DCIT, Circle-3(1), Hyd, Hyderabad V. R.K. Township Promoters (P) Ltd., Hyd, Hyderabad

ITA 1221/HYD/2016

• Counselvise Citation: [2017] 130 COUNSELVISE.COM (IT) 6029 (ITAT-HYDERABAD)
• Duration Of Justice: 6 month(s) 11 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-03-2017
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2012-2013
• Appeal Filed On: 19-09-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SUMAN MALIK
• Keywords: Search and seizure; Corroborative evidences
• Section: 44AD

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. 1221/HYD/2016 ASSESSMENT YEAR: 2012-13 DY. COMMISSIONER OF INCOME- TAX, CIRCLE 3(1), HYDERABAD. VS. R.K. TOWNSHIP PROMOTERS (P) LTD., HYDERABAD. PAN AACCR3049K (APPELLANT) (RESPONDENT) REVENUE BY : SMT. SUMAN MALIK ASSESSEE BY : SHRI K.C. DEVDAS DATE OF HEARING : 16-03-2017 DATE OF PRONOUNCEMENT : 31-03-2017 O R D E R PER S. RIFAUR RAHMAN, A.M.: THIS IS AN APPEAL OF THE REVENUE DIRECTED AGAINST THE ORDER OF THE LEARNED COMMISSIONER OF INCOME-TAX(A) - 3, HYDE RABAD, DATED 02/06/2016 FOR AY 2012-13. 2. BRIEFLY THE FACTS OF THE CASE ARE THAT A SSESSEE IS ENGAGED IN THE BUSINESS OF REAL ESTATE. IT PURCHASES THE LAND, DEV ELOPS THE LAND INTO PLOTS AND SELLS THE SAME. IT FILED RETURN OF INCOME OF RS. 45,54,920/- FOR AY 2012-13 ON 01/10/2012. IN THE SCRUTINY ASSES SMENT, THE INCOME WAS DETERMINED AT RS. 1,75,87,884/- BY ESTIM ATING THE PROFITS AT 15% OF GROSS SALES. 2.1 THE REASONS GIVEN BY THE AO FOR REJECTING THE B OOKS OF ACCOUNTS AND ESTIMATING THE PROFITS AT 15% OF TURNO VER ARE AS UNDER: 2 ITA NO. 1221/H/16 RK TOWNSHIP PROMOTERS (P) LTD., HYD. (A) THAT THERE WAS INCREASE IN PAYMENT OF COMMISSIO N TO RS. 81,36,945/- DURING THE PRESENT YEAR AGAINST SIMILAR PAYMENT OF RS. 26,66,844/- IN IMMEDIATE PREVIOUS YEAR EVEN THO UGH THERE WAS DECREASE IN SALES DURING THE YEAR. THE ASSESSEE DID NOT PRODUCE ANY SUPPORTING EVIDENCE, DID NOT FILE DETAI LS OF AGENTS, AND DID NOT SUBMIT BASIS OF COMMISSION PAYMENT, AS TO WHAT PERCENTAGE OF COMMISSION WAS PAID. (B) THE SALES WERE TO THE TUNE OF RS. 11,61,99,920/ -, WHEREAS NET PROFIT WAS ONLY RS. 47,37,872/- WHICH WORKS OUT TO 4.2% OF TURNOVER. (C) ON EXAMINATION OF BOOKS OF ACCOUNTS, IT WAS FOU ND THAT MUCH OF THE EXPENSES WERE INCURRED IN CASH, EACH PAYMENT BEING LESS THAN RS. 20,000/-. JOURNAL ENTRIES WERE PASSED AT T HE END OF THE YEAR TRANSFERRING EXPENDITURE INCURRED AT BRANCHES. (D) THE EXPENDITURE WAS SUPPORTED BY SELF MADE VOUC HERS AND NOT SUSCEPTIBLE FOR VERIFICATION. (E) THE EXPENSES WERE CLAIMED AS AND WHEN THEY WERE INCURRED, WHEREAS THE SALES WERE RECOGNIZED ONLY WHEN THE PRO PERTY WAS SOLD AND REGISTERED IN THE NAME OF PURCHASER. THERE FORE THERE IS NO MATCH BETWEEN EXPENDITURE AND SALES. (F) THAT FOR THE EARLIER ASSESSMENT YEAR, ESTIMATIN G THE INCOME WAS CONFIRMED BY THE CIT(A) AND THE HON'BLE ITAT. IN THE ABOVE FACTS AND CIRCUMSTANCES, ESPECIALLY TH E ASSESSEE'S FAILURE TO FURNISH DETAILS AND ASSESSEE'S INABILITY TO IDENTIFY THE EXPENDITURE RELATED TO CURRENT YEAR, THE ASSESSING OFFICER WAS NOT SATISFIED WITH THE CORRECTNESS OR COMPLETENESS OF ACCOUNTS, THEREFORE HELD THAT TRUE AND CORRECT INCOME CANNOT BE DETERMINED FROM THE BOOKS, THEREFORE THE SAME WERE REJECTED U/ S 145(3) OF INCOME TAX ACT AND INCOME WAS ESTIMATED AT 15% OF G ROSS SALES. 3. AGGRIEVED BY THE ORDER OF THE AO, THE ASSESSEE P REFERRED AN APPEAL BEFORE THE CIT(A). 4. BEFORE THE CIT(A), THE ASSESSEE SUBMITTED AS UND ER: (A) THAT THE BOOKS OF ACCOUNTS WERE MAINTAINED WHIC H WAS ALSO CONFIRMED BY ASSESSING OFFICER IN THE ASSESSMENT OR DER. THE SAME WERE SUBJECTED TO AUDIT BY CHARTERED ACCOUNTAN T, BASED ON WHICH FINANCIAL STATEMENTS WERE PREPARED AND RETURN OF INCOME WAS FILED. 3 ITA NO. 1221/H/16 RK TOWNSHIP PROMOTERS (P) LTD., HYD. (B) THE ASSESSING OFFICER MADE ONLY GENERAL OBSERVA TIONS WITH REGARD TO MAINTENANCE OF ACCOUNTS AND DID NOT SPECI FY THE DEFICIENCIES OR INCONSISTENCIES IN THE BOOKS OF ACC OUNTS. (C) THE HON'BLE SUPREME COURT IN THE CASE OF INDORE MALWA UNITED MILLS LTD. VS STATE OF MADHYA PRADESH (10 IT R 41) OBSERVED THAT WHEN AN ASSESSEE PRODUCED BEFORE THE AUTHORITY ALL THE REGISTERS, IT WAS NOT OPEN TO THE DEPARTMEN T TO PICK AND CHOOSE SOME OF THE REGISTERS WHICH WERE MORE FAVOUR ABLE TO THE REVENUE IN THE ABSENCE OF FINDING OF UNRELIABILITY OF ANY OF THE ENTRIES OR ANY OF THE REGISTERS. (D ) THAT THE ESTIMATION OF PROFIT AT 15% IS UNREAS ONABLY HIGH AND 15% WAS ADOPTED BY ASSESSING OFFICER BECAUSE THE SA ME PERCENTAGE WAS ADOPTED FOR THE EARLIER YEARS. REAL ESTATE BUSINESS WAS IN SHAMBLES BECAUSE OF TELANGANA AGITA TION. IGNORING THESE FACTS, THE ASSESSING OFFICER ADOPTED PROFIT AT 15% WITHOUT ANY BASIS. RELIANCE IS PLACED ON THE DECISI ON OF MADHYA PRADESH HIGH COURT IN THE CASE OF RAMDAS JUGANI VS CIT (282 ITR 356), WHEREIN IT WAS HELD THAT IN MAKING BEST J UDGMENT ASSESSMENT, THE ASSESSING OFFICER SHOULD NOT BE VIN DICTIVE OR CAPRICIOUS. THE ASSESSMENT SHOULD BE BONAFIDE AND A RRIVED AT ON A RATIONAL BASIS. (E) THE HON'BLE ITAT IN APPELLANT'S OWN CASE FOR A. Y.2000-01 TO 2006-07 VIDE ITS ORDER DATED 29.4.2016 DIRECTED THE ASSESSING OFFICER TO ESTIMATE PROFIT AT 8% ON SALES. IN VIEW OF THE ABOVE SUBMISSIONS THERE IS NO REASON FOR AO TO REJECT THE BOOKS OF ACCOUNTS. EVEN IF THE BOOKS WER E REJECTED, THE ESTIMATION SHOULD BE MADE ON REASONABLE BASIS K EEPING IN VIEW THE FACTS AND CIRCUMSTANCES OF THE PAST RECORD OF THE CASE. 5. AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESS EE THE CIT(A) OBSERVED THAT THE ASSESSING OFFICER DID NOT POINT A NY SPECIFIC DEFECTS IN THE BOOKS OF ACCOUNTS BEFORE ARRIVING AT THE CON CLUSION THAT THE TRUE AND CORRECTNESS OF INCOME COULD NOT BE DETERMI NED IN THE BOOKS OF ACCOUNTS. HE FURTHER OBSERVED THAT EXCEPT STATIN G THAT THE COMMISSION PAID DURING THE YEARS IS ON HIGHER SIDE COMPARED TO COMMISSION PAID IN IMMEDIATE PREVIOUS YEAR, AND ALS O STATING THAT MOST OF THE EXPENSES WERE IN CASH AND SUPPORTED BY SELF MADE VOUCHERS, NO SPECIFIC OR SERIOUS LAPSE IN MAINTAINI NG THE ACCOUNTS IS QUOTED BY THE ASSESSING OFFICER. THE CIT(A) WAS OF THE VIEW THAT SELF 4 ITA NO. 1221/H/16 RK TOWNSHIP PROMOTERS (P) LTD., HYD. MADE VOUCHERS ARE UNAVOIDABLE AS THE WORKS ARE CARR IED OUT WITH UNSKILLED AND ILLITERATE LABOUR. IT APPEARS THAT TH E ASSESSING OFFICER RESORTED TO ESTIMATION OF INCOME AT 15% ONLY ON THE GROUND THAT EVEN FOR EARLIER YEARS, THE INCOME WAS ESTIMATED AT THE SAME PERCENTAGE. 5.1 IN VIEW OF THE ABOVE OBSERVATIONS AND FOLLOWIN G THE DECISION OF THE ITAT IN ASSESSEES OWN CASE FOR AY 2000-01 TO 2 006-07, THE CIT(A) DIRECTED THE ASSESSING OFFICER TO ESTIMATE T HE PROFITS AT 8% OF SALES. 6. AGGRIEVED BY THE ORDER OF THE CIT(A) THE REVENUE IS IN APPEAL BEFORE US RAISING THE FOLLOWING GROUNDS OF APPEAL: 1. THE CIT(A) ERRED BOTH IN LAW AND ON FACTS OF THE CASE. 2. THE LD. CIT(A) ERRED IN REDUCING THE PROFIT RATE FROM 15% TO 18% WITHOUT APPRECIATING THE REASONS GIVEN BY THE A O. 7. BEFORE US, THE LD. AR OF THE ASSESSEE SUBMITTED THAT THE ISSUE IS COVERED BY THE DECISION OF THE COORDINATE BENCH IN ASSESSEES OWN CASE FOR AYS 2008-09 TO 2010-11 IN ITA NOS. 1656 & 1657/HYD/2012 AND 352/HYD/2015 VIDE ORDER DATED 21/10/2016. A COP Y OF THE SAID ORDER IS AVAILABLE ON RECORD. 8. ON THE OTHER HAND, LD. DR NEITHER CONTROVERTED T O THE SUBMISSIONS OF THE LD. AR NOR BROUGHT ANY CONTRARY DECISION ON RECORD. 9. CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL FACTS ON RECORD. THE COORDINATE BENCH OF THIS TRIBUNAL IN ASSESSEES OWN CASE FOR AYS 2008-09 TO 2010-11, FOLLOWING ITS DECI SION IN ASSESSEES OWN CASE FOR AYS 2000-01 TO 2006-07, DIRECTED THE A O TO DETERMINE THE NET PROFIT OF 8% ON THE SALES DISCLOSED BY THE ASSESSEE. FOR THE SAKE OF CLARITY, WE REPRODUCE THE OBSERVATIONS OF T HE COORDINATE BENCH IN ASSESSEES OWN CASE FOR AYS 2000-1 TO 2006 -07 AS UNDER: 5 ITA NO. 1221/H/16 RK TOWNSHIP PROMOTERS (P) LTD., HYD. 13.2 THERE IS NO DOUBT THAT THE BOOK KEEPING ADOPT ED BY THE ASSESSEE WAS COMPLEX AND THE RELEVANT DATA GENE RATED BY THE ASSESSEE BASED ON BILLS AND VOUCHERS WERE NO T AVAILABLE WITH THE ASSESSEE AND PART OF THE DOCUMEN TS WERE SEIZED BY THE DEPARTMENT, WHICH WAS USED BY THE SPE CIAL AUDITOR TO RECAST THE P&L A/C. THE DEGREE OF RELIAN CE AND RELIABILITY OF INFORMATION ADOPTED BY THE SPECIAL A UDITOR IS THE MAIN GROUNDS OF APPEAL BY THE ASSESSEE. THERE IS NO DISPUTE THAT THE SPECIAL AUDITOR HAD TO RELY ON THE INFORMATION AVAILABLE WITH HIM & WITH THE AO WHICH WERE ACQUIRED DUE TO SEARCH AND SEIZURE OPERATION. THE A SSESSEE ALSO EXPRESSED IN ONE OF THE COMMUNICATION WITH THE SPECIAL AUDITOR THAT DUE TO EFFLUX OF TIME, THE ASSESSEE WA S NOT IN A POSITION TO SUBMIT THE RELEVANT BILLS AND VOUCHERS EITHER BECAUSE OF SEIZURE OR NOT IN A POSITION TO SUBMIT D UE TO THE FACT THAT THE PASSAGE OF TIME, SHIFTING OF PREMISES ETC. 13.3 WE ARE IN AGREEMENT WITH THE ASSESSEE THAT THE RELIABILITY OF THE SPECIAL AUDIT REPORT AND RECASTI NG OF P&L A/C WERE COMPUTED BASED ON THE INFORMATION AVAILABL E AND PRESUMPTIONS ADOPTED BY SPECIAL AUDITOR. IT IS WORT HWHILE TO MENTION HERE THAT THE INCOME STATUS GENERATED BY SP ECIAL AUDITOR ARE NOT CORRELATING TO THE TURNOVER OF THE COMPANY, I.E. OUT OF SEVEN AYS, IN THREE AYS ARE LOSS. IN TH E REAL ESTATE BUSINESS, THE PROFIT GENERATED AGAINST SALES HAS TO BE ON THE BAND RANGE, IT CANNOT BE FLUCTUATING IN SUCH HIGH DEGREE. THE PROFIT HAS TO BE ARRIVED BASED ON THE M ATCHING PRINCIPLE, IN OUR CONSIDERED VIEW, THE SPECIAL AUDI TOR HAS FAILED IN THIS REGARD. THE RELATED COST HAS TO BE A LIGNED WITH THE RELEVANT SALES/COLLECTION. IN THE ABOVE STATED SITUATION, WE ARE INCLINED TO SUGGEST THAT THE BOOKS OF ACCOUN T MAINTAINED BY THE ASSESSEE MUST BE REJECTED, AT THE SAME TIME, THE RECASTED ACCOUNT CANNOT BE RELIED UPON DU E TO RELIABILITY FACTOR. 13.4 WE ARE LEFT WITH THE OVERALL TURNOVER OF THE A SSESSEE AND NET INCOME DETERMINED BY THE AO, CIT(A) , SPECI AL AUDITOR AND ESTIMATED PROFIT @ 15% IN THE SUBSEQUEN T YEAR BY THIS COORDINATE BENCH. WE CANNOT ADOPT 15% OF SA LES SIMPLY BECAUSE THE COORDINATE BENCH TREATED THE BUS INESS OF THE ASSESSEE AS CIVIL CONTRACT BUSINESS AND THE SAM E WAS NOT CONTROVERTED BY THE ASSESSEE. BUT FROM THE RECO RDS SUBMITTED BEFORE US BY BOTH ASSESSEE & DR AS THE BU SINESS OF ASSESSEE IS IN REAL ESTATE DEALING ONLY IN BUYIN G, DEVELOPING AND SELLING LANDS. 13.5 THE RELEVANT DATA BEFORE US ARE (EXTRACTED FRO M PAPER BOOK SUBMITTED BY THE ASSESSEE) CUMULATIVE FIGURES 6 ITA NO. 1221/H/16 RK TOWNSHIP PROMOTERS (P) LTD., HYD. A) CUMULATIVE TURNOVER FOR 7 AYS 100.61 CRORES (AS PER SPECIAL AUDIT REPORT ACCEPTED BY THE ASSESS EE) B) INCOME ASSESSED BY ACIT 21.20 CRORES (21.07%) C) INCOME ASSESSED BY CIT(A) 11.64 CRORES (11.57%) D) INCOME COMPUTED BY SPECIAL AUDITOR 9.71CRORES(9. 65%) WHILE ANALYZING THE ABOVE VALUES, WE ARE OF THE VIE W THAT INCOME ASSESSED BY ACIT IS RULED OUT AS IT IS AT 21 .07% AS THE ABOVE % IS MORE THAN 15%, WHICH WAS ALREADY REJ ECTED BY ITAT AND ALSO THE PROFIT ARRIVED WERE BEFORE SPE CIAL AUDIT. SIMILARLY, THE ASSESSEE HAD SUBMITTED & RELIED ON T HE CASE LAW IN THE CASE OF MADHAV PROPCON PVT. LTD., OF DEL HI ITAT, WHEREIN IT WAS HELD THAT THE INCOME OF THE ASSESSEE S AT 2.24% OF THE TOTAL GROSS RECEIPTS, WHO ARE ENGAGED IN THE BUSINESS OF LAND DEVELOPMENT ACTIVITIES. WE CANNOT FOLLOW THIS PERCENTAGE BECAUSE THE ACTIVITIES INVOLVED WER E ONLY FOR LAND DEVELOPMENT ACTIVITIES BUT IN THE PRESENT CASE THE ASSESSEE IS IN THE ACTIVITIES WHICH INVOLVE PURCHAS E, DEVELOPMENT AND SALE OF LAND. WITH RESPECT TO CIT(A ) ARRIVED AT THE PROFIT OF RS. 11.64 CRORES AS CUMULATIVE PRO FIT FOR 7 YEARS (I.E. 11.57%). BUT HE HAD ACCEPTED THE SPECIA L AUDIT PROFIT AS THE BASE AND GAVE PARTIAL RELIEF TO ASSES SEE BY DELETING THE DISALLOWANCE MADE ON SITE DEVELOPMENT ETC. AFTER DELETING THE DISALLOWANCE MADE BY THE AO, THE PROFIT ARRIVED BY THE CIT(A) IS MORE THAN THE SPECIAL AUDI TOR. THE CIT(A) HAD ACCEPTED THE SPECIAL AUDITORS REPORT AND PROFIT ARRIVED BY THEM, THE MERE ADJUSTMENT CANNOT INCREAS E THE PROFIT ARRIVED BY SPECIAL AUDITORS. CIT(A) HAS NOT FOUND ANYTHING NEW WHILE ADJUDICATING BUT HAD ONLY REJECT ED THE GROUNDS RAISED BY THE ASSESSEE. HENCE, THERE CANNOT BE ANY INCREMENTAL PROFIT ARRIVED BY CIT(A). HENCE, THE PR OFIT ARRIVED AFTER CONSEQUENTIAL TO CIT(A)S ORDER CANNO T BE RELIED. 13.6 WE ARE LEFT WITH INCOME COMPUTED BY SPECIAL AU DITOR AT 9.65%. BUT THIS INCOME ARRIVED BY SPECIAL AUDITOR B Y ADOPTING PRESUMPTIONS AND MODIFYING THE VALUES OF PURCHASE, SALES, OPENING AND CLOSING STOCK. BASED O N THE SUBMISSIONS OF DR AND ASSESSEE, WE ARE OF THE VIEW THAT THE RELIABILITY OF THE SPECIAL AUDIT COULD BE IN BE TWEEN 80- 85%. ON APPLYING THE RELIABILITY FACTOR TO THE INCO ME DETERMINED BY SPECIAL AUDITOR OF 9.65%, WE WILL END UP ARRIVING THE INCOME AT 8%, WHICH IS SIMILAR TO SECT ION 44AD. 13.7 ON THE OTHER HAND, THE PROVISIONS OF SECTION 4 4AD PROPOSED TO ADOPT 8% OF THE TOTAL TURNOVER OR GROSS RECEIPTS OF THE ASSESSEE SHALL BE DEEMED TO BE PROFITS & GAI NS OF THE 7 ITA NO. 1221/H/16 RK TOWNSHIP PROMOTERS (P) LTD., HYD. BUSINESS CHARGEABLE TO TAX. THIS SECTION PRESCRIBES A THUMB RULE OR PRESUMPTIVE NET PROFIT RATE APPLIED FOR THO SE ASSESSEES WHOSE TURNOVER ARE LESS THAN ONE CRORE. N O DOUBT, THE TURNOVER OF THE ASSESSEE IS MORE THAN TH E PRESCRIBED LIMIT IN THE SECTION 44AD BUT IT GIVES T HUMB RULE TO ESTIMATE THE INCOME OF THE ASSESSEE. WHEN THE BO OKS ARE NOT MAINTAINED OR REJECTED, FLAT RATE OF 8% CAN BE ADOPTED AS DECIDED BY THE HONBLE DELHI HIGH COURT IN THE CASE OF CIT VS. SUBODH GUPTA, ITA N 80 OF 2014, DATED 09/12/201 4. 13.8 THE ABOVE DECISION IS RELEVANT PARTICULARLY WH EN THE REVENUE COULD NOT SUBMIT OR ASCERTAIN WHO HAD DECLA RED HIGHER PERCENTAGE OF INCOME, WHO ARE IN THE SIMILAR BUSINESS OF ASSESSEE. IN OUR CONSIDERED VIEW, IN TH E PRESENT CASE, THE BOOKS OF THE ASSESSEE CANNOT BE ACCEPTED DUE TO THE COMPLEXITY OF THE NATURE OF BUSINESS AND MAINTE NANCE OF BOOKS OF ACCOUNT AT THE SAME TIME THE RECASTED PROF ITS & LOSS COMPUTED BY THE SPECIAL AUDITOR ALSO HAS RELIA BILITY ISSUE, WHICH WERE COMPUTED BASED ON PRESUMPTIONS. T HIS IS THE FIT CASE TO ESTIMATE THE INCOME OF THE ASSESSEE . IN THIS GIVEN SITUATION, THE PRESUMPTIVE RATE AVAILABLE IN THE SECTION 44AD MAY BE ADOPTED EVEN THOUGH THE TURNOVER OF THE ASSESSEE IS MORE THAN THE TURNOVER OF THE ELIGIBLE ASSESSEE AS PRESCRIBED IN THE SECTION 44AD. THIS IS THE RATE WHICH IS NEAR TO THE PERCENTAGE ARRIVED AFTER FACTORING THE RELIABILITY AND THE INCOME COMPUTED BY THE SPECIAL AUDITOR. HEN CE, WE DIRECT THE AO TO ADOPT 8% OF THE SALES AS DETERMINE D BY THE SPECIAL AUDITOR, TO COMPUTE THE INCOME OF THE ASSES SEE YEAR TO YEAR BASIS FOR AY 2000-01 TO 2006-07. 7.1 AS THE ISSUE UNDER CONSIDERATION IS MATERIALLY IDENTICAL TO THAT OF AYS 2000-01 TO 2006-07 AND 2008-09 TO 2010-11 IN ASSESSEES OWN CASES, RESPECTFULLY FOLLOWING THE DECISION OF C OORDINATE BENCH IN THOSE YEARS, WE CONFIRM THE ORDER OF THE CIT(A) IN DIRECTING THE AO TO ESTIMATE INCOME OF THE ASSESSEE @ 8% OF THE SALES. 8 ITA NO. 1221/H/16 RK TOWNSHIP PROMOTERS (P) LTD., HYD. 8. IN THE RESULT, APPEAL OF THE REVENUE IS DISMISSE D. PRONOUNCED IN THE OPEN COURT ON 31 ST MARCH, 2017. SD/- SD/- (P. MADHAVI DEVI) (S. RIFAUR RAH MAN) JUDICIAL MEMBER ACC OUNTANT MEMBER HYDERABAD, DATED:31 ST MARCH, 2017. KV COPY TO:- 1) DCIT, CIRCLE 3(1), ROOM NO. 714, 7 TH FLOOR, SIGNATURE TOWERS, OPP. BOTANICAL GARDEN, KONDAPUR, HYDERABAD. 2) M/S RK TOWNSHIP PROMOTERS (P) LTD., NO. 8-3-319/ 11, DOYEN CHAMBERS, 3 RD FLOOR, BESIDES SARADHI STUDIO, AMEERPET, HYDERABAD. 3) CIT(A) - 3, HYDERABAD 4 PR. CIT - 3, HYDERABAD 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDE RABAD. 6) GUARD FILE