Shiva Shakthi Shiridi Sai Anugraha Mahapeetam, Hyderabad V. Dy.Director of Income Tax (Exemptions), Hyderabad

ITA 1232/HYD/2014

• Counselvise Citation: 123222514 RSA 2014
• Duration Of Justice: 5 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 03-12-2014
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: misc
• Appeal Filed On: 23-06-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: D SUDHAKAR RAO
• Assessee Lawyers: C P RAMASWAMI
• Keywords: Charitable institution
• Section: 12A; 12AA; 12; 11

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPEETAM, HYDERABAD PAN AALTS 6316G DY. DIRECTOR OF INCOME-TAX (EXEMPTIONS), HYDERABAD. (APPELLANT) (RESPONDENT) ASSESSEE BY SHRI C.P. RAMASWAMI REVENUE BY SHRI D. SUDHAKAR RAO DATE OF HEARING 11-11-2014 DATE OF PRONOUNCEMENT 03-12-2014 O R D E R PER SAKTIJIT DEY, J.M.: THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST OR DER DATED 29/04/14 PASSED BY THE DIT(E), HYDERABAD, REJECTI NG ASSESSEES APPLICATION FOR GRANT OF REGISTRATION U/S 12A OF TH E ACT. 2. BRIEFLY THE FACTS ARE, APPELLANT CLAIMING ITSELF TO BE A CHARITABLE TRUST WAS CREATED VIDE REGISTERED DEED DATED 17/05/ 12. IT FILED APPLICATION SEEKING REGISTRATION U/S 12A OF THE AC T BEFORE LD. DIT(E) IN THE PRESCRIBED MANNER ON 15/06/12. LD. DIT(E), H OWEVER, REFUSED TO GRANT REGISTRATION TO APPELLANT TRUST ON THE GRO UND THAT IT HAS NOT COMMENCED ITS ACTIVITIES. BEING AGGRIEVED OF THE OR DER PASSED BY LD. DIT(E), ASSESSEE APPROACHED THE ITAT BY FILING AN A PPEAL REGISTERED AS ITA NO. 198/HYD/2013. THE COORDINATE BENCH OF TH IS TRIBUNAL WHILE DISPOSING OF THE APPEAL VIDE ORDER DATED 24/05/13 R EMITTED THE MATTER BACK TO THE FILE OF LD. DIT(E) WITH THE FOLLOWING D IRECTIONS: 2 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM 9. IN THE CASE BEFORE US, THE TRUST APPROACHED THE DIT(E) FOR REGISTRATION WITHIN TWO MONTHS OF ITS CREATION/ FORMATION, AND THEREFORE, TWO OBJECTS OF THE TRUST FOR WHICH IT WA S FORMED WILL HAVE TO BE EXAMINED BY THE AUTHORITY. THE REGISTRAT ION AUTHORITY SHOULD CONSIDER THE GENUINENESS OF THE AIMS AND OBJ ECTS OF THE APPLICANT SOCIETY SEEKING REGISTRATION U/S 12AA OF THE ACT WITH A CHARITABLE OBJECTIVE. AT THIS STAGE, COMMENCEMENT O F THE CHARITABLE ACTIVITY CANNOT BE THE CRITERIA, SINCE T HE TRUST IS YET TO COMMENCE ITS ACTIVITIES. IN SPITE OF THAT, THE ASSE SSEE TRUST IN THE PRESENT CASE, DID FURNISH THE LIST OF DONORS AN D ALSO DETAILS OF THE APPLICATION OF THE FUNDS TILL THE DATE OF TH E ENQUIRY BY THE DIT(E). IN THESE CIRCUMSTANCES, WE ARE OF THE OPINI ON THAT IMPUGNED ORDER IS NOT SUSTAINABLE AND IT DESERVES T O BE SET ASIDE. THEREFORE, WE SET ASIDE THE SAME. APPEAL OF THE ASSESSEE IS CONSEQUENTLY ALLOWED, WITH A DIRECTION TO THE DIT(E) TO EXAMINE THE AIMS AND OBJECTS OF THE ASSESSEE TRU ST AND GRANT REGISTRATION U/S 12AA OF THE ACT, SINCE HE HAS NOT EXAMINED THE OBJECTS, WHICH PRIMA-FACIE INDICATE THAT THEY ARE C HARITABLE IN NATURE. HOWEVER, THE ISSUE IS RESTORED TO THE FILE OF THE DIT(E) TO EXAMINE THE OBJECTS AND THEN GRANT REGISTRATION BY PASSING FRESH ORDER IN ACCORDANCE WITH LAW. NEEDLESS TO SAY , ASSESSEE SHALL BE GIVEN REASONABLE OPPORTUNITY TO PUT FORTH ITS CASE WITH REFERENCE TO THE APPLICATION OF REGISTRATION. WE DI RECT ACCORDINGLY. 3. IN PURSUANCE TO THE DIRECTIONS OF ITAT, LD. DIT( E) REVIVED THE PROCEEDING AFRESH. AS MENTIONED BY LD. DIT(E) ON GO ING THROUGH THE OBJECTS OF THE TRUST DEED, HE FOUND THAT OUT OF THE 40 OBJECT CLAUSES, OBJECTS AT S. NOS. XVII, XXV, XXVII, XXVIII, XXXIII , XXXIV & XL ARE OF RELIGIOUS NATURE. HE, THEREFORE, WAS OF THE VIEW TH AT AS ASSESSEE IS HAVING BOTH CHARITABLE AND RELIGIOUS OBJECTS, WHERE AS AS PER SECTION 11(1)(A) FOR AVAILING EXEMPTION A TRUST OR INSTITUT ION CAN EITHER BE CHARITABLE OR RELIGIOUS IT CANNOT BE GRANTED RE GISTRATION. ACCORDINGLY, HE ISSUED A SHOW CAUSE NOTICE TO ASSES SEE TO EXPLAIN WHY THE TRUST SHOULD BE GRANTED REGISTRATION AS IT IS HAVING MIXED OBJECTS. IN RESPONSE TO THE SHOW CAUSE NOTICE, ASSE SSEE FILED A DETAILED REPLY CLARIFYING ITS POSITION BY STATING T HAT OBJECT CLAUSES REFERRED TO BY LD. DIT(E), ARE ONLY ANCILLARY OR IN CIDENTAL TO THE MAIN OBJECTS WHICH IS CHARITABLE. EVEN OTHERWISE ALSO, T HEY CANNOT BE CONSIDERED TO BE FOR THE BENEFIT OF ANY PARTICULAR RELIGIOUS COMMUNITY, CASTE OR CREED. IT WAS SUBMITTED, THE ACTIVITIES PR OVIDED IN THE CLAUSES 3 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM REFERRED TO IS TAKEN UP AS INCIDENTAL AND ANCILLARY TO ATTAINMENT OF THE MAIN OBJECTS AND ARE FOR BENEFIT OF ALL COMMUNITIES IN GENERAL AND NOT FOR EXCLUSIVE BENEFIT OF ANY COMMUNITY OR RELIGION. IT WAS SUBMITTED THAT SPIRITUALITY IS THE INNER SELF OF EVERY HUMAN BEING, THE RELIEF AND EDUCATION EMBRACES BOTH OUTER I.E. PHYSICAL AS WELL AS THE INNER SPIRIT OF THE HUMAN BEINGS. IT WAS SUBMITTED THAT PROMOTI ON OF RESEARCH IN THE SUBJECTS OF ANCIENT SPIRITUALITY I.E. FOR THE C OMPLETE EXPOSITION OF INNER HUMANITY AND THE COMPLETE HUMANNESS IS NOT AN OBJECT OF RELIGIOUS NATURE. IT WAS SUBMITTED THAT OBJECT CLAU SES OBJECTED TO BY LD. DIT(E) CANNOT BE SAID TO BE FOR THE BENEFIT OF A PARTICULAR RELIGION OR COMMUNITY, BUT, THE SAME ARE FOR THE BENEFIT OF THE WHOLE OF THE MANKIND. IT WAS SUBMITTED THAT SANATHANA DHARMA IS A WAY OF CHERISHED LIFE. THE MORALS OF EPICS LIKE RAMAYANA, MAHABHARATA AND THE TEACHINGS OF THE PROPHET OR JESUS, MAHAVEERA, G AUTHAM BUDDHA ETC. ALL SPEAK OF THE SAME. A SYNTHETIC TEACHING O F THESE TENETS OF LIFE ADDRESSES THE CONCEPT OF UNIVERSAL ENHANCEMENT OF V ALUES OF HUMAN LIFE AND NOT JUST BENEFIT ONLY A PARTICULAR RELIGIO N OR COMMUNITY. EVEN THE VEDA PRAVACHANAM CANNOT BE TREATED AS RELIGIOUS ACTIVITY. IT WAS SUBMITTED THAT EVERY TEACHING THAT MODULATES PHYSIC AL, EMOTIONAL AND SPIRITUAL BEHAVIOR OF THE HUMAN BEING SHALL HAVE SO ME BASIS, BUT THE PROBLEM COMES ONLY WHEN THE PRIVILEGE AS IN THE CAS E OF TRADITIONAL CASTE SYSTEM IS EXTENDED TO A PARTICULAR GROUP OR C OMMUNITY. IT WAS SUBMITTED THAT THE TERM VEDA ITSELF MEANS KNOWLED GE AND NOT RELIGION, THEREFORE SETTING UP VEDIC PATHASALAS IS NOT A RELIGIOUS ACTIVITY. IT WAS SUBMITTED THAT PRODUCING DEVOTIONA L MOVIES, TV SERIALS RELATING TO VEDIC SCRIPTURES ETC., AND PROP AGATION OF TENETS OF VARIOUS RELIGIOUS TEACHINGS AND THE TEACHINGS OF VA RIOUS GURUS IS NOT FOR THE BENEFIT OF A PARTICULAR RELIGION OR COMMUNI TY BUT FOR THE MORAL EDUCATION OF THE PEOPLE OF ALL SECTIONS IN THE SOCI ETY. IT WAS SUBMITTED BY APPELLANT TRUST THAT HONBLE SUPREME COURT IN C ASE OF CIT, UJJAIN VS. DAWOODI BOHARA JAMAT, CIVIL APPEAL NO. 2492 OF 2014 ARISING OUT OF SLP NO. 9004 OF 2010, HELD THAT A CHARITABLE AN D RELIGIOUS TRUST WHICH DOES NOT BENEFIT ANY SPECIFIC RELIGIOUS OR CO MMUNITY , CAN CLAIM 4 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM EXEMPTION U/S 11. THEREFORE, A TRUST HAVING MIXED O BJECTS OF BOTH CHARITABLE AND RELIGION NATURE IS ELIGIBLE FOR BENE FIT OF SECTION 11, HENCE, CANNOT BE DENIED REGISTRATION U/S 12A. 4. LD. DIT(E) AFTER CONSIDERING THE SUBMISSIONS OF ASSESSEE, HOWEVER, DID NOT FIND MERIT IN THE SAME. RELYING UP ON CERTAIN DECISIONS LD. DIT(E), ULTIMATELY, CONCLUDED THAT AS ASSESSEE IS HAVING MIXED OBJECTS I.E. BOTH CHARITABLE AND RELIGIOUS, I T CANNOT BE GRANTED REGISTRATION U/S 12A OF THE ACT. 5. THE LEARNED AR REITERATING THE SUBMISSIONS MADE BEFORE LD. DIT(E) SUBMITTED THAT APPELLANT TRUST CANNOT BE SAI D TO BE FOR THE BENEFIT OF PARTICULAR RELIGION, COMMUNITY OR CREED, HENCE, THE OBJECTS MENTIONED IN THE TRUST DEED, CANNOT BE INTERPRETED IN A MANNER TO SAY THAT THEY ARE FOR THE BENEFIT OF A PARTICULAR RELIG ION OR COMMUNITY. IT WAS SUBMITTED THAT THE TEACHINGS OF VEDA AND UPANIS HADS OR TEACHINGS OF YOGA ARE NOT CONFINED TO A PARTICULAR RELIGION OR COMMUNITY. LD. AR SUBMITTED THAT NEITHER SECTION 12 A NOR SECTION 11 PROHIBIT A CHARITABLE TRUST OR INSTITUTION FROM HAV ING MIXED OBJECTS I.E. BOTH CHARITABLE AND RELIGIOUS, THEREFORE, LD. DIT(E ) IS NOT JUSTIFIED IN DENYING REGISTRATION TO APPELLANT TRUST. IN SUPPORT OF SUCH CONTENTION, LEARNED AR RELIED ON THE FOLLOWING DECISIONS: 1. KASYAPA VEDA RESEARCH FOUNDATION VS. CIT, 11 ITR 468 (TRIB.) (COCHIN) 2. VANITA VISHRAM TRUST VS. CHIEF COMMISSIONER OF INCO ME TAX & ANR. 327 ITR 121 3. ADDL. DIT(E) VS. ISLAMIC RESEARCH FOUNDATION, 21 ITR (TRIB.) 588 (MUMBAI) 4. THE SOCIETY OF PRESENTATION SISTERS AND OTHERS V S. ITO, 318 ITR (AT) 287 6. THE LEARNED DR, ON THE OTHER HAND, SUPPORTING TH E ORDER OF LD. DIT(E) SUBMITTED THAT AS ASSESSEE IS HAVING MIXED O BJECTS, IT CANNOT BE GRANTED REGISTRATION U/S 12A OF THE ACT, AS IT H AS NOT ESTABLISHED 5 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM EITHER ONLY FOR CHARITABLE PURPOSE OR FOR RELIGIOUS PURPOSE AS PROVIDED U/S 11(1)(A) OF THE ACT. 7. WE HAVE CONSIDERED THE SUBMISSIONS OF THE PARTIE S AND PERUSED THE IMPUGNED ORDER OF LD. DIT(E) AS WELL AS OTHER M ATERIALS ON RECORD. WE HAVE ALSO CAREFULLY APPLIED OUR MIND TO THE DECI SIONS RELIED UPON BY THE PARTIES. AT THE OUTSET, IT WILL BE PERTINENT TO MENTION HERE THAT ON THE EARLIER OCCASION, LD. DIT(E) HAD REJECTED AS SESSEES APPLICATION SOLELY FOR THE REASON THAT ASSESSEE HAS NOT COMMENCED ITS ACTIVITIES. LD. DIT(E) NEVER RAISED ANY ISSUE W ITH REGARD TO MIXED OBJECTS OF THE APPELLANT TRUST. IN FACT, PERUSAL O F THE ORDER PASSED BY THE TRIBUNAL WOULD SHOW THAT WHILE SETTING ASIDE TH E ORDER OF LD. DIT(E) TRIBUNAL HAS CLEARLY MENTIONED THAT PRIMA-FA CIE OBJECTS OF THE APPELLANT TRUST WERE OF CHARITABLE NATURE. HOWEVER, IN THE PROCEEDING INITIATED AFRESH, LD. DIT(E) HAS FOUND A NEW REASON TO DENY REGISTRATION TO ASSESSEE BY STATING THAT AS PER SEC TION 11(1)(A) OF THE ACT, A TRUST OR INSTITUTION SHOULD HAVE BEEN ESTABL ISHED EITHER FOR RELIGIOUS OR CHARITABLE PURPOSE AND IT CANNOT HAVE MIXED OBJECTS. LD. DIT(E) AGAIN REFUSED REGISTRATION ON THE GROUND THA T ASSESSEE IS HAVING MIXED OBJECTS I.E. BOTH RELIGIOUS AND CHARIT ABLE. 8. BE THAT AS IT MAY, BEFORE PROCEEDING TO DECIDE T HE VALIDITY OF SUCH REASONING OF LD. DIT(E), IT NEEDS TO BE MENTIO NED, AS PER SECTION 12AA, LD. CIT HAS TO SATISFY HIMSELF ABOUT THE OBJECT OF THE TRUST AND GENUINENESS OF THE ACTIVITIES OF THE TRUS T OR INSTITUTION. ON GOING THROUGH THE IMPUGNED ORDER OF LD. DIT(E), IT IS ABSOLUTELY CLEAR, HE ACCEPTS THE FACT THAT OBJECTS OF THE TRUST ARE C HARITABLE IN NATURE. SPECIFIC OBJECTION OF LD. DIT(E) IS, IN ADDITION TO CHARITABLE OBJECTS THE TRUST IS ALSO HAVING RELIGIOUS OBJECTS WHICH VIOLAT ES THE PROVISION CONTAINED U/S 11(1)(A). THE OBJECT CLAUSES, WHICH L D. DIT(E) CONSIDERS TO BE OF RELIGIOUS NATURE ARE AS UNDER: 'XVIL. TO CONSTRUCT, TAKEOVER, MAINTAIN AND MANAGE COMMUNITY HALLS, MEDITATION CENTERS, SPIRITUAL CENTERS, PLACES OF WO RSHIP AND PRAYER 6 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM HALLS OF ANY RELIGION AND PUBLIC IN GENERAL. XXV. TO UNDERTAKE OR TO EXTEND ASSISTANCE FOR THE R ESEARCH OF SUBJECTS RELATED TO SPIRITUALITY AND RELATED ANCIENT BOOKS O F ANY RELIGION. XXVII. EDUCATION IN PARTICULAR, CULTURAL AND SPIRIT UAL CONCERNING THE SUPREME VALUES OF LIFE AS SPOKEN ,TO BY THE VEDAS A ND UPANISHADS, QURAN AND BIBLE AND OTHER SCRIPTURES VIZ. TRUTH, NO N-VIOLENCE, AUSTERITY, UNIVERSAL BROTHERHOOD OR FRIENDSHIP, SEC URITY AND SAFETY, FEARLESSNESS, LOVE, PEACE, COMPASSION, CHARACTER AN D DEDICATION, WITH THE SOLE OBJECT OF TRANSFORMING THE PEOPLE AT LARGE FOR THE WELFARE OF ALL THE LIVING BEINGS ESPECIALLY HUMAN BEINGS. XXVIII. TO PROPAGATE, PREACH AND TEACH THE INTRICACIES AND THE TRUE CONSEQUENCES OF SANATHANA DHARMA WITH THE OBJECT OF SECURING CHARTURVEIDHA PURUSHARDHA VIZ., DHERME, ARDHA, KAMA , MOKSHA WHICH ARE REALLY ESSENTIAL REQUISITES FOR THE REMOVAL OF EVIL AND RENEWAL OF GOOD TO THE PERSONS AND DEVOTEES WHO VISIT THE TAPO VANAM AND PARTICIPATE IN THE ACTIVITIES OF THE TRUTH WHICH IS REALLY FOR THE BENEFIT AND WELFARE OF THE GENERAL PUBLIC OF A SECTION THER EOF. XXXIII. FOR PROPAGATION AND IMPARTING OF VEDIC KNOW LEDGE AND OTHER VALUABLE SCRIPTURES IN SANSKRIT, TELUGU AND ENGLISH . XXXIV. TO PROVIDE FEES, BOOKS, EQUIPMENTS, FREE SHI PS, AND/OR SCHOLARSHIPS TO DESERVING STUDENTS. AND TO ESTABLIS H EDUCATIONAL INSTITUTIONS SUCH AS VEDA PATHASHALA ETC. XL. TO PRODUCE, DEVELOP, DIRECT ANIMATION FILMS, SHORT FILMS, DOCUMENTARIES, SOCIAL/DEVOTIONAL MOVIES, TV SERIALS RELATING TO THE VEDIC SCRIPTURES, YOGA AND PREACHING OF VARIOUS GUR US OF VARIOUS RELIGIONS FOR ENHANCING HUMAN VALUES.' 9. HOWEVER, CAREFUL ANALYSIS OF THE AFORESAID CLAU SES, MAKES IT CLEAR THAT NEITHER THEY ARE FOR THE BENEFIT OF A PA RTICULAR RELIGION OR COMMUNITY NOR THEY ARE CONFINED TO PARTICULAR CLASS OF PEOPLE OR PEOPLE OF A PARTICULAR CASTE OR CREED. ON THE CONTR ARY, THESE OBJECT CLAUSES CERTAINLY GIVES AN IMPRESSION THAT IT IS FO R THE BENEFIT OF GENERAL PUBLIC. AS CAN BE SEEN FROM CLAUSE XXVII, I T SPEAKS OF TEACHINGS IN VEDAS AND UPANISHADS, QURAN AND BIBLE AND OTHER SCRIPTURES FOR SPREADING THE MESSAGE OF TRUTH, NON- VIOLENCE, AUSTERITY, UNIVERSAL BROTHERHOOD OR FRIENDSHIP, SECURITY AND S AFETY, FEARLESSNESS, LOVE, PEACE, COMPASSION, CHARACTER AND DEDICATION W ITH THE SOLE OBJECT OF TRANSFORMING THE PEOPLE. THEREFORE, IT CA NNOT BE TREATED TO 7 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM BE FOR THE BENEFIT OF A PARTICULAR RELIGION OR COMM UNITY. SIMILARLY, PROPAGATING, INTRICACIES AND TRUE CONSEQUENCES OF S ANATHANA DHARMA IS ALSO FOR THE BENEFIT OF GENERAL PUBLIC AND CANNO T BE CONFINED TO A PARTICULAR RELIGION OR COMMUNITY. PRODUCING/DEVELO PING FILMS OR PROGRAMMES ON VEDIC SCRIPTURES, YOGA AND PREACHING OF VARIOUS GURUS OF VARIOUS RELIGIONS IS ALSO FOR UPLIFTING THE MORA L STANDARDS OF GENERAL PUBLIC AND ENHANCING HUMAN VALUES IRRESPECTIVE OF R ELIGION, COMMUNITY, CASTE AND CREED. SIMILARLY CONSTRUCTION/ MAINTENANCE/ MANAGEMENT OF COMMUNITY HALLS, MEDITATION CENTERS, SPIRITUAL CENTERS, PLACES OF WORSHIP AND PRAYER HALLS IS NOT CONFINED TO ANY PARTICULAR RELIGION OR COMMUNITY, BUT FOR THE BENEFIT OF GENER AL PUBLIC. 10. THUS, ON CAREFUL READING OF THE OBJECT CLAUSES IN GENERAL AND SPECIFICALLY CLAUSES ON WHICH LD. DIT(E) HAS RAISED CONCERN STATING THAT THEY ARE FOR THE BENEFIT OF A PARTICULAR RELIG IOUS COMMUNITY, THE IMPRESSION ONE GETS IS THERE IS NOTHING IN THESE CL AUSES WHICH CAN LEAD ONE TO BELIEVE THAT THEY ARE FOR THE BENEFIT O F A PARTICULAR RELIGIOUS COMMUNITY, HENCE, COMING WITHIN THE MISCH IEF OF SECTION 13(1)(A) OR 13(1)(B) OF THE ACT. ON THE CONTRARY, T HESE CLAUSES, IF AT ALL THEY CAN BE CALLED TO BE OF RELIGIOUS NATURE, ARE F OR THE BENEFIT OF GENERAL PUBLIC, HENCE, CAN BE CONSIDERED TO BE IN THE NATURE OF ANY OTHER OBJECT OF GENERAL PUBLIC UTILITY AS ENGRAINED IN THE DEFINITION OF CHARITABLE PURPOSE U/S 2(15) OF THE ACT. LAW IS WELL SETTLED THAT ANY OTHER OBJECT OF GENERAL PUBLIC UTILITY IS OF THE W IDEST CONNOTATION AS THE WORD GENERAL IN SAID EXPRESSION SIGNIFIES A W HOLE CLASS. HENCE, ADVANCEMENT OF ANY OBJECT OF BENEFIT TO THE PUBLIC OR A SECTION OF THE PUBLIC AS DISTINGUISHED FROM BENEFIT TO AN INDIVIDU AL OR A GROUP OF INDIVIDUAL WOULD BE A CHARITABLE PURPOSE. THE EXPRE SSION ANY OTHER OBJECT OF GENERAL PUBLIC UTILITY WOULD PRIMA FACIE INCLUDE ALL OBJECTS WHICH PROMOTE THE WELL BEING OF THE GENERAL PUBLIC. IT CANNOT BE SAID THAT A PURPOSE WOULD CEASE TO BE CHARITABLE EVEN WH EN PUBLIC WELFARE IS INTENDED TO BE SERVED. CONSIDERED IN THE AFORESA ID PERSPECTIVE, THERE CANNOT BE ANY DOUBT THAT THE MAIN OBJECT OF T HE APPELLANT TRUST 8 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM IS CHARITABLE IN NATURE AS IT IS FOR THE BENEFIT OF GENERAL PUBLIC. EVEN, LD. DIT(E) ALSO ACCEPTS THIS POSITION, THOUGH HE OB SERVES THAT SOME OF THE OBJECT CLAUSES ARE OF RELIGIOUS NATURE. THE HON BLE SUPREME COURT IN CASE OF ADDL. CIT VS. SURAT ART SILK CLOTH MANUF ACTURERSS ASSOCIATION, [1980] 121 ITR 1 (SC) AND A NUMBER OF OTHER DECISIONS HELD THAT IF THE PRIMARY PURPOSE AND PREDOMINANT OB JECT OF A TRUST ARE TO PROMOTE WELFARE OF THE GENERAL PUBLIC, THE PURPO SE WOULD BE CHARITABLE PURPOSE. IF THE PRIMARY OR PREDOMINANT O BJECT OF AN INSTITUTION IS CHARITABLE, ANY OTHER OBJECT WHICH M IGHT NOT BE CHARITABLE BUT WHICH IS ANCILLARY OR INCIDENTAL TO THE DOMINAN T PURPOSE, WOULD NOT PREVENT THE TRUST OR INSTITUTION FROM BEING A CHARI TABLE TRUST. 11. EVEN ASSUMING THAT APPELLANT TRUST HAS MIXED OB JECTS I.E. BOTH CHARITABLE AND RELIGIOUS, LET US EXAMINE WHETHER FO R THIS REASON ALONE IT BECOMES INELIGIBLE FOR AVAILING EXEMPTIONS U/S 1 1 AND BEING REGISTERED U/S 12AA OF THE ACT. LD. DIT(E) IN HIS O RDER HAS OBSERVED THAT APPELLANT TRUST IS HAVING BOTH CHARITABLE AND RELIGIOUS OBJECTS, FURTHER THE RELIGIOUS OBJECTS ARE FOR THE BENEFIT O F PARTICULAR RELIGION. AFTER PERUSING THE OBJECTS WE ARE INCLINED TO HOLD THAT THEY CANNOT BE CONSIDERED TO BE FOR THE BENEFIT OF A PARTICULAR RE LIGIOUS COMMUNITY, RATHER, IN OUR VIEW, THE OBJECT CLAUSES SPECIFICALL Y REFERRED TO BY LD. DIT(E) ARE FOR THE BENEFIT OF THE GENERAL PUBLIC AN D NOT CONFINED TO ANY PARTICULAR RELIGIOUS CLASS OR COMMUNITY. REVERT ING BACK TO THE ISSUE WHETHER HAVING OBJECTS OF BOTH CHARITABLE AN D RELIGIOUS NATURE DISENTITLES FROM AVAILING EXEMPTION U/S 11. LET US EXAMINE THE SAID PROVISION WHICH READS AS UNDER: 11. (1) [(A) INCOME DERIVED FROM PROPERTY HELD UNDER T RUST WHOLLY FOR CHARITABLE OR RELIGIOUS PURPOSES, TO THE EXTENT TO WHICH SUCH INCOME IS APPLIED TO SUCH PURPOSES IN INDIA; AND, WHERE ANY S UCH INCOME IS ACCUMULATED OR SET APART FOR APPLICATION TO SUCH PURPOSES IN INDIA, TO THE EXTENT TO WHICH THE INCOME SO ACCUMUL ATED OR SET APART IS NOT IN EXCESS OF [FIFTEEN] PER CENT OF THE INCOME FROM SUCH PROPERTY; 9 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM ACCORDING TO LD. DIT(E) THE WORDS CHARITABLE OR RE LIGIOUS APPEARING IN THE AFORESAID PROVISION WOULD MEAN, A TRUST OR INST ITUTION CAN EITHER HAVE CHARITABLE OR RELIGIOUS OBJECTS AND NOT BOTH. IN OUR VIEW, SUCH A NARROW INTERPRETATION CANNOT BE GIVEN TO SECTION 11 (1)(A) OF THE ACT. SECTION 11(1)(A) OF THE ACT MAKES NO DISTINCTION BE TWEEN RELIGIOUS OR CHARITABLE INSTITUTION SO FAR AS GRANT OF EXEMPTION IS CONCERNED, SAVE AND EXCEPT THE CONDITIONS IMPOSED U/S 13 OF THE ACT . THE WORD OR BETWEEN CHARITABLE AND RELIGIOUS AS USED IN SECTION 11(1)(A) IS NOT DISJUNCTIVE BUT CONJUNCTIVE IN NATURE, THEREFORE, I T IS NECESSARY TO READ THAT INCOME DERIVED FROM PROPERTY HELD UNDER TRUST WHOLLY FOR CHARITABLE OR RELIGIOUS PURPOSES OR BOTH ARE EXEMPT . THE HONBLE SUPREME COURT IN CASE OF CIT VS. M/S DAWOODI BOHARH JAMAT, CIVIL APPEAL NO. 2492 OF 2014 OBSERVED, IN CERTAIN CASES ACTIVITIES OF THE TRUST MAY CONTAIN ELEMENTS OF BOTH RELIGIOUS AND CH ARITABLE AND THUS, BOTH THE PURPOSES MAY BE OVERLAPPING. MORE SO, WHEN THE RELIGIOUS ACTIVITY CARRIED ON BY A PARTICULAR SECTION OF PEOP LE WOULD BE A CHARITABLE ACTIVITY FOR OR TOWARDS OTHER MEMBERS OF THE COMMUNITY OR ALSO PUBLIC AT LARGE. FEEDING ANIMALS OR COW MAY BE A RELIGIOUS ACTIVITY FOR A PARTICULAR COMMUNITY BUT MAY BE CHAR ITABLE FOR OTHERS. SIMILARLY, FEEDING POOR PEOPLE OR GIVING WATER TO T HIRSTY MAY BE RELIGIOUS FOR SOME BUT CHARITABLE FOR OTHERS. ANALY SING THE OBJECTS OF THE TRUST BY KEEPING THE AFORESAID PRINCIPLES IN VI EW, HONBLE APEX COURT FINALLY HELD AS UNDER: 41.THEREFORE, THE OBJECTS OF THE TRUST EXHIBIT THE DUAL TENOR OF RELIGIOUS AND CHARITABLE PURPOSES AND ACTIVITIES. S ECTION 11 OF THE ACT SHELTERS SUCH TRUST WITH COMPOSITE OBJECTS TO CLAIM EXEMPTION FROM TAX AS A RELIGIOUS AND CHARITABLE TR UST SUBJECT TO PROVISIONS OF SECTION 13. THE ACTIVITIES OF THE TRU ST UNDER SUCH OBJECTS WOULD THEREFORE BE ENTITLED TO EXEMPTION AC CORDINGLY. 42.WE WOULD NOW PROCEED TO EXAMINE THE OBJECTS UNDE R THE PROVISIONS OF SECTION 13(1)(B) OF THE ACT. IT BECOM ES AMPLY CLEAR FROM THE LANGUAGE EMPLOYED IN THE PROVISIONS THAT SECTION 13 IS IN THE NATURE OF AN EXEMPTION FROM APPLICABIL ITY OF SECTIONS 11 OR 12 AND THE EXAMINATION OF ITS APPLIC ABILITY WOULD ONLY ARISE AT THE STAGE OF CLAIM UNDER SECTIONS 11 OR 12. THUS, 10 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM WHERE THE INCOME OF A TRUST IS ELIGIBLE FOR EXEMPTI ON UNDER SECTION 11, THE ELIGIBILITY FOR CLAIMING EXEMPTION OUGHT TO BE TESTED ON THE TOUCHSTONE OF THE PROVISIONS OF SECTI ON 13. IN THE INSTANT CASE, IT BEING ESTABLISHED THAT THE RESPOND ENT-TRUST IS A PUBLIC CHARITABLE AND RELIGIOUS TRUST ELIGIBLE FOR CLAIMING EXEMPTION UNDER SECTION 11, IT BECOMES RELEVANT TO TEST IT ON THE ANVIL OF SECTION 13. 43.THUS, THE SECOND ISSUE WHICH ARISES FOR OUR CONS IDERATION AND DECISION IS, WHETHER THE RESPONDENT-TRUST IS A CHARITABLE AND RELIGIOUS TRUST ONLY FOR THE PURPOSES OF A PART ICULAR COMMUNITY AND THEREFORE, NOT ELIGIBLE FOR EXEMPTION UNDER SECTION 11 OF THE ACT IN VIEW OF PROVISIONS OF SECT ION 13(1)(B) OF THE ACT. 44.IN THE INSTANT CASE, THE TRIBUNAL HAS FOUND ON F ACTS AFTER ANALYSING THE OBJECTS OF THE TRUST THAT THE RESPOND ENT TRUST IS A PUBLIC RELIGIOUS TRUST AND ITS OBJECTS ARE SOLELY R ELIGIOUS IN NATURE AND BEING OF THE OPINION THAT SECTION 13(1)( B) IS SOLELY MEANT FOR CHARITABLE TRUST FOR PARTICULAR COMMUNITY , NEGATED THE POSSIBILITY OF APPLICABILITY OF SECTION 13(1)(B) OF THE ACT AT THE OUTSET. THE HIGH COURT HAS ALSO CONFIRMED THE AFORE SAID VIEW IN APPEAL AND OBSERVED THAT SECTION 13(1)(B) WOULD ONL Y BE APPLICABLE IN CASE OF INCOME OF THE TRUST FOR CHARI TABLE PURPOSE ESTABLISHED FOR BENEFIT OF A PARTICULAR RELIGIOUS C OMMUNITY. IN OUR CONSIDERED VIEW, THE SAID VIEW MAY NOT BE THE C ORRECT INTERPRETATION OF THE PROVISION. 45.FROM THE PHRASEOLOGY IN CLAUSE (B) OF SECTION 13 (1), IT COULD BE INFERRED THAT THE LEGISLATURE INTENDED TO INCLUD E ONLY THE TRUSTS ESTABLISHED FOR CHARITABLE PURPOSES. THAT HO WEVER DOES NOT MEAN THAT IF A TRUST IS A COMPOSITE ONE, THAT I S ONE FOR BOTH RELIGIOUS AND CHARITABLE PURPOSES, THEN IT WOULD NO T BE COVERED BY CLAUSE (B). WHAT IS INTENDED TO BE EXCLUDED FROM BEING ELIGIBLE FOR EXEMPTION UNDER SECTION 11 IS A TRUST FOR CHARITABLE PURPOSE WHICH IS ESTABLISHED FOR THE BENEFIT OF ANY PARTICULAR RELIGIOUS COMMUNITY OR CASTE. 46.SUCH TRUSTS WITH COMPOSITE OBJECTS WOULD NOT BE EXPELLED OUT OF THE PURVIEW OF SECTION 13(1)(B) PER SE. THE SECT ION REQUIRES IT TO BE ESTABLISHED THAT SUCH CHARITABLE PURPOSE I S NOT FOR THE BENEFIT OF A PARTICULAR RELIGIOUS COMMUNITY OR CAST E. THAT IS TO SAY, IT NEEDS TO BE EXAMINED WHETHER SUCH RELIGIOUS -CHARITABLE ACTIVITY CARRIED ON BY THE TRUST ONLY BENEFITS A CE RTAIN PARTICULAR RELIGIOUS COMMUNITY OR CLASS OR SERVES ACROSS THE C OMMUNITIES AND FOR SOCIETY AT LARGE. (SOLE TRUSTEE, LOKA SHIKS HANA TRUST V. CIT, (1975) 101 ITR 234 (SC)). THE SECTION OF COMMU NITY SOUGHT TO BE BENEFITED MUST BE EITHER SUFFICIENTLY DEFINED OR 11 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM IDENTIFIABLE BY A COMMON QUALITY OF A PUBLIC OR IMP ERSONAL NATURE. (CIT V. ANDHRA CHAMBER OF COMMERCE, 55 ITR 722). 47.THIS COURT IN CIT V. PALGHAT SHADI MAHAL TRUST, (2002) 9 SCC 685 THE MUSLIM RESIDENTS OF KERALA CONSTITUTED A TRUST FOR THE PURPOSE OF CONSTRUCTING AND ESTABLISHING AT PAL GHAT-A-SHADI MAHAL AND OTHER INSTITUTIONS FOR THE EDUCATIONAL, S OCIAL AND ECONOMIC ADVANCEMENT OF THE MUSLIMS AND FOR RELIGIO US AND CHARITABLE OBJECTS RECOGNISED BY MUSLIM LAW AND LATER CLARIFIED THAT THE PROCEEDS WOULD BE UTILIZED FOR T HE BENEFIT FOR PUBLIC AT LARGE AND UPON THIS BASIS, THE TRUST MADE A CLAIM FOR EXEMPTION FROM TAX UNDER SECTION 11. THIS COURT HEL D THAT THE RESOLUTION CLARIFYING THE OBJECT WOULD NOT VALIDLY AMEND THE OBJECT OF THE TRUST-DEED AND SINCE THE OBJECT CONFI NED THE BENEFIT TO ONLY MUSLIM COMMUNITY, IT WOULD BE COVER ED BY THE RESTRICTION UNDER SECTION 13(1)(B) OF THE ACT EVEN THOUGH IT FUNCTIONED FOR PUBLIC BENEFIT. THUS, THEREIN THE OB JECT SUFFICIENTLY DEFINED OR EXPRESSLY STATED BENEFICIAR Y CLASS AND RESTRICTED THE ACTIVITIES OF THE TRUST TO A SPECIFI C COMMUNITY. 48.FURTHER, IN STATE OF KERALA V. M.P. SHANTI VERMA JAIN, (1998) 5 SCC 63 THIS COURT HAS HELD THAT PROPAGATION OF RE LIGION AND RESTRICTION OF BENEFITS OF ACTIVITIES OF TRUST IN I TS OBJECTS TO THE SAID COMMUNITY WOULD RENDER THE TRUST AS INELIGIBLE FOR CLAIMING EXEMPTION UNDER SIMILAR PROVISIONS OF KERALA AGRICU LTURAL INCOME TAX ACT, 1950. THE COURT OBSERVED AS FOLLOWS : THE DEED OF TRUST AND THE RULES RUN INTO MORE THA N THIRTY PAGES OUT OF WHICH SIX PAGES OF THE TRUST DE ED NARRATE THE PHILOSOPHY OF JAIN DHARMA. THE OBJECTS OF THE TRUST CLEARLY SHOW THAT THE TRUST IS MEANT FOR PROP AGATION OF JAIN RELIGION AND RENDERING HELP TO THE FOLLOWER S OF JAIN RELIGION. EVEN MEDICAL AID AND SIMILAR FACILITIES A RE TO BE RENDERED TO PERSONS DEVOTED TO JAIN RELIGION AND TO NON- JAINS IF SUFFERING FROM AILMENTS BUT THE MEDICAL AI D COULD BE GIVEN TO THEM ONLY IF ANY MEMBER OF THE FAMILIES MANAGING THE TRUST, SHOWS SYMPATHY AND IS INTERESTE D IN THEIR TREATMENT. THE TRIBUNAL, IN OUR OPINION, WAS RIGHT IN ITS CONCLUSION THAT THE DOMINANT PURPOSE OF THE TRU ST IN THE PRESENT CASE WAS PROPAGATION OF JAIN RELIGION A ND TO SERVE ITS FOLLOWERS AND ANY PART OF AGRICULTURAL IN COME OF THE TRUST SPENT IN THE STATE OF KERALA ALSO COULD N OT BE TREATED AS ALLOWABLE ITEM OF THE EXPENSES. 49.IN THE PRESENT CASE, THE OBJECTS OF THE RESPONDE NT-TRUST BASED ON RELIGIOUS TENETS UNDER QURAN ACCORDING TO RELIGIOUS FAITH OF ISLAM. WE HAVE ALREADY NOTICED THAT THE PE RUSAL OF THE OBJECTS AND PURPOSES OF THE RESPONDENT-TRUST WOULD CLEARLY DEMONSTRATE THAT THE ACTIVITIES OF THE TRUST THOUGH BOTH CHARITABLE AND RELIGIOUS ARE NOT EXCLUSIVELY MEANT FOR A 12 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM PARTICULAR RELIGIOUS COMMUNITY. THE OBJECTS, AS EXP LAINED IN THE PRECEDING PARAGRAPHS, DO NOT CHANNEL THE BENEFITS T O ANY COMMUNITY IF NOT THE DAWOODI BOHRA COMMUNITY AND TH US, WOULD NOT FALL UNDER THE PROVISIONS OF SECTION 13(1 )(B) OF THE ACT. 50.IN THAT VIEW OF THE MATTER, WE ARE OF THE CONSID ERED OPINION THAT THE RESPONDENT-TRUST IS A CHARITABLE AND RELIG IOUS TRUST WHICH DOES NOT BENEFIT ANY SPECIFIC RELIGIOUS COMMU NITY AND THEREFORE, IT CANNOT BE HELD THAT SECTION 13(1)(B) OF THE ACT WOULD BE ATTRACTED TO THE RESPONDENT-TRUST AND THER EBY, IT WOULD BE ELIGIBLE TO CLAIM EXEMPTION UNDER SECTION 11 OF THE ACT. 12. IN CASE OF THE SOCIETY OF PRESENTATION SISTERS AND OTHERS VS. ITO, 318 ITR(AT)287, THE HONBLE THIRD MEMBER WHILE CONCURRING WITH THE VIEW EXPRESSED BY HONBLE ACCOUNTANT MEMBER, HE LD AS UNDER: IT IS CLEAR FROM PLETHORA OF AUTHORITIES WHERE AFTE R CONSIDERING THE PROVISIONS OF SECTION 11(1)(A) THAT SO FAR AS T HE AFORESAID PROVISION IS CONCERNED, NO DISTINCTION IS MADE BETW EEN CHARITABLE AND RELIGIOUS PURPOSES. A CHARITABLE INS TITUTION CAN HAVE RELIGIOUS PURPOSES; WHEREAS A RELIGIOUS INSTIT UTION MAY BE PARTLY CHARITABLE. MOST OF THE DECISIONS WERE GIVEN UNDER THE 1961 ACT. EVEN WHERE THE DECISION WAS ON CONSIDERAT ION OF 1922 ACT, THERE IS NO MATERIAL DIFFERENCE AS IS DEM ONSTRATED IN THE ABOVE DISCUSSION. THEIR LORDSHIPS OF THE SUPREM E COURT HAVE HELD, AS NOTED EARLIER, THAT CHARITABLE AND RE LIGIOUS PURPOSES OVERLAPS IN INDIA. EVEN OTHERWISE RELIEF A ND HELP TO THE POOR, MEDICAL HELP TO THE NEEDY, LOOKING AFTER OF DEITY AND TEMPLES (MOSQUE, CHURCH INCLUDED) ARE NO DOUBT RELI GIOUS PURPOSES BUT THESE ARE ALSO CONSIDERED AS CHARITABL E IN INDIA. THEREFORE, THE VIEW TAKEN IN THE TWO CASES BEFORE M E THAT EXEMPTION UNDER SECTION 11(1)(A) CANNOT BE ALLOWED TO A CHARITABLE TRUST AS IT IS ALSO CARRYING SOME PURPOS ES WHICH ARE TERMED AS RELIGIOUS IS TOTALLY UNWARRANTED. THE A BOVE VIEW IS TOTALLY CONTRARY TO THE WELL ESTABLISHED AN SETTLED LAW IN INDIA, AS LAID DOWN BY THEIR LORDSHIPS OF THE SUPREME COUR T. THE OTHER REASON GIVEN BY THE LEARNED JUDICIAL MEMB ER IS THAT TWO TRUSTS IN QUESTION ARE PARTLY CHARITABLE OR REL IGIOUS TRUSTS ESTABLISHED AFTER APRIL 1, 1962. THEREFORE, ON ACCO UNT OF LANGUAGE OF THE STATUTE IN SECTION 11, THERE IS PRO HIBITION FROM INCOME DERIVED FROM PROPERTY HELD FOR CHARITABLE OR RELIGIOUS PURPOSES. ACCORDING TO HIM, INCOME UNDER BOTH CHARI TABLE AND RELIGIOUS PURPOSES CANNOT BE COMBINED TOGETHER AND THE ASSESSEE HAS TO CHOOSE EITHER OF THE CHARITABLE ACT IVITIES OR RELIGIOUS ACTIVITIES, BUT NOT BOTH. I HAD TO STATE THAT IN MY HUMBLE OPINION, THERE IS NO STATUTORY PROVISION TO SUPPORT 13 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM PROPOSITION OF LAW, STATED BY THE LEARNED JUDICIAL MEMBER. THE LEARNED JUDICIAL MEMBER, LIKE THE REVENUE AUTHORITI ES, MISCONSTRUED THE LEGAL IMPLICATION OF THE WORD OR IN SECTION 11(1)(A). 13. THE PRINCIPLE OF LAW EMERGING FROM THE AFORESAI D DECISIONS ARE A TRUST/INSTITUTION HAVING CHARITABLE AND RELIGIOUS OBJECTS WILL BE ELIGIBLE FOR EXEMPTION U/S 11 UNLESS HIT BY RESTRIC TIONS IMPOSED U/S 13(1)(A) OR 13(1)(B) OF THE ACT. AS IN THE PRESENT CASE, LD. DIT(E) HAS NOT BROUGHT ANY MATERIAL ON RECORD TO SHOW THAT PRO VISIONS OF SECTION 13(1)(A) OR 13(1)(B) APPLIES TO THE ASSESSEE, DENIA L OF REGISTRATION U/S 12AA FOR ALLEGED VIOLATION OF SECTION 11(1)(A), IN OUR VIEW, IS NOT JUSTIFIED. MOREOVER, APPLICABILITY OF SECTION 13 OF THE ACT CAN BE LOOKED INTO BY THE AO AT THE TIME OF ASSESSMENT PRO CEEDINGS AND NOT BY LD. DIT(E) WHILE EXERCISING POWER U/S 12AA OF TH E ACT. IN AFORESAID VIEW OF THE MATTER, WE ARE INCLINED TO SET ASIDE TH E IMPUGNED ORDER OF LD. DIT(E) AND DIRECT HIM TO GRANT REGISTRATION TO THE APPELLANT TRUST U/S 12AA OF THE ACT. 14. IN THE RESULT, APPEAL OF ASSESSEE IS ALLOWED. PRONOUNCED IN THE OPEN COURT ON 03/12/2014. SD/- SD/- (B. RAMAKOTAIAH) (SAKTIJIT DEY) ACCOUNTANT MEMBER JU DICIAL MEMBER HYDERABAD, DATED:3 RD DECEMBER, 2014 KV 14 ITA NO. 1232/HYD/2014 SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPTEETAM COPY TO:- 1) SHIVA SHAKTHI SHIRIDI SAI ANUGRAHA MAHAPEETAM, FLAT NO. B-201, H.NO. 1-1-563/B/S1, SURABHI APARTMENTS, NEAR G OLCONDA X ROADS POST OFFICE, NEW BAKARAM, HYDERABAD 500 020 2). DDIT(E), 3 RD FLOOR ANNEXE, AAYAKAR BHAVAN, BASHEERBAGH, HYDERABAD 500 004. 3) DIT(E), HYDERABAD 4)THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDER ABAD.