Sri V Dhana Reddy., Visakhapatnam V. The JCIT, Cent Cir-1., Visakhapatnam

ITA 119/VIZ/2007

• Counselvise Citation: [2009] 115 COUNSELVISE.COM (IT) 0115 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 2 year(s) 4 month(s) 26 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-09-2009
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Assessment Year: 2002-2003
• Appeal Filed On: 20-04-2007
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: R K SINGHDR
• Keywords: Income from undisclosed sources; Additional evidence
• Section: 201; 191; 68

Judgement Text

PAGE 1 OF 9 IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM BENCH, VISAKHAPATNAM BEFORE: SHRI SUNIL KUMAR YADAV, JUDICIAL MEMBER AND SHRI BR BASKARAN, ACCOUNTANT MEMBER ITA NO.119/VIZAG/2007 ASSESSMENT YEAR: 2002-03 V. DHANA REDDY, VISAKHAPATNAM VS. JCIT, CENTRAL CIRCLE-1, VISAKHAPATNAM (APPELLANT) (RESPONDENT) PAN NO. AAIPV 8980E APPELLANT BY: SHRI GVN HARI, CA RESPONDENT BY: SHRI R.K. SINGH,DR ORDER PER SHRI B R BASKARAN, ACCOUNTANT MEMBER : THE APPEAL OF THE ASSESSEE IS DIRECTED AGAINST THE ORDER DATED 06-03- 2007 PASSED BY THE LD CIT(A)-I HYDERABAD AND IT RELA TES TO THE ASSESSMENT YEAR 2002-03. 2. THE ISSUES AGITATED IN THESE APPEALS ARE LISTED BELOW: A) ADDITION OF RS.49,24,069/- RELATING TO THE DEPOSITS MADE IN THE CURRENT A/C MAINTAINED WITH SBI. B) ADDITION OF RS.14,91,515/- RELATING TO THE FIXED DE POSIT MADE WITH BANK. C) ADDITION OF RS.3,50,530/- RELATING TO REPAYMENT OF LOAN. 3. THE ASSESSEE IS AN INDIVIDUAL DERIVING INCOME FR OM HOUSE PROPERTY AND ALSO INCOME FROM OTHER SOURCES. HE IS ALSO A PARTNE R IN CERTAIN PARTNERSHIP FIRMS. HE FILED HIS RETURN OF INCOME FOR THE ASSESS MENT YEAR 2002-03 ON 31.7.2002 DECLARING A TOTAL INCOME OF RS.60,040/- A ND AGRICULTURAL INCOME OF PAGE 2 OF 9 RS.40,000/-. THE DEPARTMENT CARRIED OUT SEARCH OPER ATIONS IN THE GROUP CASES PARTNERSHIP FIRM NAMED V.DHANA REDDY & CO. AN D OTHERS. BASED ON THE SEARCH OPERATIONS, THE ASSESSMENT OF THE YEAR U NDER CONSIDERATION WAS COMPLETES U/S 153 A OF THE ACT IN THE HANDS OF THE ASSESSEE. 4. THE FIRST ISSUE RELATES TO THE ADDITION OF RS.49 ,24,069/-. DURING THE COURSE OF SEARCH IT WAS NOTICED THAT THE ASSESSEE I S OPERATING A CURRENT A/C MAINTAINED WITH SBI IN THE NAME OF S.V.V.S.S ENTERP RISES. FROM THE BANK RECORD IT WAS NOTICED THAT THE ACCOUNT WAS OPENED B Y DECLARING THAT THE ASSESSEE HEREIN IS THE PROPRIETOR OF THE SAID CONCE RN. IN THE SAID BANK A/C, TRANSACTIONS RELATING TO THE DEPOSIT OF FUND AS WEL L AS WITHDRAWALS WERE NOTICED. ALL THE DEPOSITS WERE BY WAY OF CHEQUES A ND DEMAND DRAFTS. IT WAS ALSO NOTICED THAT THE ASSESSEE HAS CARRIED OUT CERT AIN PERSONAL TRANSACTIONS ALSO THROUGH ITS BANK A/C. THE ASSESSEE CLAIMED TH AT THE SAID BANK A/C BELONGS TO A PARTNERSHIP FORM NAMED S.V.V.S.S ENTER PRISES AND THE SAME WAS OPERATED ON BEHALF OF THE PARTNERSHIP FIRM ONLY. IN THIS CONNECTION THE ASSESSEE COULD PRODUCE ONLY A COPY OF PARTNERSHIP D EED. IN THE ABSENCE OF PROPER EVIDENCE, THE AO REJECTED THE EXPLANATION OF THE ASSESSEE. THE AO NOTICED THAT A SUM OF RS.50.74 LAKHS WAS DEPOSITED IN THE BANK A/C DURING THE YEAR UNDER CONSIDERATION, OUT OF WHICH A SUM OF RS.1.50 LAKH REPRESENTED AMONG THE PERIOD BY THE ASSESSEE. ACCORDINGLY THE A O ADDED THE BALANCE AMOUNT OF RS.49,24,069/- AS THE INCOME OF THE ASSES SEE U/S 68 OF THE ACT. THE SAID ADDITION WAS ALSO CONFIRMED BY THE LD CIT (A). 5. WE HAVE HEARD THE PARTIES ON THIS ISSUE AND ALSO PERUSED THE RECORD. THE FIRST CONTENTION OF THE LD AR IS THAT THE IMPUG NED BANK A/C AND THE TRANSACTIONS RECORDED THEREIN ACTUALLY BELONG TO A PARTNERSHIP FIRM. HOWEVER, WE NOTICE THAT THE ASSESSEE COULD PRODUCE ONLY A PA RTNERSHIP DEED IN SUPPORT OF ITS CONTENTIONS. BEFORE US ALSO, LD AR COULD NO T CLARIFY WHETHER THE IMPUGNED BANK A/C AND THE TRANSACTIONS THEREIN WERE ACCOUNTED FOR IN THE PAGE 3 OF 9 BOOKS OF THE FIRM. BESIDES THE ABOVE, WE NOTICE TH AT THE ASSESSEE HAS OPENED THE BANK A/C BY DECLARING HIMSELF AS THE PRO PRIETOR OF THE SAID CONCERN. IN THESE CIRCUMSTANCES WE DO NOT FIND ANY MERIT IN THE CONTENTIONS OF THE ASSESSEE AND ACCORDINGLY AFFIRM THE ORDER OF THE TAX AUTHORITIES IN HOLDING THAT THE SAID BANK A/C BELONGS TO THE ASSES SEE ONLY. 5.1 THE ALTERNATIVE CONTENTION OF THE LD AR IS THAT THE TRANSACTIONS RECORDED THEREIN REPRESENT BUSINESS TRANSACTION REL ATING TO RECEIPT OF TRANSPORT CHARGE AND HENCE ONLY THE PROFIT ELEMENT SHOULD BE ASSESSED TO TAX. IN THIS CONNECTION LD AR DREW OUR ATTENTION TO PAGES 70 TO 76 OF THE PAPER BOOK FILED BY THE ASSESSEE, WHEREIN A PETITIO N FILED BEFORE THE LD CIT (A) FOR ADMISSION OF CERTAIN ADDITIONAL EVIDENCES I S PLACED. THE ADDITIONAL EVIDENCES CONSIST OF AFFIDAVITS GIVEN BY TWO PERSON S NAMED SHRI P. RAJASEKHARA REDDY AND SHRI A. SHIVANAGI REDDY. BOT H THE PERSONS HAVE AVERRED THAT THEY HAVE AVAILED TRANSPORT SERVICES F ROM SVVSS ENTERPRISES AND HAVE MADE PAYMENTS BY WAY OF DEMAND DRAFTS. BOTH TH E PERSONS HAVE ADMITTED THAT THEY HAVE PAID THE ENTIRE AMOUNT OF R S.49,24,069/- THAT WAS FOUND CREDITED WITH THE IMPUGNED BANK A/C. ACCORDI NG TO THE LD AR THE LD CIT (A) DID NOT CONSIDER THIS PETITION AND AFFIDAVI TS WHILE FRAMING THE APPELLATE ORDER. 5.2 AS STATED EARLIER THE ASSESSEE IS DERIVING INCO ME FROM HOUSE PROPERTY AND INCOME FROM OTHER SOURCES. AS SUCH, AS PER THE RECORD, HE IS NOT CARRYING ON ANY BUSINESS IN HIS INDIVIDUAL CAPACITY . HENCE, THERE IS NO MATERIAL TO SUGGEST EXISTENCE OF ANY OTHER SOURCE F ROM WHICH THE ASSESSEE COULD GENERATE UNACCOUNTED INCOME. THE ASSESSING O FFICER ALSO DID NOT HAVE ANY MATERIAL TO SHOW THAT THE IMPUGNED CREDITS REPR ESENT THE INCOME OF THE ASSESSEE. AT THE SAME TIME THE ASSESSEE COULD NOT P RODUCE EVIDENCES LIKE BILLS, RECEIPTS ETC. TO SUPPORT HIS CLAIM. HOWEVER THE ASSESSEE COULD PRODUCE TWO AFFIDAVITS FROM TWO PERSONS WHO HAVE CONFIRMED THE VERSION OF THE PAGE 4 OF 9 ASSESSEE. HENCE THE CLAIM OF THE ASSESSEE THAT THE IMPUGNED CREDITS AVAILABLE IN THE BANK A/C REPRESENT BUSINESS TRANSA CTIONS CANNOT BE ALTOGETHER DISCOUNTED WITH. HENCE, IN THE FACTS AND CIRCUMSTA NCES OF THE CASE, WE ARE OF THE OPINION THAT THE ENTIRE CREDITS CANNOT ALSO BE TAKEN AS INCOME OF THE ASSESSEE U/S 68 OF THE ACT. ACCORDINGLY, WE ARE OF THE OPINION THAT A REASONABLE PROFIT FROM THE BUSINESS TRANSACTIONS SH OULD BE ESTIMATED. HENCE ON A CONSPECTUS OF THE MATTER, WE ARE OF THE OPINIO N THAT THE INCOME FROM THE BUSINESS TRANSACTIONS MAY BE ESTIMATED AT 10% O F THE GROSS AMOUNT RECEIVED BY THE ASSESSEE AND IN OUR OPINION, IT COU LD MEET THE ENDS OF JUSTICE. ACCORDINGLY, WE DIRECT THE ASSESSING OFFICE TO ADOP T THE INCOME FROM THE BUSINESS TRANSACTIONS FOUND IN THE IMPUGNED BANK AC COUNT AT RS. 4,92,406/-. 6. THE SECOND ISSUE RELATES TO THE ADDITION MADE TO WARDS THE FOLLOWING BANK DEPOSITS: DATE OF DEPOSIT NAME AMOUNT 5-9-2001 V.DHANA REDDY 3,90,000 21-9-2001 V.DHANA REDDY 3,04,935 21-9-01 VMM REDDY (MINOR SON) 4,06,580 4-9-2001 VMM REDDY (MINOR SON) 3,90,000 TOTAL 14,91,515 WITH REGARD TO THE DEPOSIT IN THE NAME OF VMM REDDY (MINOR SON) AMOUNTING TO RS.4,06,580/- IT WAS SUBMITTED THAT THE ASSESSEE HAD MADE A DEPOSIT OF RS.4.00 LAKHS ON 24.10.2000 AND HE HAS UTILISED THE MATURITY PROCEEDS OF THE DEPOSITS FOR MAKING THE IMPUGNED DEPOSITS. HOWEVER, THE TAX AUTHORITIES ADDED THE SAME TO THE TOTAL INCOME AS THERE WAS DIF FERENCE IN THE MATURITY VALUE OF THE DEPOSITS AND THE AMOUNT OF IMPUGNED DE POSIT. HOWEVER, BEFORE US, THE LD AR EXPLAINED THE SEQUENCE OF TRANSACTION S IN THIS REGARD AS UNDER: PAGE 5 OF 9 A) A SUM OF RS.4.00 LAKH CONSISTING OF 5 DEPOSITS OF R S.80,000/- EACH WAS MADE ON 24.10.2000 B) THE SAID 5 DEPOSITS GOT MATURED ON 4-5-2001 WITH A MATURITY VALUE OF RS.4,06,165/- C) ON 13-6-2001 THE ASSESSEE MADE A DEPOSIT OF RS.4.00 LAKHS IN THE NAME OF HIS SON BY UTILIZING THE MATURITY PROCEEDS MENTIONED IN (B) ABOVE. D) THE DEPOSITS MADE ON 13-6-2001 GOT MATURED ON 24-9- 2001 WITH A MATURITY VALUE OF RS.4,06,580/- AND THE SAME WAS AD DED BY THE AO. 6.1. ON PERUSAL OF THE EXPLANATION FURNISHED ABOVE, WE ARE OF THE OPINION THAT THE AO HAS NOT PROPERLY APPRECIATED THE SEQUEN CE OF TRANSACTIONS. THE ASSESSEE HAS ALSO PLACED BEFORE US A COPY OF THE OR DER DATED 18.1.2008 PASSED BY THIS BENCH IN THE CASE OF THE ASSESSEE FO R THE ASSESSMENT YEAR 2001-02 AND 2004-05. IN THE ASSESSMENT YEAR 2001-02 THE TRIBUNAL HAS TAKEN A VIEW THAT THE ASSESSEE HAD SOURCES FOR MAKI NG DEPOSIT OF RS.4.00 LAKHS ON 24.10.2000. AS EXPLAINED EARLIER THE SAID DEPOSIT OF RS.4.00 LAKHS WAS THE STARTING POINT OF THE SEQUENCE STATED ABOVE . IN VIEW OF THE FOREGOING DISCUSSIONS, WE ARE OF THE OPINION THAT THE ASSESSEE HAS PROPERLY EXPLAINED THE SOURCES FOR MAKING THE IMPUGNED DEPOS IT OF RS.4,06,580/-. ACCORDINGLY WE DIRECT THE AO TO DELETE THE ADDITION OF RS.4,06,580/-. 7. WITH REGARD TO THE REMAINING THREE DEPOSITS, THE ASSESSEE HAS EXPLAINED THAT THEY WERE MADE OUT OF CASH WITHDRAWA LS MADE FROM THE BANK AND THE PARTNERSHIP FIRMS IN WHICH HE WAS A PARTNER . IN SUPPORT OF HIS CONTENTIONS, THE ASSESSEE HAS FILED THE FUND FLOW S TATEMENT AND CASH FLOW STATEMENT TO EXPLAIN THE SOURCES FOR THESE 3 DEPOSI TS. HOWEVER, IN THE ABSENCE OF REGULAR BOOKS OF ACCOUNTS, THE TAX AUTHO RITIES DID NOT GIVE PAGE 6 OF 9 IMPORTANCE TO THE CASH FLOW STATEMENT AND FUND FLOW STATEMENT FILED BY THE ASSESSEE. 7.1 IN THIS CONNECTION, LD AR PLACED BEFORE US A COP Y OF ORDER DATED 18- 01-2008 PASSED BY THIS BENCH IN THE ASSESSEES OWN CASE IN ITA NO.450/V/2006 RELATING TO THE ASSESSMENT YEARS 2001 -02 AND 2004-05. WE NOTICE FROM THE SAID ORDER THAT THE LD AR, AT THAT TIME, RELIED UPON FOUR CASE LAW TO DRIVE THE POINT THAT THE TAX AUTHORITIES SHO ULD GIVE DUE IMPORTANCE TO THE CASH FLOW STATEMENT. THE RELEVANT OBSERVATIONS MADE BY THE TRIBUNAL IN THAT CASE ARE EXTRACTED BELOW: 7. THE LD AUTHORISED REPRESENTATIVE STRONGLY RELIE D ON THE ARGUMENTS PUT FORTH BEFORE THE LD CIT (A). HE ALSO RELIED ON THE DECISIONS OF HONBLE HIGH COURT AND HONBLE TRIBUNA L DETAILED BELOW: I) COMMISSIONER OF INCOME TAX VS. KULWANT RAI 191 ITR 3 6 (DEL). IN THIS CASE THE HONBLE HIGH COURT OBSERVED AS UNDER: THIS CASH FLOW STATEMENT FURNISHED BY THE ASSESSEE WAS REJECTED BY THE ASSESSING OFFICER WHICH IS ON THE B ASIS OF SUSPICION THAT THE ASSESSEE MUST HAVE SPENT THE AMO UNT FOR SOME OTHER PURPOSES. THE ORDERS OF THE ASSESSIN G OFFICER AS WELL AS LD CIT (A) ARE COMPLETELY SILENT AS TO FOR WHAT PURPOSE THE EARLIER WITHDRAWALS WOULD HAVE BEEN SPENT IT HAS BEEN HELD BY THE TRIBUNAL THAT I N THE INSTANT CASE, THE WITHDRAWAL SHOWN BY THE ASSESSEE ARE FAR IN EXCESS OF THE CASH FOUND DURING THE COURSE O F SEARCH PROCEEDINGS. NO MATERIAL HAS BEEN RELIED UPO N BY THE ASSESSING OFFICER OR LD CIT(A) TO SUPPORT THEIR VIEW THAT THE ENTIRE CASH WITHDRAWAL MUST HAVE BEEN SPEN T BY THE ASSESSEE AND ACCORDINGLY, THE TRIBUNAL RIGHTLY HELD THAT THE ASSESSMENT OF RS.2.5 LAKHS IS LEGALLY NOT SUSTAINABLE UNDER SECTION 158BC OF THE ACT AND THE SAME WAS RIGHTLY ORDERED TO BE DELETED II) R.K. DAVE VS. ITO 94 TTJ (JD) 19. IN THIS CASE, IT H AS BEEN OBSERVED AS UNDER: PAGE 7 OF 9 IT IS NOT THE CASE OF REVENUE THAT THE AMOUNTS SO WITHDRAWN WERE UTILIZED ELSEWHERE. MERE FACT THAT T HE ASSESSEE COULD NOT EXPLAIN THE TIME GAP BETWEEN THE AMOUNT WITHDRAWN AND THE INVESTMENT IN NSCS OR WHER E THE AMOUNT WAS KEPT WOULD NOT ITSELF JUSTIFY THE AD DITION. THE CLAIM OF THE ASSESSEE WOULD HAVE BEEN REJECTED ONLY, IF THE SOURCE OF BALANCE IN THE BANK ACCOUNT WAS NOT ESTABLISHED OR IT COULD HAVE BEEN DEMONSTRATED THAT THE AMOUNT SO WITHDRAWN WAS UTILISED ELSEWHERE. III) ANAND PRAKASH SONI VS. DCIT (JD) 101 TTJ 100. IT HA S BEEN OBSERVED AS UNDER: THE CRUCIAL QUESTION WHICH LOOMS LARGE OVER THE F ACTUAL MATRIX OF THE INSTANT CASE IS TO DECIDE AS TO WHETH ER OR NOT THE ASSESSEE IS ENTITLED TO FURNISH CASH FLOW STATEMENT TO EXPLAIN THE TRANSACTIONS WHEN NO BOOKS OF ACCOUNT ARE MAINTAINED?. IN OUR VIEW, THE REPLY TO T HIS QUESTION HAS TO BE IN AFFIRMATIVE. FOR THE OBVIOUS REASON THAT ALL THE TRANSACTIONS, ASSETS OR INCOME OF A PE RSON NOT MAINTAINING BOOKS OF ACCOUNT CANNOT BE SAID TO BE UNDISCLOSED INCOME, MORE SO, WHEN THE INCOME EARNED IS NEGLIGIBLE NOT WARRANTING THE MAINTENANCE OF BOOKS OF ACCOUNT AS PER THE PROVISIONS OF THE ACT AND THE AS SESSEE IS REGULARLY ASSESSED TO TAX, HAVING FILED HIS RETU RN OF INCOME IN DUE COURSE. IV) HONBLE ITAT VISAKHAPATNAM BENCH DECISION IN ITA NO.400/V/2005 THE HONBLE BENCH HAS HELD AS UNDER: THE GAP IN UTILIZATION OF FUNDS FROM THE DATE OF WITHDRAWAL CANNOT BE A CRITERIA TO TURN THE GOOD EXPLANATION AS BAD AND DISPROVE THE BONAFIDE CLAIM OF THE ASSESSEE AS HAS ALSO BEEN HELD BY HONBLE KERAL A HIGH COURT IN THE CASE OF CIT VS. K.SRIDHARAN 201 I TR 1010. IN THAT CASE THE TRIBUNAL NOTICED THE FACT THAT THE ASSESSEE DID NOT MAINTAIN BOOKS OF ACCOUNT FOR HIS PERSONAL TRANSACTIONS. IT A LSO NOTICED THAT THE FUND FLOW AND CASH FLOW STATEMENT HAVE BEEN PREPARED FRO M THE ENTRIES ALREADY RECORDED IN THE BOOKS OF PARTNERSHIP FIRM AND ALSO IN THE BANK ACCOUNT. ACCORDINGLY, THE TRIBUNAL HAS OBSERVED THAT NO NEW ITEM OF RECEIPTS WAS PAGE 8 OF 9 TAKEN INTO ACCOUNT FOR PREPARING THE CASH FLOW STAT EMENT. THE TRIBUNAL HAS ALSO OBSERVED THAT THE AO, IN THE ABSENCE OF BOOKS OF ACCOUNTS, SHOULD HAVE OBJECTIVELY ANALYZED THE ABOVE STATEMENTS BEFORE RE JECTING THE ASSESSEE EXPLANATIONS BY APPLYING THE TEST OF HUMAN PROBABIL ITIES. 7.2 THE ASSESSEE HAS FILED CASH FLOW STATEMENTS FOR SEVERAL YEARS. WE RESTRICTED OUR OBJECTIVE ANALYSIS ONLY TO THE CASH FLOW STATEMENTS RELEVANT FOR THE ASSESSMENT YEARS 2001-02 AND 2002-03. FOLLOWIN G POSITION EMERGES FROM OUR ANALYSIS. AMOUNT WITHDRAWN DURING THE YEAR RELEVANT FOR ASSESSMENT YEAR 2001-02 10,53,429 (-) CASH OUT GO DURING THAT YEAR 8,16,000 -------------- 2,37,429 (A) ======= AMOUNT WITHDRAWN DURING THE YEAR RELEVANT FOR ASSESSMENT YEAR 2002-03 - RS.17,16,891 (-) CASH OUT GO DURING THAT YEAR -OTHER THAN THE IMPUGNED DEPOSITS 8,62,033 -------------- 8,54,858 (B) ======= TOTAL BALANCE CASH AVAILABLE (A + B) 10,92,287 SO THE CASH WITHDRAWALS MADE ONLY DURING THE YEAR U NDER CONSIDERATION AND IN THE IMMEDIATELY PRECEDING YEAR WERE SUFFICIENT E NOUGH TO EXPLAIN THE SOURCES FOR MAKING THESE THREE DEPOSITS. IT IS PERT INENT TO NOTE HERE THAT THE ASSESSEE CLAIMS TO HAVE AN OPENING CASH BALANCE OF RS.10,30,452/- AS ON 1.4.2000. HOWEVER, EVEN WITHOUT CONSIDERING THE OP ENING CASH BALANCE, THE ASSESSEE COULD EXPLAIN THE SOURCES FOR MAKING THESE THREE DEPOSITS. HENCE THE ADDITION OF THE REMAINING THREE DEPOSITS ARE AL SO LIABLE TO BE DELETED AND WE ORDER ACCORDINGLY. PAGE 9 OF 9 8. THE NEXT ISSUE RELATES TO THE ADDITION OF RS .3,50,530/- RELATING TO THE REPAYMENT OF LOANS. WE NOTICE THAT IN THE CASH FLO W STATEMENT THE REPAYMENT OF LOAN OF RS.2.00 LAKHS HAS BEEN DULY IN CORPORATED. AS NOTICED EARLIER, THE ASSESSEE HAS EXPLAINED THE SOURCES FOR RS.2.00 LAKHS, THROUGH THE CASH FLOW STATEMENT. HENCE WE ORDER FOR DELETION OF RS.2.00 LAKHS. HOWEVER THE REPAYMENT OF RS.1,50,530/- DOES NOT FIND PLACE IN THE CASH FLOW STATEMENT AND THE ASSESSEE ALSO COULD NOT EXPLAIN P ROPERLY THE SOURCES FOR MAKING THE SAID REPAYMENT. HENCE WE CONFIRM THE AD DITION OF RS.1,50,530/-. 9. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. PRONOUNCED IN THE OPEN COURT ON 16.09.2009 SD/- SD/- (SUNIL KUMAR YADAV) (B R BASKARAN) JUDICIAL MEMBER ACCOUNTANT MEMBER PVV/SPS VISAKHAPATNAM, 16 TH SEPTEMBER, 2009. COPY TO 1 SHRI VELAGALA DHANA REDDY, PLOT NO: 25, OCEAN VIE W LAYOUT EXTN. PANDURANGAPURAM, VISAKHAPATNAM 2 THE JCIT, CIRCLE-1 VISAKHAPATNAM 3 THE CIT, VISAKHAPATNAM 4 THE CIT (A)-1, HYDERABAD 5 THE CIT (A) VISAKHAPATNAM 6 THE DR, ITAT, VISAKHAPATNAM. 7 GUARD FILE. BY ORDER SENIOR PRIVATE SECRETARY INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM