THE ACIT, Hyderabad V. M/s J.C.Brothers Jewellers, Hyderabad

ITA 1187/HYD/2009

• Counselvise Citation: [2011] 119 COUNSELVISE.COM (IT) 6619 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 6 month(s) 16 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-06-2011
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Next Hearing Date: 10-03-2011
• Assessment Year: 2006-2007
• Appeal Filed On: 14-12-2009
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Additional evidence; Capital expenditure
• Section: 143(3); 194C

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A, HYDERABAD BEFORE SHRI G.C.GUPTA, VICE PRESIDENT AND SHRI AKBER BASHA, ACCOUNTANT MEMBER ITA NO.1187/HYD/2009 : ASSESSMENT YEAR 2006 -07 ACIT, CIR-9(1), HYDERABAD. VS M/S. J.C. BROTHERS JEWELLERS, HYDERABAD. PAN: AAEFJ 8571 B (APPELLANT) (RESPONDENT) APPELLANT: SRI DIWAKAR PRA SAD RESPONDENT: SRI V. SIVA KUMAR O R D E R PER AKBER BASHA, AM :- THIS APPEAL FILED BY THE REVENUE IS DIRECTED AGAINST THE ORDER OF THE CIT (A)-VI, HYDERABAD DATED 27-10-2009 AND IT PERTAINS TO THE ASSESSMENT YEAR 2006-07. 2. GROUNDS RAISED BY THE REVENUE READ AS UNDER:- I. THE LEARNED CIT (A) ERRED ON FACTS AND IN LAW. II. THE CIT (A) ERRED IN ADMITTING INCOMPL ETE ADDITIONAL EVIDENCE IN THE FORM OF TDS CERTIFICATE AND CHALLAN WI TH REGARD TO ALLOWANCE OF RENT. III. THE CIT (A) ERRED IN DELETING THE ADDITION ON ACCOUNT OF RENT WITHOUT VERIFYING THE FACT THAT WHETHER TDS AMOUNT W AS ACTUALLY REMITTED TO THE GOVERNMENT ACCOUNT IN THE SAME PREVIOUS YEAR OR NOT. ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 2 IV. THE CIT (A) ERRED IN GRANTING RELIEF FOR ADVERTISEME NT EXPENDITURE OF RS.37,35,376/- THOUGH THE ASSESSEE DID NO T DEDUCT TDS ON THE SAME AS REQUIRED U/S 40(A)(IA). V. THE CIT (A) ERRED IN HOLDING THAT THE PROVISIONS OF T DS ARE NOT ATTRACTED ON PAYMENTS MADE BY THE ASSESSEE TO M/S. JEANS CORNER TOWARDS ADVERTISEMENT. VI. THE CIT (A) FAILED TO APPRECIATE THAT AS PER SECTION 40 (A) (IA), THE DEDUCTION OF TDS SHOULD BE DONE BY THE ASSESSEE OR IN THE NAME OF THE ASSESSEE BY ITS AGENT M/S JEANS CORNER AS THE AMOUNT IS BORNE BY THE ASSESSEE. VII. THE CIT (A) ERRED IN IGNORING THE SUBMISSION THAT 80% OF RS,28,60,035/- MET DIRECTLY BY THE ASSESSEE TOWARDS ADVERTISEMENT IS DISALLOWABLE, MORE SO WHEN THE ASSESSEE I N ITS LETTER DATED 24-3-2008 CLAIMED THAT ALL THE ADVER TISEMENT EXPENDITURE IS COMMON IN NATURE. VIII. THE CIT (A) OUGHT TO HAVE GIVEN OPPORTUNITY OF HEAR ING TO THE ASSESSING OFFICER BEFORE IGNORING THE SUBMISSION THAT 80% OF RS.28,60,035/- MET DIRECTLY BY THE ASSESSEE TOWARD S ADVERTISEMENT IS DISALLOWABLE. IX. THE CIT (A) ERRED IN GRANTING RELIEF FOR PAYMENT TO WARDS ELECTRICITY EXPENDITURE WITHOUT VERIFYING THE WATTAGE OF USAGE BETWEEN THE ASSESSEE AND M/S JEANS CORNER. X. ANY OTHER APPROPRIATE GROUND THAT MAY BE TAKEN AT T HE TIME OF HEARING. 2. GROUNDS NOS.1 AND 10 ARE GENERAL IN NATURE AND TH EY DO NOT REQUIRE ANY ADJUDICATION. ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 3 3. GROUND NOS. 2 AND 3 RELATE TO THE DISALLOWANCE OF RENT UNDER SECTION 40 A(IA) OF THE ACT. AT THE OUTSET, WE FIND TH AT THE CIT (A) HAS ADMITTED THE ADDITIONAL EVIDENCE FILED BY THE ASSESSEE, IN THE FORM OF TDS CERTIFICATE IN FORM NO.16A, FOR HAVING MADE THE TDS DEDUCTION IN RESPECT OF RENT PAYMENT OF RS.15,54,000/- AND THE ASSESSE E EXPLAINED BEFORE THE CIT (A) THAT THE ASSESSEE COULD NOT PRODUCE TH ESE EVIDENCES BEFORE THE ASSESSING OFFICER SINCE THE SAME WAS NOT CALLED FO R. THE CIT (A) ADMITTED THE ADDITIONAL EVIDENCE FILED BY THE ASSE SSEE AND AFTER OBTAINING A REMAND REPORT FROM THE ASSESSING OFFICER AN D AFTER VERIFYING THE DETAILS BY HIMSELF DIRECTED THE ASSESSING OFFICER TO DE LETE THE DISALLOWANCE OF RS.15,54,000/-. IN VIEW OF THIS, WE DO NOT SEE ANY INFIRMITY IN THE ORDER OF THE CIT (A) AND ACCORDINGLY THE SAME IS CONFIRMED. HENCE THE GROUNDS RAISED BY THE REVENUE ARE R EJECTED. 4. GROUND NOS. 4 TO 8 RELATE TO THE DISALLOWANCE OF EXPENDITURE ON ADVERTISEMENT OF RS.37,35,376/- UNDER SECTION 40A(IA) OF THE ACT. BRIEF FACTS OF THIS ISSUE ARE THAT THE ASSESSEE P AID ITS 20% SHARE OF ADVERTISEMENT EXPENDITURE WITH M/S JEANS CORNE R AMOUNTING TO RS.37,35,376/-. THE ASSESSING OFFICER OPINED THAT THE ASSE SSEE OUGHT TO HAVE DEDUCTED TDS ON SUCH PAYMENTS. SINCE, THERE WAS NO TDS DEDUCTION, THE ASSESSING OFFICER DISALLOWED THE SAID EXPEND ITURE UNDER SECTION 40A(IA) OF THE ACT. THE CIT (A) AFTER OBTAIN ING COMMENTS FROM THE ASSESSING OFFICER ON THE WRITTEN SUBMISSIONS FILED BY T HE ASSESSEE HELD THAT THE WORK OF ADVERTISEMENT IN FACT HAS BEEN CA RRIED OUT BY VARIOUS OUTSIDE ADVERTISING AND MARKETING AGENCIES AND NOT BY M/S JEANS CORNER. SINCE THE ASSESSEE HAS NOT PAID DIRECTLY TH E SAID AMOUNT OF RS.37,35,376/- FOR CARRYING OUT ANY WORK FROM THE OUTSIDERS, BUT THE SAME WAS CARRIED OUT BY M/S JEANS CORNER AND THE ASSESSEE INCURRED THE SAID EXPENDITURE TOWARDS REIMBURSEMENT AND SHARING OF ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 4 EXPENDITURE, THE CIT [A] HELD THAT THE PROVISIONS OF SECTION 40A (IA) ARE NOT ATTRACTED IN THE INSTANT CASE OF THE ASSESSEE. FOR TH E REASONS ELABORATELY MENTIONED IN HIS ORDER AT PAGES 14 AND 15 , HE DIRECTED THE ASSESSING OFFICER TO DELETE THE DISALLOWANCE MADE OF RS.37 ,35,376/- TOWARDS ADVERTISEMENT EXPENDITURE. AGGRIEVED AGAINS T THE FINDINGS OF THE CIT (A), THE REVENUE IS IN APPEAL BEFORE US. 5. THE LEARNED COUNSEL FOR THE ASSESSEE SUBMITTED THAT T HE ASSESSING OFFICER HELD THAT THE ASSESSEE OUGHT TO HAVE DEDUCT ED TAX AT SOURCE ON THE SHARED AMOUNT OF ADVERTISEMENT EXPENDITUR E AND SINCE TDS WAS NOT MADE BY THE ASSESSEE, HE DISALLOWED THE SHARED EXPENDITURE UNDER SECTION 40 A(IA) OF THE ACT. THE A SSESSEE FILED WRITTEN SUBMISSIONS BEFORE THE CIT (A) ON WHICH THE CI T (A) OBTAINED COMMENTS OF THE ASSESSING OFFICER AND AFTER CONSIDERING THE SAME, THE CIT (A) HELD THAT THE WORK OF ADVERTISEMENT WAS CARRI ED OUT BY VARIOUS OUTSIDE ADVERTISEMENT AND MARKETING AGENCIES AND NOT BY M/S JEANS CORNER AND THAT SINCE THE ASSESSEE HAS NOT PAID THE AMOUNT OF RS.37,35,376/- FOR CARRYING OUT ANY WORK BY M/S JEANS C ORNER, THE ASSESSEE WAS NOT UNDER ANY OBLIGATION TO DEDUCT TAX AT SOURCE ON THE AMOUNTS SHARED WITH M/S JEANS CORNER. THE CIT (A) HELD THAT CONSEQUENTLY, THE PROVISIONS OF SECTION 40 (A) (IA) OF TH E ACT ARE NOT ATTRACTED IN THE CASE OF THE ASSESSEE. IN THE LIGHT OF TH E ABOVE SUBMISSIONS, THE LEARNED COUNSEL FOR THE ASSESSEE PLEADED TH AT THE DEPARTMENTAL APPEAL MAY BE DISMISSED IN RESPECT OF GROUN D NOS. 4, 5 AND 6. IT IS FURTHER SUBMITTED THAT ON THE ALTERNAT IVE GROUND FOR DISALLOWANCE OF THE AMOUNT OF RS.37,35,376/- VIZ., THA T THE SAME WAS NOT NECESSARY FOR THE PURPOSES OF ASSESSEES BUSINESS, THE CIT (A) HELD THAT THE EXAMINATION OF NECESSITY OR OTHERWISE OF INCURR ING AN EXPENDITURE IS NOT WITHIN THE JURISDICTION OF THE A SSESSING OFFICER AND HE ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 5 HELD THAT AS LONG AS THE EXPENDITURE IS GENUINE, VERIF IABLE AND LAID DOWN FOR BUSINESS PURPOSES AND IS NOT IN THE NATURE OF CAPITAL EXPENDITURE, THE SAME IS TO BE ALLOWED AS DEDUCTION. COMING TO THE FACTS OF THE SPECIFIC CASE OF THE ASSESSEE, THE CIT (A) NOTICED THAT THE SALES TU RNOVER GREW FROM RS.3.20 CRORES IN FINANCIAL YEAR 2004-05 TO RS.13 .99 CRORES FOR THE FINANCIAL YEAR 2005-06 AND HELD THAT THE TOTAL EXPE NDITURE OF RS.65.95 LAKHS ON TOTAL TURNOVER OF RS.13.99 CRORES IS NOT EXCESSIVE KEEPING IN VIEW THE NATURE OF THE BUSINESS AND GROWTH IN SALES TUR NOVER AS COMPARED TO THE IMMEDIATE PREVIOUS YEAR. AS ALREADY DETAILED THAT THE EXPENDITURE OF RS.65.95 LAKHS ON ADVERTISEMENT INCLUDES RS.28,60,035/- BEING STAND ALONE EXPENDITURE AND THIS WAS SUBJECT TO SCRU TINY DURING THE COURSE OF REGULAR ASSESSMENT AND THERE THE ASSESSING OFFI CER DID NOT MAKE ANY DISALLOWANCE OUT OF THE SAME AND THE ASSESSING OF FICER MADE A CLAIM BEFORE THE CIT (A) FOR THE FIRST TIME IN THE REMAND REPORT SUBMITTED BY HIM THAT THE ENTIRE EXPENDITURE INCURRED BY THE ASSESSEE ON ADVERTISEMENT REPRESENTS COMMON EXPENDITURE AND SINCE THE ASSESSEES SHARE IN ADVERTISEMENT EXPENDITURE IS ONLY 20% A S PER THE AGREEMENTS. IT IS FURTHER SUBMITTED THAT THE CIT (A) EXAMINED THE DETAILS FURNISHED BY THE ASSESSEE AND HAS GIVEN A CLEAR F INDING THAT THE AMOUNT OF RS.28,60,035/- REPRESENTS EXPENDITURE INCURR ED BY THE ASSESSEE FIRM DIRECTLY FOR PROMOTION OF ITS GOLD JEWELLE RY BUSINESS AND THAT THIS EXPENDITURE WAS TO BE BORNE EXCLUSIVELY BY TH E ASSESSEE WITHOUT SHARING IT WITH THE ASSOCIATE CONCERN BECAUSE IT RE LATES TO JEWELLERY ADVERTISEMENT. IN THE LIGHT OF THE FINDIN G BY THE CIT (A), GROUND NO.7 AND 8 IN THE DEPARTMENTAL APPEAL ARE LI ABLE TO BE DISMISSED. 6. ON THE OTHER HAND, THE LEARNED DEPARTMENTAL REP RESENTATIVE SUBMITTED THAT AS PER CIRCULAR NO.715 ISSUED BY THE CBD T REPORTED IN ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 6 215 ITR 12 WHEREIN IT WAS HELD THAT EVEN REIMBURSEME NT OF EXPENDITURE OF TDS HAS TO BE DEDUCTED. SINCE, THERE W AS NO DEDUCTION OF TDS BY THE ASSESSEE ON SUCH PAYMENTS, THE ASSESSING OFFICER HAS RIGHTLY INVOKED SECTION 40A [IA] OF THE ACT FOR MAKING DISALLOWANCE AND THE CIT (A) IS WRONG IN HIS DIRECTION TO THE ASSESSING OFF ICER FOR DELETING THE SAME. 7. WE HAVE CONSIDERED THE SUBMISSIONS OF THE RIVAL PAR TIES AND PERUSED THE MATERIAL AVAILABLE ON RECORD. IT IS UNDIS PUTED FACT THAT THE ADVERTISEMENT EXPENDITURE AMOUNTING TO RS.37,35,376/- WAS INCURRED BY THE ASSOCIATE CONCERN M/S JEANS CORNER AND THE ASSESSE E INCURRED THE SAID EXPENDITURE BY WAY OF REIMBURSEMENT. THE A CTUAL ADVERTISING WORK WAS CARRIED OUT BY VARIOUS OUTSIDE AGENCIES AND NOT BY THE JEANS CORNER. SINCE THE PAYMENT MADE BY THE ASSESSEE FIRM TO M/S JEANS CORNER IS MERELY TOWARDS REIMBURSEMENT OF EXPENDITURE AND NOT FOR CARRYING OUT ANY WORK OBLIGATION WHICH REQUIRES DEDUCT ION OF TDS U/S 194C OF THE ACT. M/S JEANS CORNER PER SE HAS NOT CARRIED OUT ANY WORK FOR THE ASSESSEE FIRM. SINCE THE TAX IS NOT DEDUCTIBLE AT SOURCE, THE PROVISIONS OF SECTION 40 A (IA) PROVIDING FOR DISALLOWAN CE OF EXPENDITURE DO NOT GET ATTRACTED. WE SEE NO MERIT IN THE CONT ENTIONS OF THE DEPARTMENTAL REPRESENTATIVE THAT THE EXPENDITURE OF RS.28,60,035/- IS NOT BEING NECESSARY FOR THE PURPOSE OF ASSESSEES BUSINESS AND THE SAME IS EXCESSIVE AS THE ASSESSEE APPEARS TO HAVE INCURRED SUCH EXPENDITURE DIRECTLY FOR PROMOTION OF ITS GOLD JEWELL ERY BUSINESS. THESE ARE THE EXPENDITURE INCURRED BY THE ASSESSEE EXCLUSIVELY WITHOUT SHARING IT WITH THE ASSOCIATE CONCERN M/S JEANS CORNER AS THEY RE LATE TO JEWELLERY BUSINESS. IN OUR CONSIDERED OPINION, THE ASSE SSING OFFICER IS NOT WITHIN HIS JURISDICTION TO EXAMINE THE NECESSITY OR O THERWISE OF INCURRING AN EXPENDITURE. AS LONG AS THE EXPENDITUR E IS GENUINE AND ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 7 INCURRED FOR THE PURPOSE OF BUSINESS AND THE SAME IS NOT I N THE NATURE OF CAPITAL EXPENDITURE, THE SAID EXPENDITURE IS TO BE ALL OWED AS DEDUCTION. WE DO NOT SEE ANY INFIRMITY IN THE ORDER OF THE FIRST APPELLATE AUTHORITY ON THIS ISSUE AND THE SAME IS CONFIRMED. THE GROUNDS RA ISED BY THE REVENUE ON THESE ISSUES ARE REJECTED. 8. GROUND NO.9 IS WITH REGARD TO DISALLOWANCE OF ELECT RICITY EXPENDITURE WITHOUT VERIFYING THE WATTAGE OF USAGE B ETWEEN THE ASSESSEE AND M/S JEANS CORNER. BRIEF FACTS OF THIS ISSUE ARE THAT AN AMOUNT OF RS.20,50,000/- IS DEBITED TO ELECTRICITY EXPE NSES BY THE ASSESSEE FIRM AND THIS EXPENDITURE IS BASED ON SHARING ARR ANGEMENT ENTERED INTO WITH THE ASSOCIATE CONCERN M/S JEANS CORNER A ND THE EXPENDITURE SHARING ARRANGEMENT IS RECORDED IN TWO SUB- LEASE DEED AGREEMENT REFERRED EARLIER. THE ASSESSING OFFICER, OUT OF THE TOTAL EXPENDITURE OF RS.20,50,000/-, HAS CONSIDERED RS.3 LAKHS AS REASONABLE AND THE BALANCE OF RS.17,50,000/- IS DISALLOWED . AGAI NST THE ORDER OF THE ASSESSING OFFICER, THE ASSESSEE WENT IN APPEAL BEFORE TH E CIT (A). ON APPEAL CIT (A) AFTER CONSIDERING THE FACTS OF THIS ISSU E ELABORATELY IN HIS ORDER HELD IN PARA- 39 OF HIS ORDER WHICH READS AS UNDER:- I HAVE CAREFULLY EXAMINED AND CONSIDERED THE FACTS AND SUBMISSION MADE BY THE AR, OBSERVATIONS MADE BY THE AO IN HIS ASSESSMENT ORDER U/S 143(3) AND IN HIS REMAND REPOR T. THE ASSESSING OFFICER FINDING THAT CONSIDERING THE SIM ILAR TYPE OF ASSESSEE DEALING IN SIMILAR TYPE OF BUSINESS THE EL ECTRICITY EXPENSES ARE ESTIMATED TO BE REQUIRED AT AN AMOUNT OF RS.3 LAKHS PER YEAR IS NOT BASED ON ANY COMPARABLE CASES . THERE IS NO MENTION AS TO WHICH SIMILAR TYPE OF ASSESSEE HAS BE EN COMPARED TO ARRIVE AT THE REASONABLE ESTIMATED EXPENDITURE O F RS.3,00,000/- FOR THE YEAR. FURTHER, THE ASSESSEE IS NOT REQUIRED TO ESTABLISH THE NECESSITY OF EXPENDITURE AS CONTEN DED BY THE ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 8 ASSESSING OFFICER. THE ASSESSING OFFICER FINDING T HAT THE BALANCE AMOUNT OF RS.17,50,000/- IS DISALLOWED AS NOT HAVIN G BEEN INCURRED FOR THE PURPOSE OF BUSINESS OF THE ASSESSE E IS ALSO NOT WELL FOUNDED ON THE FACTS AND MATERIALS ON RECORD. IT IS A FACTUAL POSITION THAT THE SHARING OF EXPENDITURE IS BASED O N A RECORDED UNDERSTANDING AND IS DEFINITELY FOR ITS BUSINESS CA RRIED ON FROM DILSUKHNAGAR AND AMEERPET SHOWROOM. FURTHER, THE E LECTRICITY EXPENDITURE OF RS.20,50,000/- ON A SALES TURNOVER B ASE OF RS.13,99,61,519/- APPEAR TO BE REASONABLE. IN VIEW OF THE ABOVE, THE CIT (A) HAS DIRECTED THE A SSESSING OFFICER TO DELETE THE DISALLOWANCE MADE OF RS.17,50,000/- TOWARDS ELECTRICITY EXPENDITURE. AGGRIEVED BY THE ORDER OF THE CIT (A), THE REVENUE IS IN APPEAL BEFORE US. 9. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL AVAILABLE ON RECORD. WE FIND THAT THE ASSESSI NG OFFICER CONSIDERED RS.3 LACS AS REASONABLE ONE WITHOUT ANY BASIS. HE MADE THE DISALLOWANCE ON AD HOC BASIS WITHOUT ANY JUSTIFICATION. WHEREAS THE ASSESSEE ALLOCATED THE EXPENDITURE BY TAKING INTO CONSIDER ATION THE AREA OCCUPIED AND THE TYPE OF LIGHTING AND ELECTRIC DECORATIO N REQUIRED FOR DISPLAY OF JEWELLERY. THE SHARING OF SAID EXPENDITURE WAS DONE IN TERMS OF SUB-LEASE DEEDS ENTERED BETWEEN THE ASSESSEE AND ITS ASSO CIATE CONCERNS. BY COMPARING THE AMOUNT OF EXPENDITURE INC URRED TOWARDS ELECTRICITY WITH THE SALES TURNOVER OF THE ASSESSEE I.E, 1. 46% OF THE SALES-TURNOVER, THE EXPENDITURE INCURRED BY THE ASSESSEE ON THIS COUNT SEEMS TO BE REASONABLE AND JUSTIFIED ONE. HENCE, THE C IT (A) IS PERFECTLY JUSTIFIED IN GIVING DIRECTION TO THE ASSESSING O FFICER TO DELETE THE SAID DISALLOWANCE MADE TOWARDS ELECTRICITY EXPENDITURE. IN VIEW OF THE ABOVE, WE DO NOT SEE ANY INFIRMITY IN THE ORDER OF T HE CIT (A) AND ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 9 ACCORDINGLY, HIS FINDINGS ARE UPHELD ON THIS ISSUE. HEN CE, WE UPHOLD THE ORDER OF THE CIT (A) AND REJECT THE GROUND RAISED BY THE REVENUE. 10. IN THE RESULT, THE APPEAL FILED BY THE REVENUE IS DISMISSED. ORDER WAS PRONOUNCED IN THE COURT ON 30- 06-2011. SD/- SD/- (G.C. GUPTA) (AKBER BASHA) VICE PRESIDENT ACCOUNTANT MEMBER DT.30-06-2011. JMR* COPY FORWARDED TO: 1. 2. 3. 4. 5. ACIT, CIR-9(1), HYDERABAD M/S. J.C. BROTHERS JEWELLERS, 16-11-515/A/1, YELLISHAL DILSUKHNAGAR, HYDERABAD. CIT (A)-VI, HYDERABAD. CIT, AP, HYDERABAD. THE DR, ITAT, HYDERABAD. ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 10 ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 11 ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 12 ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 13 ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 14 ITA NO.1187/HYD/2009 M/S. J.C. BROTHERS, HYD. ====================== 15