Appeal Details
Counselvise Citation
[2011] 140 COUNSELVISE.COM (IT) 51274 (ITAT-BANGALORE)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
10 month(s) 27 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
23-09-2011
Appeal Filed By
Assessee
Order Result
Partly Allowed
Bench Allotted
A
Next Hearing Date
19-09-2011
Assessment Year
2006-2007
Appeal Filed On
27-10-2010
Judgement Text
PAGE 1 OF 11 ITA NO.1175/BANG/2010 1 IN THE INCOME TAX APPELLATE TRIBUNAL, BANGALORE BENCH A BEFORE SHRI N K SAINI, ACCOUNTANT MEMBER AND SHRI GEORGE GEORGE K, J.M ITA NO.1175/BANG/2010 (ASSESSMENT YEAR 2006-07) SRI KAVERIPATTI RAGHUNATHAN KANNAN, NO.71, CENTRAL EXCISE LAYOUT, VIJAYANAGAR, BANGALORE-560 040. - APPELLANT PAN NO.AFOPK 5290B VS THE ADDL. COMMISSIONER OF INCOME-TAX, RANGE-2, BANGALORE. - RESPONDENT DATE OF HEARING : 19/09/2011 DATE OF PRONOUNCEMENT : /09/2011 APPELLANT BY : SHRI RAMASUBRAMANIYAN, C.A . RESPONDENT BY : SHRI PRATAP SINGH, ADDL. CIT ORD ER PER GEORGE GEORGE K : THIS APPEAL INSTITUTED BY THE ASSESSEE IS DIRECTE D AGAINST THE ORDER OF LEARNED CIT(A), BANGALORE DATE D 16/8/2010. THE ASST. YEAR CONCERNED IS 2006-07. 2. BRIEFLY STATED THE FACTS ARE AS FOLLOWS:- THE ASSESSEE IS AN INDIVIDUAL. HE IS ENGAGED IN THE BUSINESS OF FORMATION OF LAYOUT AND SALE OF SITES AS WELL AS CIVIL CONSTRUCTION. FOR THE CONCERNED ASST. YEAR, RETURN OF INCOME WAS PAGE 2 OF 11 ITA NO.1175/BANG/2010 2 FILED DISCLOSING A TOTAL INCOME OF RS. 55,86,130/-. THE ASSESSMENT WAS TAKEN UP FOR SCRUTINY BY ISSUANCE OF NOTICE U/S 1 43(2) OF THE ACT AND THE SCRUTINY ASSESSMENT WAS COMPLETED VIDE ORDER DATED 30.12.2008. IN COMPLETING THE SCRUTINY ASSESSMENT, THE AO DISALLOWED THE FOLLOWING EXPENDITURE UNDER THE PROV ISIONS OF SECTION 40A(IA) OF THE ACT:- PROVISION FOR EXPENSES RS.88,69,675/- PROVISION FOR EQUIPMENT HIRE CHARGES RS.26,37,925 /- LABOUR CHARGES RS.20,26,077/- COMMISSION RS. 5,49,000/- THE AO ALSO DISALLOWED BUSINESS PROMOTION EXPENSES AMOUNTING TO RS.31,16,464/-. 4. AGGRIEVED BY THE ASSESSMENT COMPLETED, THE ASSES SEE CARRIED THE MATTER IN APPEAL BEFORE THE FIRST APPEL LATE AUTHORITY, WHO DELETED THE DISALLOWANCE OF RS.88,69,675/-. THE CI T(A) HAS ALSO ALLOWED 50% OF THE BUSINESS PROMOTION EXPENSES AMOU NTING TO RS.15,58,232/- (TOTAL RS.31,16,464/-). THE CIT(A) CONFIRMED THE OTHER ADDITIONS MADE. 5. THE ASSESSEE, BEING AGGRIEVED, IS IN APPEAL BEF ORE US RAISING THE FOLLOWING GROUNDS:- I) THAT THE ORDER OF THE LEARNED CIT(A) IN SO FAR IT IS PREJUDICIAL TO THE INTERESTS OF THE APPELLANT IS BAD AND ERRONEOUS IN LAW AND AGAINST THE FACTS AND CIRCUMSTANCES OF THE CASE. II) THAT THE LEARNED AO ERRED IN LAW AND ON FACTS IN DISALLOWING EQUIPMENT HIRE CHARGES OF PAGE 3 OF 11 ITA NO.1175/BANG/2010 3 RS.26,37,925/- U/S 40A(IA) OF THE ACT THOUGH THE APPELLANT IS NOT REQUIRED TO DEDUCT TAX AT SOURCE ON EQUIPMENT HIRE CHARGES PAID/PAYABLE TO RESIDENT DURING FINANCIAL YEAR 2005-06. III) THAT THE LEARNED CIT(A) ERRED IN LAW AND ON FACTS IN DISALLOWING A SUM OF RS.15,58,232/- UNDER THE HEAD BUSINESS PROMOTION EXPENSES WITHOUT BRINGING ON RECORD ANY MATERIAL TO PROVE THAT THERE IS A PERSONAL ELEMENT IN THE BUSINESS PROMOTION EXPENSES INCURRED. IV) THAT THE LEARNED AO ERRED IN LAW AND ON FACTS IN DISALLOWING WEEKLY WAGES OF RS.20,26,077/- PAID TO WORKERS AS PAYMENT TO LABOUR CONTRACTORS U/S 40A(IA) OF THE ACT ON THE GROUND THAT THE APPELLANT HAS NOT DEDUCTED TAX AT SOURCE U/S 194C OF THE ACT. V) THAT THE LEARNED AO ERRED IN LAW AND ON FACTS IN HOLDING THAT THE APPELLANT IS LIABLE TO DEDUCT TAX AT SOURCE U/S 194C(2) EVEN THOUGH HE IS NOT LIABLE TO DEDUCT TAX AT SOURCE U/S 194C OF THE ACT. 6. EQUIPMENT HIRE CHARGE RS.26,37,925/- THE AO DISALLOWED EQUIPMENT HIRE CHARGES OF RS.26,37,925/- U/S 40A(IA) OF THE ACT ON THE GROUND THAT TAX HAS NOT BEEN DEDUCTED AT SOURCE U/S 194C OF THE ACT. IT WA S SUBMITTED BEFORE THE FIRST APPELLATE AUTHORITY THAT SECTION 19 4C DOES NOT APPLY TO PAYMENT OF EQUIPMENT HIRE CHARGES. FOR THIS PROP OSITION, THE ASSESSEE RELIED ON THE CIRCULAR NO.681 DATED 8 TH MARCH, 1994 AND ALSO RELIED ON THE DECISION OF THE TRIBUNAL IN DCIT V SA TISH AGGARWAL & CO. PAGE 4 OF 11 ITA NO.1175/BANG/2010 4 317 ITR (AT) 196. IT WAS SUBMITTED THAT THE SECTIO N 194I OF THE I T ACT IS APPLICABLE TO THE FACTS OF THIS CASE. IT WA S CONTENDED THAT SECTION 194I WAS AMENDED W.E.F. 13/07/2006 TO SPECI FICALLY INCLUDE IN ITS AMBIT, THE PAYMENT MADE FOR MACHINERY/EQUIPMENT H IRE. ACCORDINGLY IT WAS CONTENDED THAT THE PROVISIONS OF SECTION 194I OF THE ACT DID NOT APPLY FOR MACHINERY HIRE CHARGES PRI OR TO 13/7/2006. THEREFORE, IT WAS SUBMITTED THAT FOR THE RELEVANT A SST. YEAR, THERE IS NO DEFAULT ON THE PART OF THE ASSESSEE IN MAKING PA YMENT WITHOUT DEDUCTION OF TAX. ACCORDINGLY, THE DISALLOWANCE MAD E BY THE AO INVOKING THE PROVISIONS OF SECTION 40A(IA) IS BAD I N LAW AND LIABLE TO BE DELETED. 7. THE CIT(A) HELD THAT THE RELEVANT PROVISION FOR DEDUCTION OF TAX AT SOURCE IS 194I OF I T ACT. HE, HOWEVER, DISMISSED THE APPEAL OF THE ASSESSEE. THE RELEVANT FINDING OF THE CIT(A) IS REPRODUCED BELOW FOR READY REFERENCE:- 9.6 SO FAR PAYMENT OF RS.26,37,925/- TO DIFFERENT PERSONS ENUMERATED IN PARA 9.2 ABOVE AS RENT AND HIRE CHARGES OF JCB AND TIPPER, THE SAME FALLS UNDER SECTION 194I OF I T ACT COVERED UNDER GROUND NO.6 OF THE GROUNDS OF APPEAL. SINCE PAYMENT OF RS.26,37,925/- IS TREATED AS A PAYMENT U/S 194I OF I T ACT WHICH IS APPLICABLE TO INDIVIDUALS AND HUFS, WHOSE TOTAL TURNOVER OR SALE OR GROSS RECEIPTS FROM BUSINESS EXCEED THE MONETARY LIMITS SPECIFIED UNDER CLAUSE (A) OR (B) OF SEC.44AB W.E.F. 1.6.2002 (FA 2002), THE SAME IS HELD HEREWITH AS COVERED U/S 40(A)(IA) OF I T ACT UNDER THE HEAD RENT. ADMITTEDLY NO TAX HAD BEEN DEDUCTED AT SOURCE FROM SUCH PAYMENT OF RENT. PAGE 5 OF 11 ITA NO.1175/BANG/2010 5 HENCE, I FIND JUSTIFIED TO CONFIRM THE ADDITION. GROUND NO.6 IS DISMISSED. 8. THE ASSESSEE BEING AGGRIEVED IS IN APPEAL BEFOR E US. 9. IT WAS CONTENDED THAT MACHINERY HIRE CHARGES WAS INCLUDED U/S 194I OF THE ACT W.E.F. 13/7/2006 AND S INCE THE CONCERNED ASST. YEAR IS 2006-07, THE ASSESSEE WAS NO T BOUND TO DEDUCT TAX AT SOURCE IN RESPECT OF PAYMENT MADE FOR MACHINERY HIRE CHARGES. FOR THE ABOVE PROPOSITION, THE ASSESSEE R ELIED ON THE DECISION OF THE HONBLE MADRAS HIGH COURT IN THE CA SE OF CIT V D RATHINAM 335 ITR 101. 10. WE HAVE HEARD THE RIVAL SUBMISSION AND PERUSED THE MATERIAL ON RECORD. THE CIT(A) IN HIS FINDING HAS CATEGORICALLY HELD THAT SECTION 194 I OF THE ACT IS APPLICABLE TO THE FACTS OF THIS CASE. DETAILS OF EQUIPMENT/MACHINERY HIRE CHARGES ARE LIST ED AT PAGE 4 OF THE ASSESSMENT ORDER. THE ASSESSEE HAD MADE PAYMENT OF RS.26,37,925/- FOR HIRING TIPPER AND JCB. THE HIRE CHARGES FOR MACHINERY/EQUIPMENT ARE SPECIFICALLY INCLUDED U/S 19 4I OF THE ACT W.E.F. 13/07/2006. THE RELEVANT ASST. YEAR BEING 20 06-07, THERE IS NO SCOPE TO FIND FAULT WITH THE ASSESSEE IN NOT DED UCTING TAX AT SOURCE ON THESE PAYMENTS MADE. HENCE, THE DISALLOW ANCE MADE BY THE AO AND SUSTAINED BY THE FIRST APPELLATE AUTHORIT Y IS NOT SUSTAINABLE IN LAW AND WE DELETE THE SAME. IN TAK ING THE ABOVE VIEW, WE ARE FORTIFIED BY THE JUDGEMENT OF HONBLE MADRAS HIGH COURT CITED SUPRA. PAGE 6 OF 11 ITA NO.1175/BANG/2010 6 10.1 IN THE RESULT, GROUND NO. 2 MENTIONED ABOVE I S ALLOWED. 11. BUSINESS PROMOTION EXPENSES THE ASSESSEE HAD TRAVELLED TO PLACES LIKE UAE, CO LOMBO AND KOLKATA. THE BOARDING AND LODGING CHARGES AMOU NTED TO RS.12,60,194/-. THE TRAVELLING AND OTHER CHARGES AM OUNTED TO RS.18,56,269/- THE TOTAL OF THE ABOVE EXPENDITURE A MOUNTING TO RS.31,16,464/- WAS CLAIMED AS A DEDUCTION UNDER BU SINESS PROMOTION EXPENSES. THE ASSESSEE WAS DIRECTED TO PROVE THAT THE JOURNEY UNDERTAKEN WAS FOR THE PURPOSES OF BUSINESS. IT WA S SUBMITTED THAT THE ASSESSEE HAD UNDERTAKEN THESE FOREIGN TRIPS IN ORDER TO PROMOTE THE VARIOUS PROJECTS AND THESE TRIPS HELPED THE ASS ESSEE TO SELL HIS SITES AT NELAMANGALA HUSKAR PROJECT WHICH WAS REMAI NING UNSOLD FOR A LONG TIME. IT WAS SUBMITTED THAT THE SITES SOLD DU RING THE YEAR WAS 42 IN NUMBER FOR A TURNOVER OF RS.1,32,79,992/-. I T WAS FURTHER SUBMITTED THAT MAJORITY OF THESE SITES WERE SOLD AND REGISTERED TO THE NRIS WITH WHOM THE ASSESSEE HAD DISCUSSIONS AND THE SAME IS EVIDENT FROM THE INCREASE IN THE SALE OF SITES DURI NG THE CONCERNED ASST. YEAR COMPARED TO PREVIOUS ASST. YEARS. THEREFOR E, IT WAS CONTENDED THAT THE EXPENDITURE OF RS.31,16,464/- WA S INCURRED FOR MARKETING OF THESE SITES AND IS ALLOWABLE BUSINESS EXPENDITURE. THE AO, HOWEVER, DISALLOWED THE ENTIRE BUSINESS PROMOTI ON EXPENSES AMOUNTING TO RS.31,16,464/- BY HOLDING THUS:- THE ASSESSEES REPRESENTATIVE COULD PRODUCE ONLY LEDGER A/C EXTRACTS OF THE BOOKS OF ACCOUNTS. THE ASSESSEE ALSO FAILS TO PRODUCE A SINGLE SALE OF SIT E SOLD TO A NON RESIDENT INDIAN AND FOREIGN EXCHANGE PAGE 7 OF 11 ITA NO.1175/BANG/2010 7 BROUGHT AS SALES. IT IS ALSO STATED THAT THE EXPENDITURE DEBITED DOES NOT BELONG TO THIS PROJECT AND BELONGED TOI K R KANNAN ENCLAVE. 11.2 AGGRIEVED BY THE DISALLOWANCE OF BUSINESS PROM OTION EXPENSES, THE ASSESSEE CARRIED THE MATTER IN APPEAL BEFORE THE FIRST APPELLATE AUTHORITY. 11.3 SAMPLE COPIES OF AGREEMENT OF SALE, THE LIST OF THE PURCHASERS TO WHOM THE SITES WERE SOLD, WERE ALSO F ILED. THE DETAILS OF THE TRIPS MADE TO ABROAD WITH PROOF OF TRAVELLIN G AND BOARDING EXPENDITURE WERE ALSO FURNISHED. IT WAS CONTENDED THAT THE EXPENDITURE INCURRED WERE FOR THE PURPOSE OF SELLIN G THE SITES IN NELAMANGALA HUSKUR PROJECT AND THE SITES WERE MAINL Y SOLD TO NRIS SOLELY BECAUSE OF THE MARKETING DONE BY THE ASSESSEE IN THE COUNTRIES SUCH AS COLOMBO AND DUBAI. 11.4 THE FIRST APPELLATE AUTHORITY LIMITED THE DIS ALLOWANCE TO RS.15,58,232/- AND THE BALANCE WAS CONFIRMED. THE RELEVANT FINDING AT PARA 10.2 OF THE CIT(A)S ORDER IS REPRODUCED BE LOW:- 10.2 I HAVE CONSIDERED THE ABOVE. LEGALLY, THE APPELLANT IS NOT REQUIRED TO SHOW ANY DIRECT NEXUS BETWEEN THE TRIPS TO THE UAE/COLOMBO/KOLKATA IN ONE HAND AND THE BUSINESS OF DEVELOPMENT AND SALE OF PROPERTY SO AS TO BE COVERED UNDER THE PRINCIPLES OF COMMERCIAL EXPEDIENCY. IT IS ENOUGH IF SOME CONNECTION IS ESTABLISHED. I FIND THE PROPERTIES WERE NOT SOLD IN THE LAST THREE YEARS. THE TRIPS TO UAE/COLOMBO AND KOLKATA HAD HELPED PAGE 8 OF 11 ITA NO.1175/BANG/2010 8 IN SELLING THE PROPERTIES. OUT OF 19 PURCHASERS, 1 8 ARE FOREIGNERS, BASED IN UAE/SAUDI ARABIA AND ONE IS ONLY FROM BARODA WHICH ITSELF WOULD HAVE JUSTIFIED THE TRIPS SHOWING THE CONNECTION THAT TRAVEL WAS FOR BUSINESS PURPOSE. BUT TO HOLD THAT THE TRIPS HAVE NO ELEMENT OF PLEASURE AND ALL FOR BUSINESS WOULD BE A WHITE LIE ESPECIALLY IN THE FAC E OF NON-PRODUCTION OF DETAILED EXPENDITURE ON THE PLACES VISITED, DATE OF VISIT, PERSONS WITH WHOM TH E MEETINGS WERE HELD, SPECIFIC EXPENDITURE INCURRED IN SUCH MEETING, ETC. THEREFORE, THE ALLOWANCE IS LIMITED TO RS.15,58,232/- AND ADDITION OF RS.15,58,232/- IS CONFIRMED. APPEAL IS ALLOWED PARTLY ON THIS GROUND. 11.5 THE ASSESSEE, BEING AGGRIEVED, IS IN APPEAL B EFORE US. 11.6 THE LEARNED AR REITERATED THE SUBMISSIONS MAD E BEFORE THE INCOME TAX AUTHORITIES WHEREAS THE LEARNED DR R ELIED ON THE FINDINGS OF THE AO. 11.7 WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUS ED THE MATERIAL ON RECORD. THE CIT(A) HAS HELD THAT THE TRIPS TO UAE AND COLOMBO HAS HELPED TO SELL THE PROPERTIES OF THE AS SESSEE, WHICH WAS REMAINING UNSOLD IN THE PREVIOUS ASST. YEARS. IT IS ALSO FOUND BY THE CIT(A) THAT OUT OF THE 19 PURCHASERS, 18 ARE FOREIG NERS, BASED IN UAE/SAUDI ARABIA AND ONLY ONE PURCHASER IS FROM BARO DA. WE FIND THAT THE TRIPS ARE ALSO UNDERTAKEN TO COLOMBO AND K OLKATA AND IN ABSENCE OF DETAILED EXPENDITURE ON THE PLACES VISIT ED, DATE OF VISIT, PERSONS WITH WHOM THE MEETINGS WERE HELD, WE ARE OF THE VIEW THAT THE CIT(A) IS JUSTIFIED IN DISALLOWING A PORTION OF THE EXPENDITURE. PAGE 9 OF 11 ITA NO.1175/BANG/2010 9 HOWEVER, THE CIT(A), HAVING FOUND THAT THE FOREIGN TRIPS HAVE HELPED THE ASSESSEE IN SELLING THE LARGE NUMBER OF SITES I N THE CONCERNED ASST. YEAR, OUGHT NOT TO HAVE DISALLOWED 50% OF THE TOTAL CLAIM. THE DISALLOWANCE OF 50% OF THE CLAIM IS ON HIGHER SIDE. IN ORDER TO MEET THE END OF JUSTICE, WE LIMIT THE DISALLOWANCE TO 25 % OF THE TOTAL CLAIM. HENCE, THE ADDITION SUSTAINED IS RS.7,79,11 6/-. 11.8 IN THE RESULT, GROUND NO.3 IS PARTLY ALLOWED. 12. LABOUR CHARGES AND DEVELOPMENT EXPENDITURE THE ASSESSEE CARRIED OUT LAY-OUT FORMATION WORK FO R DUO ASSOCIATES. THE CASE OF THE ASSESSEE IS THAT HE HA D ENGAGED LABOURERS TO CARRY OUT THE WORK. THE ASSESSEE HAD PAID LABOUR CHARGES TO SITE SUPERVISORS WHO MONITORED THE WORK AND THE SITE SUPERVISORS DISTRIBUTED THE WAGES TO THE LABOURS EM PLOYED AT SITE. THE AO HELD THAT THE PAYMENTS ARE MADE TO LABOUR CON TRACTORS AND AS TAX HAS NOT BEEN DEDUCTED AT SOURCE, THE LABOUR CHARGES OF RS.20,26,077/- AND DEVELOPMENT EXPENDITURE OF RS.3, 44,850/- ARE DISALLOWED U/S 40A(IA) OF THE ACT. 12.1 AGGRIEVED BY THE DISALLOWANCE MADE UNDER THE P ROVISIONS OF SECTION 40A(IA), THE ASSESSEE CARRIED THE MATTER IN APPEAL BEFORE THE FIRST APPELLATE AUTHORITY. 12.2 IT WAS SUBMITTED THAT PAYMENTS WERE MADE TO TH E EMPLOYEES FOR DISTRIBUTION OF WAGES TO THE SITE LABO URS AND HENCE, IS NOT A PAYMENT TO THE SUB-CONTRACTORS. PAGE 10 OF 11 ITA NO.1175/BANG/2010 10 12.3 THE CIT(A) AFFIRMED THE ACTION OF THE AO VIDE PARA 9.5 OF HIS IMPUGNED ORDER, WHICH READS AS UNDER:- 9.5 HOWEVER, IF THE CONTRACTOR INDIVIDUAL OR HUF IS HAVING GROSS RECEIPTS/SALES/TURNOVER EXCEEDING THE LIMIT PRESCRIBED U/S 44AB OF THE I T ACT IS PAYING TO A SUB-CONTRACTOR PAYEE, IF OTHER CONDITIONS ARE FULFILLED, IS LIABLE TO DEDUCT TAX A T SOURCE UNDER PROVISO TO SEC.194C(2) OF I T ACT W.E.F. 1/6/2002 WHICH IS THE CASE HERE RELATING TO PAYMENT OF RS.20,26,077/- TO DIFFERENT INDIVIDUALS ENUMERATED IN PARA 9.1 ABOVE FOR CIVIL WORK. SINCE NO TDS HAS BEEN DEDUCTED FROM THE PAYMENTS MADE, THE SAME DESERVES TO BE TREATED AS INCOME OF THE APPELLANT U/S 40A(IA) OF I T ACT. HENCE, ADDITION OF RS.20,26,077/- IS CONFIRMED. GROUND NO.S 4 & 5 ARE DECIDED AGAINST THE APPELLANT. 12.4 AGGRIEVED, THE ASSESSEE IS IN APPEAL BEFORE U S. 12.5 IN THE COURSE OF HEARING, IT WAS FAIRLY CONCED ED THAT THE LABOURS EMPLOYED AT THE SITES ARE NOT ASSESSEES EMP LOYEES AND THEY WERE THE LABOURS OF THE SUPERVISORS WHOM THE ASSESS EE HAS TAKEN ON CONTRACT. THEREFORE, IT IS EVIDENT THAT THE SUPERV ISORS TO WHOM THE ASSESSEE HAD MADE THE PAYMENT ARE THE LABOUR CONTRAC TORS AND BY VIRTUE OF PROVISIONS OF SECTION 194C, THE ASSESSEE OUGHT TO HAVE DEDUCTED TAX AT SOURCE. HENCE WE ARE OF THE VIEW T HAT DISALLOWANCE OF LABOUR CHARGES AMOUNTING TO RS.20,26,077/- AND S ITE DEVELOPMENT CHARGES OF RS.3,44,850/- BY VIRTUE OF PROVISIONS OF SECTION 40A(IA) IS PERFECTLY IN ORDER AND JUSTIFIED. HENCE, WE UPHOLD THE ACTION OF THE INCOME TAX AUTHORITIES. PAGE 11 OF 11 ITA NO.1175/BANG/2010 11 12.6 IN THE RESULT, GROUND NOS.4 AND 5 ARE DISMISS ED. 13. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS PARTLY ALLOWED AS INDICATED ABOVE. THE ORDER PRONOUNCED ON THE 23 RD DAY OF SEPTEMBER, 2011 AT BANGALORE. SD/- SD/- (N K SAINI) (GEORGE GEORGE K) ACCOUNTANT MEMBER JUDICIAL MEMBER COPY TO : 1. THE REVENUE 2. THE ASSESSEE 3. THE C IT CONCERNED. 4. THE CIT(A) CONCERNED. 5. DR 6. GF MSP/ BY ORDER ASST. REGISTRAR, ITAT, BANGALORE.
Mehul