Appeal details
Counselvise Citation
[2018] 126 COUNSELVISE.COM (IT) 0619 (ITAT-MUMBAI)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
1 year(s) 10 month(s) 30 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
09-02-2018
Appeal Filed By
Department
Order Result
Dismissed
Bench Allotted
Not Allotted
Assessment Year
2011-2012
Appeal Filed On
10-03-2016
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH L, MUMBAI BEFORE SHRI G.S.PANNU, ACCOUNTANT MEMBER AND SHRI RAVISH SOOD, JUDICIAL MEMBER ITA NO.1247/MUM/2016 (AY. 2011-12) DCIT (IT) 2(1)(1) R.NO.114, 1 ST FLOOR SCINIDIA HOUSE N.M.ROAD, BALLARD ESTATE MUMBAI 400 036 ...... APPELLANT VS. M/S. CREDIT SUISSE AG 10 TH FLOOR, CEEJAY HOUSE, PLOT F, SHIVSAGAR ESTATE DR. ANNIE BESANT ROAD WORLI, MUMBAI 400 018 PAN:AABCC9113E .... RESPONDENT ITA NO.7357/MUM/2017 (AY. 2011-12) & CROSS OBJECTION NO.278/MUM/2017 (2011-12) (ARISING OUT OF ITA NO.1247/MUM/2016) M/S. CREDIT SUISSE AG 10 TH FLOOR, CEEJAY HOUSE, PLOT F, SHIVSAGAR ESTATE DR. ANNIE BESANT ROAD WORLI, MUMBAI 400 018 PAN:AABCC9113E .... APPELLANT VS. DCIT (IT) 2(1)(1) MUMBAI 400 036 .... RESPONDENT 2 ITA NO.1247/MUM/2016, 7357/MUM/2017 & CO NO.278/MU M/2017 M/S. CREDIT SUISSE AG APPELLANT BY : SHRI SHISHIR DHAMIJA RESPONDENT BY : SHRI ARVIND SONDE DATE OF HEARING : 01 /02/2018 DATE OF PRONOUNCEMENT : 09/02/2018 ORDER PER G.S.PANNU,A.M: THESE CROSS APPEALS AND CROSS OBJECTION ARE ARISIN G FROM THE DIRECTIONS GIVEN BY THE DISPUTE RESOLUTION PANEL (D RP) U/S.144C(5) OF THE ACT DATED 29.12.2015 IN TERMS OF WHICH THE ASSESSMENT U NDER SECTION 144C(13) R.W.S. 143(3) OF THE INCOME TAX ACT, 1961 (THE ACT ) HAS BEEN FINALIZED BY THE ASSESSING OFFICER FOR ASSESSMENT YEAR 2011-12 WITH REGARD TO THE NATURE AND TREATMENT OF FEE OF RS.18,27,90,578/- EARNED BY THE ASSESSEE FROM CREDIT SECURITIES (INDIA) PRIVATE LIMITED (HEREINAFTER REF ERRED TO AS INDIAN COMPANY). 2. FIRST WE SHALL TAKE UP THE APPEAL OF THE REVENUE IN ITA NO.1247/MUM/2016. THE GROUNDS OF APPEAL RAISED BY THE REVENUE READ AS UNDER:- 1. 'WHETHER ON THE FACTS AND UNDER THE CIRCUMSTANCE S OF THE CASE AND IN LAW, THE LD. DRP IS RIGHT IN HOLDING THAT THE REFERRAL F EES RECEIVED BY THE ASSESSEE OF RS. 18,27,90,5787- FROM CREDIT SUISSE SECURITIES (INDIA) PVT. LIMITED DOES NOT CONSTITUTE 'FEES FOR TECHNICAL SERVICES'. 2. WHETHER ON THE FACTS AND UNDER THE CIRCUMSTANC ES OF THE CASE AND IN LAW, THE LD. DRP IS RIGHT IN HOLDING THAT THE REFER RAL FEES ARE IN THE NATURE OF COMMISSION INCOME BUT SINCE THE REFERRAL FEE RECEIV ED CANNOT BE CONSIDERED TO BE ATTRIBUTABLE TO A PERMANENT ESTABLISHMENT (PE ) IN INDIA AND THEREFORE NOT LIABLE TO TAX IN INDIA AS PER ARTICLE 7 OF THE INDIA-SWITZERLAND TREATY, AS IT IS NOT ATTRIBUTABLE TO A PE IN INDIA. 3. THE APPELLANT PRAYS THAT THE ORDER OF THE ID . DRP ON THE ABOVE GROUNDS BE SET ASIDE AND THAT OF THE ASSESSING OFFICER BE R ESTORED. 3 ITA NO.1247/MUM/2016, 7357/MUM/2017 & CO NO.278/MU M/2017 M/S. CREDIT SUISSE AG 4. THE APPELLANT CRAVES LEAVE TO AMEND OR ALTER ANY GROUND OR ADD A NEW GROUND WHICH MAY BE NECESSARY.' 3. BRIEFLY PUT, THE RELEVANT FACTS ARE THAT THE ASS ESSEE BEFORE US IS AN ENTITY INCORPORATED IN SWITZERLAND AND IS A TAX-RES IDENT OF SWITZERLAND. THE ASSESSEE IS A PART OF THE CREDIT SUISSE GROUP, A GL OBAL BANK PROVIDING VARIOUS FINANCIAL SERVICES IN THE FIELD OF INVESTMENT AND P ERSONAL BANKING TO ITS CLIENTS ACROSS THE GLOBE. THE ASSESSEE HAS A BANK B RANCH OFFICE IN INDIA WHICH IS REGISTERED WITH THE RESERVE BANK OF INDIA. THE A SSESSEE ALSO HAS A BRANCH IN DUBAI (HEREINAFTER REFERRED TO AS CSDB). IN SO FAR AS THE DISPUTE BEFORE US IS CONCERNED, THE SAME RELATES TO TAXABILITY OF A S UM OF RS. 18,27,90,578/- RECEIVED BY ASSESSEES DUBAI BRANCH (CSDB) FROM THE INDIAN COMPANY, WHICH IS AN ASSOCIATE ENTERPRISE. BEFORE THE ASSESSING OF FICER, ASSESSEE CANVASSED THAT THE SAID SUM WAS RECEIVED BY CSDB FOR REFERRIN G AN INDIAN RESIDENT CLIENT TO THE INDIAN COMPANY FOR BRINGING OUT ISSUE OF CONVERTIBLE BONDS. THE ASSESSEE CONTENDED THAT SUCH REFERRAL FEE RECEIVED BY CSDB WAS A BUSINESS INCOME NOT LIABLE TO TAX IN INDIA BECAUSE CSDB DID NOT HAVE A PERMANENT ESTABLISHMENT IN INDIA AS RECOGNISED IN ARTICLE 5 OF THE INDO-SWISS DOUBLE TAXATION AVOIDANCE AGREEMENT (DTAA). THE ASSESSING OFFICER HOWEVER DID NOT ACCEPT THE STAND OF THE ASSESSEE AND INSTEAD H ELD THAT THE REFERRAL FEE WAS LIABLE TO BE TAXED IN INDIA HAVING REGARD TO SE CTION 5(2)(B) OF THE ACT READ WITH SECTION 9(1)(I) OF THE ACT. AS PER THE AS SESSING OFFICER, SINCE THE REFERRAL FEE WAS PAYABLE TO CSDB IN RELATION TO THE EXECUTION OF TRANSACTION BETWEEN INDIAN COMPANY AND REFERRED CLIENT, SUCH RE FERRAL FEE IS DEEMED TO ACCRUE OR ARISE IN INDIA. IN OTHER WORDS, AS PER TH E ASSESSING OFFICER, BY VIRTUE OF THE SOURCE OF THE REFERRAL FEE BEING LO CATED IN INDIA, THE SAME WAS TAXABLE IN INDIA. IN COMING TO SUCH CONCLUSION, THE ASSESSING OFFICER DIFFERED WITH THE ASSESSEE ON THE NATURE OF THE IMPUGNED FEE , WHICH ACCORDING TO 4 ITA NO.1247/MUM/2016, 7357/MUM/2017 & CO NO.278/MU M/2017 M/S. CREDIT SUISSE AG HIM WAS IN THE NATURE OF FEE FOR TECHNICAL SERVICE S AND NOT BUSINESS INCOME AS CONTENDED BY THE ASSESSEE. FOR THE SAID REASONS, THE ASSESSING OFFICER BROUGHT TO TAX A SUM OF RS. 18,27,90,578/- TO TAX IN HAND OF THE ASSESSEE AS FEE FOR TECHNICAL SERVICES EARNED BY CSDB IN THE DRAFT ASSESSMENT ORDER PASSED U/S.144C(1) READ WITH SECTI ON 143(3) OF THE ACT DATED 25.03.2015. AGAINST THE SAID ORDER, THE ASSES SEE RAISED VARIOUS OBJECTIONS BEFORE THE DRP, INTER-ALIA, ASSAILING THE STAND OF THE ASSESSING OFFICER OF NOT TREATING THE REFERRAL FEE AS BUS INESS INCOME BUT FEE FOR TECHNICAL SERVICES AND ALSO CONTENDED THAT SUCH FE E WAS NOT TAXABLE IN THE HANDS OF THE ASSESSEE IN INDIA. THE ORDER OF THE DR P HAS CAPTURED THE VARIOUS SUBMISSIONS OF THE ASSESSEE IN DETAIL, WHIC H WE ARE NOT REPEATING HERE BECAUSE THE DRP HAS ULTIMATELY UPHELD THE PLE A OF THE ASSESSEE OF NON- TAXABILITY OF THE SAID RECEIPTS IN INDIA ON A SHORT POINT, WHICH IS TO THE EFFECT (I) THAT THE REFERRAL FEE INCOME IN QUESTION IS NOT IN THE NATURE OF FEE FOR TECHNICAL SERVICES; AND (II) THAT, THE REFERRAL FE E WAS NOT ATTRIBUTABLE TO ASSESSEES PERMANENT ESTABLISHMENT (PE) IN INDIA, A ND THUS SUCH REFERRAL FEE WAS NOT LIABLE TO BE TAXED IN INDIA AS PER ART ICLE 7 OF THE INDO-SWISS DOUBLE TAXATION AVOIDANCE AGREEMENT (DTAA). IN SUM AND SUBSTANCE AS PER THE DRP, CSDB UNDERTOOK THE REFERRAL ACTIVITY AND I T HAD NO PE IN INDIA AND SO FAR AS ASSESSEES PE IN INDIA IS CONCERNED, SUCH INCOME COULD NOT BE ATTRIBUTABLE TO ITS ACTIVITIES IN INDIA. ACCORDINGL Y, THE ASSESSING OFFICER PASSED THE FINAL ASSESSMENT ORDER U/S.144C(13) R.W. S. 143(3) DATED 11/01/2016 EXCLUDING THE SUM OF RS. 18,27,90,578/- FROM THE TOTAL INCOME, WHICH IS BEING AGITATED BY THE REVENUE BEFORE US. 4. IN THIS BACKGROUND, THE LEARNED DR HAS REFERRED TO THE ABOVE STATED GROUNDS OF THE APPEAL WHEREBY, FIRSTLY, IT IS CANVA SSED THAT THE DRP WAS 5 ITA NO.1247/MUM/2016, 7357/MUM/2017 & CO NO.278/MU M/2017 M/S. CREDIT SUISSE AG WRONG IN HOLDING THAT THE REFERRAL FEE RECEIVED FRO M INDIAN COMPANY DID NOT CONSTITUTE FEE FOR TECHNICAL SERVICES. SECONDLY, THE REVENUE HAS ALSO CANVASSED ERROR ON THE PART OF THE DRP IN HOLDING T HAT THE REFERRAL FEE COULD NOT BE CONSIDERED TO BE ATTRIBUTABLE TO ASSESSEES PE IN INDIA. NOTABLY, AT THE TIME OF HEARING, THE GROUNDS OF APPEAL RAISED B Y THE REVENUE HAVE BEEN REITERATED BY THE LD. CIT-DR BUT NO SPECIFIC ARGUME NT, ON FACTS OR IN LAW, HAS BEEN LED BEFORE US TO ASSAIL THE DIRECTIONS OF THE DRP. THE LEARNED DR HAS MERELY REFERRED TO THE STAND OF THE ASSESSING OFFIC ER, AS MANIFESTED IN THE DRAFT ASSESSMENT ORDER, SPECIALLY THE FACT THAT THE REFERRAL FEE INCOME HAS BEEN HELD TO BE IN THE NATURE OF FEE FOR TECHNICAL SERVICES. 5. ON THE OTHER HAND, LEARNED REPRESENTATIVE FOR TH E ASSESSEE HAS DEFENDED THE DIRECTIONS OF THE DRP, AND, IN PARTICULAR POINT ED OUT THAT THE FOLLOWING DECISIONS CLEARLY SUPPORT THE INFERENCE OF THE DRP THAT THE REFERRAL FEE IN QUESTION CANNOT BE CONSTRUED TO BE IN THE NATURE OF FEE FOR TECHNICAL SERVICES AND THAT THE SAME IS MERELY IN THE NATURE OF COMMISSION INCOME. (I) CUSHMAN & WAKEFIELD (S) PTE. LTD., 305 ITR 208( AAR) (II) CLSA LTD., VS. ITO (INTERNATIONAL TAXATION), 5 6 SOT 254(MUM) (III) ADIT (IT) VS.STAR CRUISE INDIA TRAVEL SERVICE S (P) LTD., 46 SOT 173(MUM) 6. THE STAND OF THE ASSESSEE IS THAT CONSIDERING T HE FACT THAT THE REFERRAL FEE IS IN THE NATURE OF COMMISSION INCOME, THE DRP MADE NO MISTAKE IN TREATING IT AS NOT TAXABLE IN INDIA IN VIEW OF THE ARTICLE 7 OF THE INDO-SWISS DOUBLE TAXATION AVOIDANCE AGREEMENT (DTAA). 7. WE HAVE CAREFULLY CONSIDERED THE RIVAL SUBMISSIO NS. AS THE AFORESAID DISCUSSION SHOWS, THE SHORT CONTROVERSY BEFORE US R ELATES TO THE NATURE AND 6 ITA NO.1247/MUM/2016, 7357/MUM/2017 & CO NO.278/MU M/2017 M/S. CREDIT SUISSE AG CHARGEABILITY TO TAX OF REFERRAL FEE OF RS.18,27,90 ,578/- RECEIVED BY ASSESSEES DUBAI BRANCH (CSDB) FROM THE INDIAN COMP ANY. THE CHARGE OF THE ASSESSING OFFICER IS THAT HAVING REGARD TO SECTION 5(2)(B) READ WITH SECTION 9(1)(I) OF THE ACT, THE SAID INCOME IS INCLUDIBLE I N THE SCOPE OF TOTAL INCOME CHARGEABLE TO TAX IN INDIA. TO PUT IT DIFFERENTLY, AS PER THE ASSESSING OFFICER, REFERRAL FEE IS DEEMED TO ACCRUE OR ARISE IN INDI A AND THEREFORE, THE SAME IS TAXABLE IN INDIA. THIS HAS BEEN INFERRED ON THE STR ENGTH OF THE FACT THAT THE FEE HAS BEEN PAID BY THE INDIAN COMPANY AFTER EXECU TION OF THE WORK OF THE REFERRED CLIENT BASED IN INDIA AND THEREFORE, THE S OURCE OF THE FEE IS LOCATED IN INDIA. ALLIED TO THE AFORESAID STAND, THE PERCEP TION OF THE ASSESSING OFFICER IS THAT SAID REFERRAL FEE IS IN THE NATURE OF FEE FOR TECHNICAL SERVICES. THE EXPRESSION FEES FOR TECHNICAL SERVICES FINDS MEAN ING IN EXPLANATION(2) BELOW SECTION 9(1)(VII) OF THE ACT; BROADLY SPEAKIN G, THE EXPLANATION PRESCRIBES THAT FEES FOR TECHNICAL SERVICES, MEANS ANY CONSIDERATION FOR RENDERING OF ANY MANAGERIAL, TECHNICAL OR OTHER CON SULTANCY SERVICES, INCLUDING THE PROVISION OF SERVICES OF TECHNICAL OR OTHER PERSONNEL, BUT DOES NOT INCLUDE CONSIDERATION FOR ANY CONSTRUCTION, ASS EMBLING, MINING OR LIKE PROJECT UNDERTAKEN BY THE RECIPIENT OR CONSIDERATIO N WHICH WOULD BE INCOME OF THE RECIPIENT CHARGEABLE UNDER THE HEAD SALARI ES. AT THIS STAGE, WE MAY BRIEFLY TOUCH UPON THE NATURE OF THE IMPUGNED REFER RAL FEE EARNED BY THE ASSESSEE. THE RELEVANT DISCUSSION IN THE ORDERS OF THE AUTHORITIES BELOW REVEAL THAT CSDB REFERRED AN INDIA RESIDENT CLIENT TO THE INVESTMENT BANKING DIVISION OF THE INDIAN COMPANY; INDIAN COMPANY WOR KED ON THE ASSIGNMENT OF THE ISSUE OF CONVERTIBLE BONDS FOR THE REFERRED CLIENT, AND 50% OF THE FEE EARNED BY THE INDIAN COMPANY WAS PAID TO CSDB IN TE RMS OF GLOBAL POLICY OF THE GROUP, WHICH IS THE AMOUNT OF RS.18,27,90,578/- IN QUESTION. IN THE 7 ITA NO.1247/MUM/2016, 7357/MUM/2017 & CO NO.278/MU M/2017 M/S. CREDIT SUISSE AG FACE OF SUCH FACT SITUATION, WE ARE UNABLE TO APPRE CIATE THE STAND OF THE ASSESSING OFFICER AS TO WHY THE REFERRAL FEE IS T O BE CONSTRUED AS FEES FOR TECHNICAL SERVICES AS UNDERSTOOD FOR THE PURPOSES OF THE ACT. AS PER THE ASSESSING OFFICER, THE REFERRAL FEE HAS BEEN PAID BY THE INDIAN COMPANY AFTER THE EXECUTION OF THE WORK OF THE REFERRED CLI ENT. MERELY BECAUSE THE FEE WAS PAYABLE BY THE INDIAN COMPANY TO CSDB AFTER EXECUTION OF THE WORK OF THE REFERRED CLIENT IS NO GROUND TO DETERMINE TH E NATURE OF THE PAYMENT. IN THIS CONTEXT, THE AUTHORITY FOR ADVANCE RULINGS IN THE CASE OF CUSHMAN & WAKEFIELD(S) PTE. LTD., (SUPRA) HAS DEALT WITH A SO MEWHAT SIMILAR SITUATION, WHEREIN THE APPLICANT WAS A RESIDENT OF SINGAPORE, WHO HAD EARNED COMMISSION FROM AN INDIA BASED ENTITY FOR HAVING RE FERRED CUSTOMERS. AS PER THE AUTHORITY FOR ADVANCE RULINGS, SUCH REFERRAL F EE, BEING IN THE NATURE OF COMMISSION WAS TO BE TREATED AS BEING IN THE NATU RE OF BUSINESS INCOME; BOTH, UNDER THE ACT AS WELL AS UNDER THE INDO-SINGA PORE DOUBLE TAXATION AVOIDANCE AGREEMENT (DTAA), AND NOT AS FEES FOR TE CHNICAL SERVICES. TO THE SIMILAR EFFECT IS THE DECISION OF THE MUMBAI TRIBUN AL IN THE CASE OF CLSA LTD., (SUPRA) WHEREIN ALSO REFERRAL FEE EARNED BY A NON-R ESIDENT ASSESSEE FROM AN INDIA BASED ENTITY FOR REFERRING CERTAIN INTERNATIO NAL CLIENTS WAS HELD NOT TO BE IN THE NATURE OF FEES FOR TECHNICAL SERVICES W ITHIN THE MEANING OF SECTION 9(1)(VII) OF THE ACT. NOTABLY, THE AFORESAID DECISI ONS HAVE ALSO BEEN REFERRED AND RELIED UPON BY THE DRP IN CONCLUDING THAT THE REFERRAL FEE IS IN THE NATURE OF COMMISSION TO BE TAXED AS BUSINESS INC OME AND NOT AS FEES FOR TECHNICAL SERVICES. IN THE COURSE OF HEARING BEFOR E US, NO DECISION TO THE CONTRARY HAS BEEN BROUGHT OUT BY THE REVENUE. FOR A LL THE SAID REASONS, WE ARE UNABLE TO UPHOLD THE STAND OF THE ASSESSING OFF ICER THAT THE IMPUGNED 8 ITA NO.1247/MUM/2016, 7357/MUM/2017 & CO NO.278/MU M/2017 M/S. CREDIT SUISSE AG REFERRAL FEE WAS A CONSIDERATION IN THE NATURE OF FEES FOR TECHNICAL SERVICES. 8. ANOTHER FACTUAL ASPECT WHICH IS NOT IN DISPUTE I S THAT CSDB HAS NO PE IN INDIA AND ALSO THE FACT THAT ASSESSEES PE IN INDIA I.E., MUMBAI BANK BRANCH HAD NO ROLE TO PLAY IN THE PERFORMANCE OF THE REFER RAL ACTIVITY IN QUESTION. NEITHER THE DISCUSSION IN THE DRAFT ASSESSMENT ORDE R AND NOR IN THE COURSE OF HEARING BEFORE US ANY CREDIBLE ASSERTIONS TO THE CO NTRARY HAS BEEN BROUGHT OUT BY THE REVENUE. THUS, CONSIDERING THAT THE REFE RRAL ACTIVITY WAS UNDERTAKEN OUTSIDE INDIA AND ASSESSEES MUMBAI BRA NCH (PE) HAD NO ROLE TO PLAY IN THE PERFORMANCE OF THE REFERRAL ACTIVITY, T HE REFERRAL FEE OF RS.18,27,90,578/- EARNED BY CSDB COULD NOT BE CONS TRUED TO BE ATTRIBUTABLE TO ASSESSEES PE IN INDIA AND THUS, THE DRP RIGHTLY APPLIED ARTICLE 7 OF INDO- SWISS DOUBLE TAXATION AVOIDANCE AGREEMENT (DTAA) AN D HELD THE SAME TO BE NON-TAXABLE IN INDIA. THE AFORESAID CONCLUSION O F THE DRP IS HEREBY AFFIRMED. THEREFORE, CONSIDERING THE SHORT POINT O N THE BASIS OF WHICH THE DRP HAS ALLOWED THE PLEA OF THE ASSESSEE, WE DISPO SE OF THE AFORESAID APPEAL BY AFFIRMING THE ULTIMATE DIRECTION OF THE D RP. THUS, REVENUE FAILS IN ITS APPEAL. ITA NO.7357/MUM/2017 & CROSS OBJECTION NO.278/MUM /2017 9. IN SO FAR AS CAPTIONED CROSS APPEAL AND THE CROS S OBJECTION FILED BY THE ASSESSEE ARE CONCERNED, THE LEARNED REPRESENTATIVE OF THE ASSESSEE STATED AT THE TIME OF HEARING THAT THE SAME WOULD BE RENDERED INFRUCTUOUS ONCE THE APPEAL OF THE REVENUE IS DISMISSED; SINCE WE HAVE D ISMISSED THE APPEAL OF THE REVENUE IN THE FOREGOING PARAGRAPHS, THE CROSS- APPEAL AND THE CROSS- OBJECTION OF THE ASSESSEE ARE DISMISSED AS INFRUCT UOUS. 9 ITA NO.1247/MUM/2016, 7357/MUM/2017 & CO NO.278/MU M/2017 M/S. CREDIT SUISSE AG 10. BEFORE PARTING, WE MAY ALSO MENTION THAT ASSESS EE HAS MADE AN APPLICATION UNDER RULE 27 OF THE INCOME-TAX (APPELL ATE TRIBUNAL) RULES, 1963 WHICH ALSO IS RENDERED INFRUCTUOUS AS PER THE SAY O F THE LEARNED REPRESENTATIVE FOR THE ASSESSEE, ONCE THE APPEAL OF THE REVENUE STANDS DISMISSED BY US. 11. RESULTANTLY, CAPTIONED APPEALS BY THE REVENUE AS WE LL AS THE ASSESSEE ARE DISMISSED, AS ABOVE. ORDER PRONOUNCED IN THE OPEN COURT ON 09/ 02/201 8 SD/- SD/- (RAVISH SOOD ) (G.S. PANNU) JUDICIAL MEMBER ACCOCUNTANT MEMBER MUMBAI, DATED 09/02/2018 KARUNA, SR. PS COPY OF THE ORDER FORWARDED TO : 1. THE APPELLANT, 2. THE RESPONDENT. 3. THE CIT(A)- 4. CIT 5. DR, ITAT, MUMBAI 6. GUARD FILE. BY ORDER, //TRUE COPY/ (DY./ASSTT. REGISTRAR), ITAT, MUMBAI
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