 2. THE ONLY GRIEVANCE OF THE ASSESSEES IN THIS APPEAL RELATES TO LEGALITY AND VALIDITY OF THE REVISIONARY ORDERS UNDER S.263 OF THE ACT PASSED BY THE COMMISSIONER OF INCOME - TAX, AND THE EFFECTIVE GROUNDS OF THE ASSESSEE, COMMON IN THESE APPEALS, AS TAKEN FROM ITA NO.497/HYD/2013, READ AS FOLLOWS - ITA NO. 2 & 117 / HYD/20 13 M/S.SYNERGIES CASTINGS P. LIMITED, HYDERABAD 2 1. THE LEARNED CIT (A) IS ERRONEOUS IN LAW AND ON THE FACTS OF THE CASE. 2. (A) THE LEARNED CIT (A) IS NOT JUSTIFIED IN DENYING THE DEDUCTION OF RS.5,65,49,284/ - UNDER SECTION 10B OF THE IT ACT WHEN THE ELIGIBLE UNDERTAKING CLAIMING THE DEDUCTION REMAINED THE SAME. (B) THE LEARNED CIT (A) ERRED IN IGNORING THE FACT THAT THE APPELLANT IS SUCCESSOR OF THE UNDERTAKING AS CONFIRMED BY DEVELOPMENT COMMISSIONER VSEZ, MINISTRY OF COMMERCE AND INDUSTRY THROUGH TRANSFER ON LEASE BASIS, FOR CLAIMING SECTION 10B DEDUCTION. (C) THE LEARNED CIT (A) ERRED IN LAW IN NOT GRANTING THE TAX HOLIDAY IN THE HANDS OF THE APPELLANT THOUGH IT WAS ADMITTED BY LEARNED CIT (A) THAT THE UNIT WAS TRANSFERRED TO THE APPELLANT. (D) THE LEARNED CIT (A) HAVING COME TO A CONCLUSION THAT THE UNDERTAKING WAS TRANSFERRED TO THE APPELLANT IS NOT JUSTIFIED IN LAW IN IGNORING THE BOARD CI RCULAR NO.F.NO.15/5/63 - IT(A - 1) TO GRANT TAX HOLIDAY IN THE HANDS OF THE SUCCESSOR I.E. APPELLANT COMPANY. (E) THE LEARNED CIT (A) OUGHT TO HAVE APPRECIATED THE RESTRUCTURING PACKAGE APPROVED BY THE LENDERS WHICH RESULTED IN TRANSFER OF UNDERTAKING ON LEAS E BASIS TO THE APPELLANT COMPANY. (F) THE LEARNED CIT (A) OUGHT TO HAVE ALLOWED DEDUCTION UNDER SECTION 10B AS CLAIMED BY THE APPELLANT COMPANY 3. THE LEARNED AO/CIT HAS ERRED IN LEVYING INTEREST UNDER SECTION 234 B OF THE ACT ON ADDITIONAL INCOME ARISING DUE TO ITA NO. 2 & 117 / HYD/20 13 M/S.SYNERGIES CASTINGS P. LIMITED, HYDERABAD 3 DENIAL OF SEC.10B EXEMPTION BY COMPLETELY DISREGARDING THE PROVISIONS OF THE ACT AND THE JUDICIAL PRECEDENCE. 4. .. 3. WE HEARD BOTH SIDES AND PERUSED THE IMPUGNED ORDER OF THE REVENUE AUTHORITIES AND OTHER MATERIAL AVAILABLE ON RECORD. THE ONLY POINT IN DISPUTE IN THIS APPEAL RELATES TO DENIAL OF ASSESSEES CLAIM FOR EXEMPTION UNDER S.10B OF THE ACT. IT IS AN UNDISPUTED FACT THAT THIS VERY ISSUE CAME UP FOR CON S IDERATION BEFORE COORDINATE BENCH OF THIS TRIBUNAL IN ITA N O.864/ H YD/2010 FOR ASSESSMENT YEAR 2006 - 07 AND ITA NO.1364/HYD/2010 FOR ASSESSMENT YEAR 2007 - 08, AND CONSIDERING IDENTICAL GROUNDS RAISED BY THE ASSESSEE FOR THOSE YEARS, THE TRIBUNAL DECIDED THE ISSUE AGAINST THE ASSESSEE, CONFIRMING THE VIEW TAKEN BY THE REVENUE AUTHORITI ES. RELEVANT PORTION OF THE COPY OF THE SAID ORDER OF THE TRIBUNAL, DATED 18.3.2011, COPY OF WHICH IS FURNISHED BEFORE US, READS AS FOLLOWS - 6. WE HAVE CONSIDERED THE SUBMISSIONS OF THE RIVAL PARTIES AND PERUSED THE MATERIAL AVAILABLE ON RECORD. WE F IND FROM THE ORDER OF THE CIT [A] THAT, FOR THE ASSESSMENT YEAR 2006 - 07, THE ASSESSEE HAS MADE A MEAGER INVESTMENT OF RS.1,38,55,000/ - IN MACHINERY, WHEREAS THE SAME BUSINESS WAS BEING CARRIED OUT BY M/S SYNERGY DOORAY AUTOMATIC LIMITED WITH THE PLANT MACH INERY VALUE OF RS.125.55 CRORES AND THEREFORE, IT IS CLEAR THAT BUT FOR THIS PREMEDITATED ARRANGEMENT, IT WOULD NOT HAVE BEEN POSSIBLE FOR THE ASSESSEE COMPANY TO MANUFACTURE THE COMMODITY OF THIS KIND AND THEREFORE IT IS ONLY WHEN SUCH AN INTEGRATED UNIT IS LAUNCHED THAT IT CAN BE SAID THAT THERE WAS NO SPITTING UP OF BUSINESS OR THERE WAS NO RE - CONSTRUCTION. IT IS HELD BY THE CIT (A) THAT ACCORDING TO HON'BLE APEX COURT THE INDUSTRIAL UNIT SET UP MUST BE NEW IN THE SENSE THAT NEW PLANTS AND MACHINERY ARE ERECTED FOR PRODUCING EITHER THE SAME COMMODITIES OR SOME DISTINCT COMMODITIES. IN THE CASE OF THE ASSESSEE HOWEVER, THERE IS NO NEW INTEGRATED UNIT WHICH IS CAPABLE ENOUGH TO CARRY OUT THE PRODUCTION OF THE GOODS AS HAVE BEEN CLAIMED AS MANUFACTURED AND E XPORTED BY IT. IT IS FURTHER HELD BY THE CIT (A) THAT THE DEVELOPMENT OR PRODUCTION OF COMPUTER SOFTWARE REQUIRES APPLICATION OF MIND AND CREATION OF 'ALGORITHMS' WHICH CAN BE DONE BY OUTSIDE AGENCIES ALSO AT THE INSTRUCTIONS ITA NO. 2 & 117 / HYD/20 13 M/S.SYNERGIES CASTINGS P. LIMITED, HYDERABAD 4 OF THE ORIGINAL MANUFACTURER. IN THE CASE OF MANUFACTURING OF ALUMINIUM ALLOY WHEELS, IT IS OF PLANT AND MACHINERY WHICH IS OF UTMOST IMPORTANCE FOR CARRYING OUT THE MANUFACTURE. BESIDES IT IS NOT THE CASE THAT IN ADDITION TO THE PRODUCTION CARRIED OUT ON ITS OWN, THE ASSESSEE HAD TAKE N THE ASSISTANCE OF PLANT AND MACHINERY BELONGING TO OTHERS FOR THE SAKE OF SOME ADDITIONAL PRODUCTIONS. 7. IN THE CASE UNDER CONSIDERATION, WE FIND THAT THERE WAS AN INDUSTRIAL UNDERTAKING OWNED BY M/S SYNERGY DOORAY AUTOMATIC LIMITED [SDAL] AND THE SAID COMPANY WAS ALLOWED DEDUCTION UNDER SECTION 10B OF THE ACT IN THE PROCEEDING ASSESSMENT YEARS. THE ASSESSMENT YEAR WITH WHICH WE ARE CONCERNED IN THE CASE UNDER CONSIDERATION IS ASSESSMENT YEARS 2006 - 07 AND 2007 - 09. IN THE PREVIOUS YEARS RELEVANT TO THE AS SESSMENT YEARS UNDER CONSIDERATION, THE ASSESSEE COMPANY TAKEN THE UNIT ON LEASE OR LICENSE FOR OPERATING AND MAINTAINING THE UNIT WITH FACILITIES OF MANUFACTURING OF ALUMINUM ALLOY WHEELS FROM SDAL AND CARRIED ON MANUFACTURING. THE ASSESSEE COMPANY CLAIME D CONTINUATION OF RELIEF UNDER SECTION 10B OF THE ACT FOR THE BALANCE UNEXPIRED PERIOD. IN OTHER WORDS, THE ASSESSEE COMPANY CLAIMED BENEFIT UNDER SECTION 10B OF THE ACT NOT ON THE BASIS OF THE ESTABLISHMENT OF NEW INDUSTRIAL UNDERTAKING, BUT ON THE BASIS OF THE LEASE ARRANGEMENT BETWEEN THE ASSESSEE COMPANY WITH SDAL. WE AGREE THAT THE CIRCULAR ISSUED BY THE CBDT VIDE NO.F.NO.15/5/63 - IT[AI], IS WITH THE VIEW THAT THE BENEFIT UNDER SECTION 10B [IN CIRCULAR IT WAS FOR SECTION 80J OF THE ACT] OF THE ACT ATTAC HES TO THE UNDERTAKING AND NOT TO THE OWNER THEREOF AND THEREFORE, A SUCCESSOR TO THE BUSINESS WOULD BE ENTITLED TO THE BENEFITS FOR THE BALANCE UNEXPIRED PERIOD. HENCE, IN ORDER TO GET THE BENEFIT OF SECTION 10B OF THE ACT, FOR THE UNEXPIRED PERIOD, THE A SSESSEE COMPANY MUST PROVE THAT IT IS A SUCCESSOR TO THE PREDECESSOR WHO WAS ENJOYING THE BENEFIT OF SECTION 10B OF THE ACT. BUT, ACCORDING TO THE FACTS OF INSTANT CASE, THE ASSESSEE COMPANY IS ONLY A LESSEE, HAVING A RIGHT TO ENJOY THE PLANT AND MACHINERY . OWNING THE PLANT AND MACHINERY AND TAKING PLANT AND MACHINERY ON LEASE ARE TWO DIFFERENT THINGS. OWNERSHIP IS A BUNDLE OF RIGHTS. LEASE - HOLD RIGHTS ARE A PART OF BUNDLE OF RIGHTS IN THE OWNERSHIP. IN THE CASE BEFORE US, THE ASSESSEE COMPANY IS NOT A SUCC ESSOR TO THE LESSOR. IN ORDER TO DECIDE THE ELIGIBILITY OF THE ASSESSEE COMPANY TO CLAIM UNDER SECTION 10B OF THE ACT, IT IS REQUIRED TO BE SEEN THAT WHETHER THE UNDERTAKING TRANSFERRED TO THE ASSESSEE COMPANY, ON LEASE BASIS, CAN BE SAID TO BE A NEW UNDER TAKING. IT IS CLEAR THAT, ON READING OF SECTION 10B OF THE ACT, THE EXEMPTION IS APPLICABLE ONLY TO AN ABSOLUTELY NEW UNDERTAKING STARTED FOR THE FIRST TIME. UNLESS THE ASSESSEE WHO CLAIMS THE BENEFIT UNDER SECTION 10B OF THE ACT FOR THE UNEXPIRED PERIOD, ESTABLISHES ITA NO. 2 & 117 / HYD/20 13 M/S.SYNERGIES CASTINGS P. LIMITED, HYDERABAD 5 THAT IT IS A SUCCESSOR OF A LESSOR, AND IT FULFILLS ALL OTHER NECESSARY CONDITIONS IN EACH YEAR, IT CANNOT CLAIM OF BENEFIT UNDER SECTION 10B OF THE ACT FOR THE BALANCE UNEXPIRED PERIOD. APPROVALS AND PERMISSIONS GIVEN BY THE CONCERNED DEVLOPME NT COMMISSIONER ON RESTRUCTURING PACKAGE ARE ALL IN THE CONTEXT OF BONDING, DE - BONDING OF THE UNIT, CENTRAL EXCISE AND CUSTOM DUTY FORMALITIES, ETC AND IT IS NOTING TO DO WITH THE EXEMPTION UNDER SECTION 10B OF THE INCOME TAX ACT. WE DO NOT SEE ANY MERIT I N THE ARGUMENTS OF THE LEARNED COUNSEL FOR THE ASSESSEE THAT UNDER SECTION 10B OF THE ACT, IT IS NOT NECESSARY THAT THE MANUFACTURING ACTIVITY HAS TO BE CARRIED ON BY THE ASSESSEE HIMSELF BY USING HIS OWN PLANT AND MACHINERY. IF THE ARGUMENTS OF THE LEARNE D COUNSEL FOR THE ASSESSEE ARE TO BE TAKEN AS CORRECT, THEN THERE IS NO LOGIC OR PURPOSE TO HAVE SUB - SECTION 2 OF SECTION 10B OF THE ACT IN THE STATUE BOOK AND THE CONDITIONS LAID DOWN THERE UNDER. THE ARRANGEMENTS ENTERED BY THE ASSESSEE COMPANY IS TO BE HELD IN THE NATURE OF A DEVICE ADOPTED BY IT TO AVOID THE APPLICATION OF THE PROVISIONS OF SUB - SECTION 2 TO SECTION 10B OF THE ACT AND RELEVANT APPLICABLE EXPLANATIONS. THE DECISION RELIED ON BY THE LEARNED COUNSEL FOR THE ASSESSEE IN THE CASE OF ITO VS. TECHDRIVE [SUPRA]; WE FIND THAT THE ASSESSEE WAS IN THE BUSINESS OF EXPORT OF SOFTWARE AND ALSO HAD ITS OWN COMPUTERS AND LAPTOP COMPUTERS, FOR DOING THE INTEGRATION OF THE COMPONENT PROGRAMMES DEVELOPED BY THE OTHER COMPANY. IN THE CASE OF TO VS. HEARTLAN D K.G. [SUPRA], RELIED ON BY THE LEARNED COUNSEL FOR THE ASSESSEE, IN THAT CASE, THE ASSESSEE ACQUIRED ASSETS FROM ANOTHER COMPANY AND THERE WERE NO LEASE ARRANGEMENTS. IN THE CASE OF CIT VS. NARANG DAIRY PRODUCTS [SUPRA] RELIED ON BY THE LEARNED COUNSEL F OR THE ASSESSEE, IN THAT CASE, THE ASSESSEE CLAIMED DEVELOPMENT REBATE AND THE APEX COURT HELD THAT WITHDRAWAL OF DEVELOPMENT REBATE BY THE ASSESSING OFFICER RELYING ON SECTION 34(3)(B) OF THE ACT IS JUSTIFIED BY INTERPRETING THE CRUCIAL WORDS 'OTHERWISE T RANSFERRED' OCCURRING IN SECTION 34(3)(B) OF THE ACT. ALL THE DECISIONS RELIED ON BY THE ASSESSEE LEARNED COUNSEL FOR THE ASSESSEE ARE DISTINGUISHABLE ON FACTS. AFTER CONSIDERING THE TOTALITY OF FACTS AND THE CIRCUMSTANCES OF THE CASE AND GOING THROUGH THE ORDERS OF THE AUTHORITIES BELOW, WE FIND THAT THE CIT (A) IS PERFECTLY JUSTIFIED IN UPHOLDING THE FINDINGS OF THE ASSESSING OFFICER IN DENYING THE CLAIM OF EXEMPTION UNDER SECTION 10B OF THE ACT FOR THE ASSESSMENT YEARS UNDER CONSIDERATION. THEREFORE, NO INTERFERENCE IS CALLED FOR. FACTS AND CIRCUMSTANCES OF THE CASE BEING IDENTICAL FOR THE YEAR UNDER APPEAL AS WELL, FOR THE DETAILED REASONS DISCUSSED IN THE ABOVE ORDER OF THE TRIBUNAL, WE FIND NO INFIRMITY IN THE IMPUGNED ORDER OF THE REVENUE AUTHORITIES . WE ITA NO. 2 & 117 / HYD/20 13 M/S.SYNERGIES CASTINGS P. LIMITED, HYDERABAD 6 ACCORDINGLY UPHOLD THE SAME, REJECTING THE GROUNDS OF THE ASSESSEE IN THIS APPEAL. 4. IN THE RESULT, ASSESSEES APPEAL, ITA NO.2/HYD/2013, IS DISMISSED. REVENUE S APPEAL : ITA NO. 117 /HYD/2013 5. THE ONLY EFFECTIVE GROUND FO THE REVENUE IN THIS APPEAL READS AS FOLLOWS - 1. . 2. THE LEARNED CIT(A) ERRED IN HOL D IN G TH A T ASSESSEES CONTRIBUTION TOWARDS EPF & ESI AREA ALLOWABLE AS DEDUCTION, IF THE SAME ARE PAID WITHIN THE DUE DATE FOR FILIN G RETURN OF INCOME OBLIVIOUS OF THE FACT THAT THE RELE V ANT DUE DATE AS SPECIFIED U/S. 36(1)(VA) FOR REMITTANCE OF EMPLOYEES CONTRIB U TION IS THE DUE DATE IN THE RELEVANT FUND AND ARE NO T G OVERNED BY THE P R O VI SION S OF SECTION 43B SO AS TO EQUATE EMPLOYEES CONTRIBUTION WITH EMPLOY E RS CONT RIBUTION. 3. . 6. WE HEARD BOTH SIDES AND PERUSED THE IMPUGN E D ORDERS OF THE R E VENUE AUTHORITIES. THE ONLY ISSUE IN DISPUTE RELATES TO DISALLOWANCE OF EPF AND ESI CONTRIBUTIONS, ON ACCOUNT OF DELAYED REMITTANCES, IN TERMS OF S.43B OF THE ACT. WE FI ND THAT THE IMPUGNED ORDER OF THE CIT(A) ON THIS ISSUE IS BASED ON THE DECISIONS OF THE TRIBUNAL IN ACIT V/S. SHAKTI BHOG FOODS P. LTD.(ITA NO.2777 TO 2781.DEL/2010 DATED 28.6.2011), WHICH IN TURN FOLLOWED THE DECISIONS OF THE DELHI HIGH COURT IN CIT V/S. AIMIL LIMITED (321 ITR 508) AND OF THE SUPREME COURT IN THE CASE OF CITV/S. VINAY CEMENTS LTD.(213 CTR 268) . FURTHER, THE LEARNED COUNSEL FOR THE ASSESSEE HAS RELIED ON THE FOLLOWING DECISIONS BEFORE US, IN SUPPORT OF THE CLAIM OF THE ASSESSEE - ( A ) CIT JAIP UR II, JAIPUR VS. JAIPUR VIDYUT VITARAN NIGAM LTD. AND OTHERS (INCOME - TAX APPEAL NO.278/2011) - RAJ HC ( B ) CIT V/S/ MARK AUTO INDUSTRIES LTD. (2013) 40 TAXMANN.COM 482(P&H) ( C ) CIT FARIDABAD V./S. HEMLA EMBROIDERY MILLS (P)LTD. (2013) 37 TAXMANN.COM 160(P&H) ITA NO. 2 & 117 / HYD/20 13 M/S.SYNERGIES CASTINGS P. LIMITED, HYDERABAD 7 ( D ) NUCHEM LTD. V/S. INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH (2013) 40 TAXMANN.COM 371) - P&H THOUGH THE LEARNED DEPARTMENTAL REPRESENTATIVE RELIED UPON THE RECENT DECISION OF THE HONBLE GUJARAT HIGH COURT IN THE CASE OF GUJARAT STATE ROAD TRANSPORT CORPORAT ION IN TAX APPEAL N O.637 OF 2013, WHEREIN VIDE ITS JUDGMENT DATED 26.12.2013, THE HONBLE HIGH COURT AFTER CONSIDERING AT LENGTH THIS ISSUE IN THE LIGHT OF VARIOUS DECISIONS OF APEX COURT AND OTHER COURTS, CONCLUDED THE ISSUE IN FAVOUR OF THE REVENUE, GOING BY THE RATIO OF THE DECISION OF THE APEX COURT IN THE CASE OF CIT V/S. VEGETABLE PRODUCTS LTD.(88 ITR 192), WHEREIN IT HAS BEEN HELD THAT IN THE EVENT OF ANY CLEAVAGE OF JUDICIAL OPINION, IT IS THE VIEW THAT IS IN FAVOUR OF THE ASSESSEE HAS TO BE P REFERRED, WE FIND NO INFIRMITY IN THE IMPUGNED ORDER OF THE CIT(A) . WE ACCORDINGLY UPHOLD THE IMPUGNED ORDER OF THE CIT(A) AND REJECT THE GROUNDS OF THE REVENUE IN THIS APPEAL. 7 . IN THE RESULT, APPEAL OF THE REVENUE IS DISMISSED . 8. TO SUM UP, APPEA L OF THE ASSESSEE, BEING ITAT NO.2/HYD/2013, AS WELL AS THE APPEAL OF THE REVENUE, BEING ITA NO.117/HYD/2013, ARE DISMISSED . ORDER PRONOUNCED IN THE COURT AT THE CONCLUSION OF THE HEARING ON 26.2.2014 SD/ - SD/ - (CHANDRA POOJARI ) (ASHA VIJAYARAGHAVAN) ACCOUNTANT MEMBER JUDICIAL MEMBER DT/ - 26 TH FEBRUARY, 2014 COPY FORWARDED TO: 1. M/S.SYNERGIES CASTINGS LIMITED, C/O. M/S. PRASAD & PRASAD CHARTERED ACCOUNTANTS, FLAT NO.301 3RD FLOOR, M.J. TOWERS, ROAD NO.12, BANJARA HILLS, HYDERABAD - 34 2. DY. COMMISSIONER OF INCOME - TAX CIRCLE 3(3), HYDERABAD ITA NO. 2 & 117 / HYD/20 13 M/S.SYNERGIES CASTINGS P. LIMITED, HYDERABAD 8 3. COMMISSIONER OF INCOME - TAX IV, HYDERABAD 4. COMMISSIONER OF INCOME - TAX III 5. DEPARTMENTAL REPRESENTATIVE, ITAT, HYDERABAD. B.V.S