Deputy Commissioner of Income TAx, Hyderabad V. M/s. Maheswari Mega Ventures Ltd., Hyderabad

ITA 1217/HYD/2013

• Counselvise Citation: [2018] 126 COUNSELVISE.COM (IT) 2424 (ITAT-HYDERABAD)
• Duration Of Justice: 4 year(s) 7 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 21-03-2018
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Next Hearing Date: 14-02-2018
• Assessment Year: 2010-2011
• Appeal Filed On: 20-08-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: U MINICHANDRAN
• Keywords: Sale consideration of property below Jantri Value; Business expenditure; Earning of tax free income; Fair market value; Revenue expenditure
• Section: 143(3); 50C; 14A

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A, HYDERABAD BEFORE SMT P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA NO. 1217/HYD/2013 ASSESSMENT YEAR: 2010-11 DY. COMMISSIONER OF INCOME- TAX, CIRCLE 16(2), HYDERABAD. VS. M/S MAHESWARI MEGA VENTURES LTD., HYDERABAD (APPELLANT) (RESPONDENT) REVENUE BY : SMT. U. MINICHANDRAN ASSESSEE BY : SHRI K.C. DEVDAS DATE OF HEARING 14/02/2018 DATE OF PRONOUNCEMENT 21/03/2018 O R D E R PER S. RIFAUR RAHMAN, A.M.: THIS APPEAL OF THE REVENUE IS DIRECTED AGAINST THE ORDER DATED 31/05/2013 PASSED BY CIT(A) V7, HYDERABAD RELATIN G TO AY 2010- 11. 2. BRIEFLY THE FACTS OF THE CASE ARE THAT ASSESSEE COMPANY ENGAGED IN THE BUSINESS OF REAL ESTATE, CONSTRUCTING FLATS, SA LE OF LANDS AND RESTAURANT, FILED ITS RETURN OF INCOME FOR THE AY 2010-11 ON 15 /10/2010 ADMITTING INCOME OF RS. 79,11,029/-. THE AO COMPLETED THE ASS ESSMENT U/S 143(3) RWS 144A OF THE INCOME-TAX ACT, 1961 (IN SHORT THE ACT) DETERMINED THE TOTAL INCOME AT RS. 2,59,01,875/- BY MAKING THE FOL LOWING DISALLOWANCES: 1. DISALLOWANCE U/S 14A RS. 6,48,610 2. SUPPRESSION OF SALE VALUE OF PLOTS RS. 40,00, 000 3. DISALLOWANCE OF EXTRAORDINARY ITEMS RS.1,29,0 0,000 4. DISALLOWANCE OF PROPORTIONATE COST OF DILSHAD PLAZA RS. 7,00,000 3. AGGRIEVED BY THE ORDER OF AO, THE ASSESSEE PREFE RRED AN APPEAL BEFORE THE CIT(A), WHO DELETED THE AFOREMENTIONED D ISALLOWANCES. 2 ITA NO. 1217 /HYD/2013 M/S MAHESWARI MEGA VENTURES LTD. 4. AGGRIEVED BY THE ORDER OF THE CIT(A), THE REVENU E IS IN APPEAL BEFORE US RAISING THE FOLLOWING GROUNDS OF APPEAL: 5. AS REGARDS THE GROUND NO. 1 RELATING TO DISALLOW ANCE OF RS. 6,48,610/- U/S 14A OF THE ACT, THE AO NOTICED THAT THE ASSESSEE COMPANY HAS INVESTED AN AMOUNT OF RS. 8,17,65,500/- IN DIFF ERENT COMPANIES FROM THE BORROWED FUNDS AND ASSESSEE DEBITED AN AMOUNT O F RS. 69,25,335/- AS INTEREST ON THE LOAN. HE, THEREFORE, WORKED OUT THE DISALLOWANCE U/S 14A RWR 8D. 5.1 BEFORE THE CIT(A), THE ASSESSEE SUBMITTED THAT THE SAID INVESTMENTS WERE NOT MADE DURING THE YEAR UNDER CONSIDERATION A ND WERE ACCUMULATED OVER A PERIOD OF TIME AND IN THE ABSENCE OF ANY EXE MPT INCOME, PROVISIONS OF SECTION 14A CANNOT BE INVOKED. FURTHER, AS THEY HAVE RESERVES OF AROUND RS. 60.76 CRORES AS AGAINST THE INVESTMENT O F RS. 8.18 CRORES MADE, HE, THEREFORE, CONTENDED BEFORE CIT(A) THAT W ITHOUT PROVING THE NEXUS BETWEEN THE LOANS OBTAINED AND THE INVESTMENT S, THE PROVISIONS OF SECTION 14A CANNOT BE INVOKED FOR MAKING DISALLOWAN CE OF INTEREST. 5.2 THE CIT(A) AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESSEE AS WELL AS RELYING ON CASE LAW, HELD THAT THE ASSESSEE DOES NOT HAVE ANY INCOME WHICH DOES NOT FORM PART OF THE TOTAL INCOME NOR HAS THE ASSESSEE MADE SUCH A CLAIM AND ALSO THE INVESTMENTS HAD BEEN MADE BY THE ASSESSEE FROM ITS OWN FUNDS AND NO PART OF THE BORR OWED FUNDS HAD BEEN USED FOR PURPOSE OF MAKING INVESTMENT ANY TIME DURI NG THE PREVIOUS YEAR. FURTHER, HE HELD THAT NO NEXUS BETWEEN THE FUNDS BO RROWED AND THE FUNDS INVESTED BY THE ASSESSEE WAS BROUGHT OUT BY THE AO. HE, THEREFORE, DIRECTED THE AO TO DELETE THE DISALLOWANCE MADE U/S 14A RWR 8D OF THE ACT. 5.3 AGGRIEVED BY THE ORDER OF THE CIT(A), THE REVEN UE IS IN APPEAL BEFORE US. 5.4 IT IS A SETTLED POSITION OF LAW THAT THE PROVIS IONS OF SECTION 14A CAN BE APPLIED TO QUANTIFY THE EXPENSES IN RELATION TO EXEMPT INCOME. SINCE THE EXEMPT INCOME IS NIL, SECTION 14A WILL NO T APPLY. THE RULE 8D CAN BE APPLIED ONLY WHEN THERE IS DIFFICULTY IN FINDING THE 3 ITA NO. 1217 /HYD/2013 M/S MAHESWARI MEGA VENTURES LTD. EXPENDITURE RELATING TO EXEMPT INCOME. THE PROVISIO NS OF SECTION 14A AND RULE 8D WILL NOT APPLY TO THE PRESENT CASE. IT IS THE CONSISTENT VIEW OF THE HYDERABAD BENCHES AND ACCORDINGLY WE UP HOLD THE ORDER OF THE CIT(A) AND DISMISS THE GROUND RAISED BY THE REVENUE IN THIS REGARD. 6. AS REGARDS GROUND NO. 2 RELATING TO ADDITION OF RS. 40,00,000/- MADE ON ACCOUNT OF SUPPRESSION OF SALE VALUE OF PLOTS, D URING THE COURSE OF ASSESSMENT PROCEEDINGS, THE AO NOTICED THAT THE ASS ESSEE COMPANY DURING THE FY 2009-10 VIDE SALE DEED NO. 357/2010 H AD SOLD PLOT N. 2 OF SURVEY NO. 157/1, THOKATTA VILLAGE, TIRUMALAGIRI MA NDAL, SECUNDERABAD ADMEASURING 250 SQ.YDS IN FAVOUR OF MRS SUNITA JAIN ON 31/12/2009 FOR A SALE CONSIDERATION OF RS. 25,00,000/- WHEREAS THE F AIR MARKET VALUE AS ADOPTED BY STAMP VALUATION AUTHORITY, SUB-REGISTRAR BOWENPALLY WAS RS. 45,00,000/-. FURTHER, THE ASSESSEE COMPANY VIDE SAL E DEED NO. 358/2010 HAD SOLD PLOT N. 1 OF SURVEY NO. 157/1, THOKATTA VI LLAGE, TIRUMALAGIRI MANDAL, SECUNDERABAD ADMEASURING 250 SQ.YDS IN FAVO UR OF SHRI ARVIND KUMAR BHALGATN ON 31/12/2009 FOR A SALE CONSIDERATI ON OF RS. 25,00,000/- WHEREAS THE FAIR MARKET VALUE AS ADOPTED BY STAMP V ALUATION AUTHORITY, SUB-REGISTRAR BOWENPALLY WAS RS. 45,00,000/-. THERE FORE, THERE WAS A DIFFERENCE OF RS. 40,00,000/- BETWEEN THE FAIR MARK ET VALUE AS ADOPTED BY STAMP VALUATION AUTHORITY, SUB-REGISTRAR BOWENPALLY AND THE SALE VALUE AS ADOPTED BY THE ASSESSEE COMPANY. SINCE THE ASSESSEE HAS NEVER DISPUTED THE VALUE SO ADOPTED BY THE STAMP VALUATION AUTHORI TY BEFORE ANY AUTHORITY OR COURTS, THE AO TREATED THE ABOVE DIFFERENCE AMOU NT OF RS. 40,00,000/- AS SUPPRESSION OF SALE VALUE OF THE PLOTS SOLD AND ADDED TO THE INCOME RETURNED BY THE ASSESSEE. 6.1 BEFORE THE CIT(A), THE ASSESSEE, INTER-ALIA SUB MITTED THAT THE ACTUAL MARKET PRICE AT WHICH THE BUYER IS READY TO BUY PLO T/LAND/FLAT DEPENDS UPON VARIOUS FACTORS. THE BOOM IN THE MARKET SWINGS WITH VARIOUS FACTORS AFFECTING THE SALE PRICE. THERE IS NO THRESHOLD THA T THE BUYER IS READY TO BUY A PLOT/LAND/FLAT AT A PRICE EQUAL TO OR MORE THAN T HE FAIR MARKET VALUE. FURTHER, HE SUBMITTED THAT THE PLOTS WERE SOLD UNDE R COMPELLING CIRCUMSTANCES AT THE PRICES LESSER THAN FAIR MARKET VALUE AS THE TITLE OF THE PLOTS WAS UNCLEAR. THE PARTY TO WHICH THE SALE HAS BEEN TRANSACTED IS AWARE OF THE FACT THAT THERE IS NO CLEAR TITLE ON T HE PLOTS AND HENCE AGREED 4 ITA NO. 1217 /HYD/2013 M/S MAHESWARI MEGA VENTURES LTD. TO BUY AT A LOWER PRICE WHICH IS MUCH LESSER THAN T HE FAIR MARKET VALUE. IT WAS SUBMITTED THAT THE FAIR MARKET VALUE IS JUDGED AND DECIDED BY THE RESPECTIVE AUTHORITY WHICH IS UNDISPUTABLE. WHEN TH E FACTORS ON WHICH THE FAIR MARKET VALUE IS FIXED ARE IRRELEVANT FOR AGREE ING UPON THE SALE PRICE WITH THE BUYER, THERE IS NO REQUIREMENT FOR THE ASS ESSEE COMPANY TO DISPUTE THE SAME BEFORE ANY AUTHORITY OR COURTS. 6.2 LD. DR SUBMITTED THAT THE ASSESSEE HAS SOLD THE PROPERTY AT RS. 25 LAKHS WHEREAS THE SRO VALUE WAS RS. 45 LAKHS, FO R WHICH IT HAS NOT FILED ANY OBJECTION. THEREFORE, THE PROVISIONS OF SECTION 50C IS ATTRACTED, BUT THE SAME WAS DELETED BY LD. CIT(A) B Y OBSERVING THAT THIS PROPERTY HAS NO CLEAR TITLE AND IS IN DISPUTE. SHE BROUGHT TO OUR NOTICE THE ITAT ORDER (ITA NO. 190/HYD/12 AND OTHER S) TO INDICATE THAT THE ASSESSEE HAS IN FACT SETTLED THE ISSUE WITH THE LAND LORDS AND THE OTHER CLAIMANTS. THEREFORE, THERE IS NO DISPUTE EXI STED AT THE TIME OF SALE. FURTHER, SHE SUBMITTED THAT LD. CIT(A) HAS NO T DISCUSSED THE REASONS FOR DELETION ELABORATELY. 6.3 LD. AR, ON THE OTHER HAND, SUBMITTED THAT THE PLOTS OF LAND SOLD WERE IN FACT STOCK IN TRADE, THE PROOF OF SUCH CONV ERSION IS AVAILABLE IN THE SAME CASE LAW SUBMITTED BY THE LD. DR AT PAGE 6 OF PAPER BOOK. SINCE, IT IS BUSINESS ASSET, THE PROVISIONS OF SECT ION 50C WILL NOT APPLY IN THE ASSESSEES CASE. FOR THIS SUBMISSION, HE BROUGHT TO OUR NOTICE, THE FINANCIAL STATEMENT, WHICH IS PART OF P APER BOOK AT PAGE 102, IN WHICH ASSESSEE HAS DECLARED THE SALE VALUE OF THE PROJECT AT BOWENPALLY. FOR THIS PROPOSITION, HE RELIED ON THE DECISION IN THE CASE OF CIT VS. SHIVAKANI CO.P. LTD., 159 ITR 71 TO SUBM IT THAT THE ASSESSEE HAD SOLD THE PROPERTY AT LESS THAN MARKET PRICE BUT THE SAME WAS DECLARED BEFORE AUTHORITIES. IT IS NOT THE CASE THAT ASSESSEE HAS CONCEALED THE FACTS OR RECEIVED THE DIFFERENCE OF THE VALUE BY FRAUDULENT MEANS. THERE WAS NO EVIDENCE DIRECT OR I NFERENTIAL NOR THERE IS ANY FINDINGS BY THE AUTHORITIES. 5 ITA NO. 1217 /HYD/2013 M/S MAHESWARI MEGA VENTURES LTD. 6.4 CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED TH E MATERIAL ON RECORD. IT IS NOTED FROM THE FINANCIAL RECORDS SUBM ITTED BEFORE US THAT THE PLOT OF LAND SOLD WERE STOCK-IN-TRADE AND THE S ALE OF SUCH PLOT WERE RECORDED AS THE BUSINESS ACTIVITIES. THEREFORE , THE PROVISIONS OF SECTION 50C IS NOT APPLICABLE TO THE BUSINESS ACTIV ITIES, AS THE PROVISIONS OF SECTION 50C APPLICABLE ONLY IN THE CA SE OF COMPUTATION OF INCOME FROM CAPITAL GAINS. THEREFORE, THE MERIT OF THIS GROUND IS IN FAVOUR OF THE ASSESSEE. HENCE, GROUND RAISED BY THE REVENUE IS DISMISSED. 7. AS REGARDS GROUND NOS. 3 & 4 RELATING TO THE DIS ALLOWANCE OF RS. 1,29,00,000/- ON ACCOUNT OF EXTRA ORDINARY ITEM EXPENSE BY HOLDING IT TO BE BUSINESS EXPENDITURE, THE AO OBSER VED THAT THE ASSESSEE COMPANY DURING THE FY 2009-10 HAS PAID AN AMOUNT OF RS. 1,30,00,000/- (CLAIMED RS. 1,29,00,000 ONLY AS EXTR A ORDINARY ITEM FOR THE AY 2010-11) FOR RELEASE OF MORTGAGED PERSON AL PROPERTIES BELONGING TO SHRI ASHOK KUMAR MALPANI AND SMT. KIRA N DEVI WHO ACTED AS GUARANTORS ON BEHALF OF M/S MEGA BOWL PVT. LTD. FOR AVAILING LOAN OF RS. 1,50 CRORES FROM UCO BANK. THUS, THE AO OPINED THAT THIS PAYMENT OF RS.1,30,00,000/- MADE BY THE ASSESSEE CO MPANY IS ON BEHALF OF THIRD PARTIES TO CLEAR THEIR PERSONAL LIA BILITIES WHICH IS NOT RELATED TO ASSESSEE COMPANY BUSINESS AND THUS DOES NOT HAVE ANY BUSINESS EXPEDIENCY. HE, THEREFORE, DISALLOWED THE SAID AMOUNT OF RS. 129,00,000/-. 7.1 BEFORE THE CIT(A), THE ASSESSEE SUBMITTED THAT SINCE THE LIABILITY IS A BUSINESS LIABILITY, CRYSTALLIZED AND PAID, THE SAME MAY BE ALLOWED AS BUSINESS EXPENDITURE OF THE ASSESSEE AS THE SAME IS RELEVANT FOR PEACEFUL RUNNING OF THE BUSINESS AND A LSO DISCHARGE THE LIABILITY OF THE ASSESSEE COMPANY. FURTHER, HE SUBM ITTED THAT THE PROPERTIES OF THE COMPANY ARE NOT FREE HOLD AS ON T HE DATE OF PROVIDING GUARANTEE TO MEGA BOWL LTD., THE FAMILY REQUESTED MR. 6 ITA NO. 1217 /HYD/2013 M/S MAHESWARI MEGA VENTURES LTD. ASHOK KUMAR MALPANI TO PROVIDE THEIR PROPERTY AS PE RSONAL GUARANTEE. 7.2 THE CIT(A) AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESSEE, HELD THAT THERE IS A MERIT IN THE ARGUMENTS OF THE ASSESSEE THAT THE EXPENDITURE PERTAINS TO THE BUSINESS OF THE ASSESSE E AND, THEREFORE, DIRECTED THE AO TO DELETE THE ADDITION. 7.3. LD. DR SUPPORTED THE FINDINGS OF AO AND SUBMIT S THAT LD. CIT(A) HAS ALLOWED THE GROUND RAISED BY ASSESSEE WHEREAS T HE PROPERTY WAS NEVER CAPITALIZED IN THE BOOKS OF ASSESSEE. THEREFO RE, THE LIABILITIES DISCHARGED BY THE ASSESSEE IS IN FACT LIABILITIES O F PERSONAL, RELATING TO THE DIRECTORS. 7.4 LD. AR SUBMITTED THAT MR. ASHOK KUMAR MALPANI H AS GIVEN GUARANTEE TO THE UCO BANK FOR THE ASSETS BOUGHT BY M/S MEGA BOWL LTD. SUBSEQUENT TO DISPUTE, THE ASSETS WERE ACQUIRE D BY M/S MAHESWARI PLAZA RESORTS LTD. HE SUBMITTED THAT SUBS EQUENT TO FAMILY SETTLEMENT (REFER PAGE 13 OF PAPER BOOK), THIS ENTE RTAINMENT ASSETS ARE ALLOCATED TO MR. RAJKUMAR MALPANI AND HE CARRIE D ON THE BUSINESS IN THE NAME AND STYLE OF KNOCK 10 IN THE MPM MALL AND DECLARED THE PROFIT DULY SINCE 2005. HE SUBMITTED THAT THIS ASSE T WAS NOT CAPITALIZED IN THE BOOKS DUE TO DISPUTES AND CASE W AS PENDING BEFORE HIGH COURT. SINCE THIS LIABILITY IS CONNECTED TO TH E BUSINESS OF KNOCK 10, WHICH IS ALLOCATED TO MR. RAJKUMAR MALPANI. TH IS VENTURE WAS RUN UNDER THE BUSINESS OF ASSESSEE. HE SUBMITTED THAT T HEREFORE, THE LIABILITY DISCHARGED BY THE ASSESSEE IS NOTHING BUT BUSINESS LIABILITY. HE SUBMITTED THAT THE DISCHARGE OF LIABILITY IS CO NNECTED TO THE BUSINESS AND GUARANTEE WAS GIVEN BY MR. ASHOK KUMAR MALPANI. THEREFORE, THE SETTLEMENT WITH UCO BANK IS NOTHING BUT BUSINESS EXPENDITURE. 7 ITA NO. 1217 /HYD/2013 M/S MAHESWARI MEGA VENTURES LTD. 7.5 CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED TH E MATERIAL ON RECORD. THE FACTS AS PLACED ON RECORD ARE, M/S MEGA BOWL AND M/S MAHESWARI PLAZA RESORTS (P) LTD. ENTERED INTO CONTR ACT TO SET UP AN AMUSEMENT CENTRE AT MPM MALL OWNED BY THE MALPANI F AMILY. AS PER THE AGREEMENT, M/S MEGA BOWL WILL BRING IN 45.5% OF MARGIN MONEY OF THE VALUE OF AMUSEMENT ASSETS AND UCO BANK WILL FIN ANCE THE REST OF THE VALUE. FOR THAT PURPOSE, THE MALPANI FAMILY DIR ECTED SHRI ASHOK KUMAR MALPANI & HIS WIFE TO GIVE PERSONAL GUARANTEE BY OFFERING THE RESIDENTIAL PROPERTY OWNED BY THEM IN THE YEAR 2001 . AFTER THE FAMILY ARRANGEMENT IN 2005, THE MEGA MALL PROPERTY WAS ALL OCATED TO MR. RAJ KUMAR MALPANI. THESE ASSETS ARE MANAGED BY MR. RAJ KUMAR MALPANI UNDER M/S MAHESWARI MEGA VENTURES LD. THE LIABILITY RELATING TO THE MEGA MALL WERE NOT SETTLED AND UCO BANK HAS INITIAT ED LEGAL PROCEEDINGS AGAINST MR. ASHOK KUMAR MALPANI AS HE H AS GIVEN PERSONAL GUARANTEE. AS THE ASSETS ARE ALLOCATED TO M. RAJ KUMAR MALPANI CO., I.E. TO THE ASSESSEE, HENCE, THEY ENTE RED INTO SETTLEMENT AGREEMENT WITH THE UCO BANK AND GOT RELEASED THE PE RSONAL GUARANTEE OF THE BROTHER ASHOK KUMAR MALPANI. SINCE , THE GUARANTEE WAS GIVEN FOR ESTABLISHMENT OF AMUSEMENT BUSINESS, WHICH WAS ALLOCATED TO THE ASSESSEE. THIS IS THE EXPENDITURE INCURRED TO THE LIABILITY OF GUARANTEE GIVEN ON BEHALF OF M/S MAHES WARI PLAZA RESORTS (P) LTD., AFTER FAMILY ARRANGEMENT, IT HAS BECOME T HE LIABILITY OF THE ASSESSEE. THEREFORE, THE SETTLEMENT IS NOTHING BUT THE BUSINESS LIABILITY OF THE ASSESSEE. IT CLEARLY ESTABLISHES T HAT THE SETTLEMENT OF GUARANTEE HAS RELEASED THE BUSINESS OUT OF LITIGATI ONS AND BUSINESS LIABILITIES. BY THIS, ASSESSEE CAN RUN THE BUSINESS WITHOUT ANY HINDRANCES. THEREFORE, IN OUR VIEW, THIS IS BUSINES S LIABILITIES AND SUCH SETTLEMENT IS BUSINESS EXPENDITURE. IT CROSSED OUR MIND, WHETHER THIS SETTLEMENT EXPENDITURE IS CAPITAL IN NATURE BU T NOTED THAT THIS DOES NOT INCREASE THE USEFUL LIFE OF THE ASSET NOR IT WILL HAVE IMPACT ON THE VALUE OF ASSET. THEREFORE, IT CAN ONLY BE TREAT ED AS REVENUE EXPENDITURE. ACCORDINGLY, WE UPHOLD THE FINDINGS OF LD. CIT(A) AND THE GROUND RAISED BY THE REVENUE IS DISMISSED. 8 ITA NO. 1217 /HYD/2013 M/S MAHESWARI MEGA VENTURES LTD. 8. IN THE RESULT, APPEAL OF THE REVENUE IS DISMISSE D. PRONOUNCED IN THE OPEN COURT ON 21 ST MARCH, 2018. SD/- SD/- (P. MADHAVI DEVI) (S. RIFAUR RAHM AN) JUDICIAL MEMBER A CCOUNTANT MEMBER HYDERABAD, DATED: 21 ST MARCH, 2018 KV COPY TO:- 1) DCIT, CIRCLE 16(2), 2 ND FLOOR, B BLOCK, IT TOWERS, AC GUARDS, MASAB TANK, HYDERABAD. 2) M/S MAHESWARI MEGA VENTURES LTD., 4-1-833, 3 RD FLOOR, MPM MALL, ABIDS, HYDERABAD 500 001 3) CIT(A) V, HYD. 4) CIT IV, HYD. 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDE RABAD. 6) GUARD FILE