Appeal details
Counselvise Citation
126122514 RSA 2014
Assessee PAN
Bench
Appeal Number
Duration Of Justice
8 month(s) 24 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
20-03-2015
Appeal Filed By
Department
Order Result
Allowed
Bench Allotted
A
Next Hearing Date
17-03-2015
Assessment Year
2006-2007
Appeal Filed On
26-06-2014
Judgement Text
ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 1 OF 10 IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD A BENCH, HYDERABAD BEFORE SHRI P.M. JAGTAP, ACCOUNTANT MEMBER & SMT.ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER ITA NO.1261/HYD/2014 (ASSESSMENT YEAR: 2006-07) DY. COMMISSIONER OF INCOME TAX CIRCLE 14(2) HYDERABAD VS. M/S. LANCO AMARKANTAK POWER (P) LTD PLOT NO.4, SOFTWARE UNITS LAYOUT, MADHAPUR, HYDERABAD PAN: AACCK 0633 Q (APPELLANT) (RESPONDENT) FOR REVENUE : SHRI RAMAKRISHNA BANDI, DR FOR ASSESSEE : SHRI S. RAMA RAO DATE O F HEARING : 17/03/2015 DATE OF PRONOUNCEMENT : 20 /03/2015 O R D E R PER SMT. ASHA VIJAYARAGHAVAN, J.M. THIS APPEAL IS PREFERRED BY THE REVENUE AGAINST TH E ORDER OF THE CIT (A)-V HYDERABAD DATED 31.01.2014 PASSED FOR A.Y 2006- 07. 2. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE IS A COMPANY INCORPORATED WITH AN OBJECT TO CARRY ON THE BUSINES S OF POWER GENERATION AND ALLIED ACTIVITIES AND IT HAS BEEN IN THE PROCESS OF SETTING UP A THERMAL POWER GENERATING STATION IN CH HATTISGARH. ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 2 OF 10 THE AO FOUND THAT AN AMOUNT OF RS.1,23,51,998 IS TR ANSFERRED TO CAPITAL WORK-IN-PROGRESS AND IS REPRESENTING PAY MENT OF SERVICE CHARGES TO CHHATTISGARH STATE INDUSTRIAL DE VELOPMENT CORPORATION LTD. ACCORDING TO THE AO, THE SAID PAYM ENT SHOULD HAVE BEEN SUBJECTED TO DEDUCTION OF TAX AT SOURCE U /S 194J OF THE ACT. AO AFTER CONSIDERING THE EXPLANATION OF TH E ASSESSEE HELD THAT THE NATURE OF THE PAYMENT IS PROFESSIONAL FEE U/S 194J OF THE ACT, THE ASSESSEE OUGHT TO HAVE DEDUCTE D TDS U/S 194J OF THE ACT AND SINCE THE ASSESSEE HAS NOT DEDUCTED TDS, THE COMPANY WAS TREATED AS ASSESSEE IN DEFAULT AND HELD THAT OUT OF RS.1,21,51,998, AN AMOUNT OF RS.82 ,00,034 WAS PAID TO CSIDC LIMITED TOWARDS SERVICE CHARGES F OR THE F.Y.2005-06 AND ACCORDINGLY THE AMOUNT OF RS.82,00, 034 WAS CONSIDERED IN THE ASST. YEAR UNDER CONSIDERATIO N AND ACCORDINGLY CALCULATED TDS U/S 201 (1) AND INTEREST U/S 201 (LA) AMOUNTING TO RS.12,80,979. 3. BEFORE THE CLT (APPEALS)-II, HYDERABAD, THE ASSESSE E SUBMITTED THE FOLLOWING SUBMISSIONS, WHICH ARE AS U NDER: THE ASSESSING OFFICER IS THE INCOME-TAX OFFICER, WARD-14(3), HYDERABAD. IN ALL THE ABOVE CASES THE ONLY ISSUE IS WITH .REGARD TO DEDUCTION OF TAX IN RESPECT OF PAYMENT OF LEASE RENTALS AND SERVICE ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 3 OF 10 CHARGES TO CHHATTISGARH STATE INDUSTRIAL DEVELOPMEN T CORPORATION LTD. (CSIDC). ACCORDING TO THE ASSESSIN G OFFICER, THE APPELLANT HEREIN HAS TO DEDUCT TAX AT SOURCE IN RESPECT OF THE PAYMENT OF LEASE RENTALS MADE TO CSIDC. BEFORE THE ASSESSING OFFICER IT WAS SUBMITTED THAT THE CSIDC IS COLLECTING LEASE RENTALS AND THE CHARGES ON BEHALF OF THE GOVERNMENT OF CHHATTISGARH. THE AGREEMENTS WERE ENTERED INTO B Y THE MANAGING DIRECTOR, CSIDC ON BEHALF OF THE GOVERNOR OF CHHATTISGARH. A COPY EACH OF THE AGREEMENTS ENTERED INTO DATED 03-08-2005, 21-06- 2006 AND 09-09-2007 WERE SUBMITTED BEFORE THE ASSESSING OFFICER AND COPIES ARE SUBMITTED BEFORE T HE HON'BLE C1T(A). ACCORDING TO THE SAID AGREEMENTS, T HE GOVERNMENT OF CHHATTISGARH ALLOTTED AC.260.92 CENTS OF LAND AT PATHADI VILLAGE, KORBA DISTRICT OF CHHATTISGARH FOR ESTABLISHING ELECTRICAL POWER GENERATION AND DISTRIBUTION UNIT. THE GROUND RENT I S FIXED AT RS. 13,00,732/- FOR FIRST 30 YEARS; ALL TH E AGREEMENTS ARE SIMILARLY WORDED. THE APPELLANT SUBMITTED BEFORE THE ASSESSING OFFICER THAT THE AMOUNT IS SHOWN SEPARATELY BY THE CSIDC AS PAYABLE TO THE STATE GOVERNMENT. IT CAN BE SEEN FROM THE FI NAL ACCOUNTS DRAWN ON 31-03-2005 THAT THE AMOUNT OF LEASE RENTS ARE TAKEN AS THE REVENUE RECEIPT AND IS CREDITED TO STATE GOVERNMENT ACCOUNT. THEREFORE, IT IS CLEAR THAT THE SAID LEASE RENTALS PAID DO NOT RELATE TO THE CSIDC BUT RELATES TO THE STATE GOVERNMENT OF CHHATISGARH. THE SAID CSIDC COLLECTED THE AMOUNTS AS A TRUSTEE FOR THE GOVERNMENT. THEREFORE, THE APPELLANT SUBMITTED THAT THE PROVISI ONS OF SEC. 194-1 HAVE NO APPLICATION. THE ASSESSING OFFICER, HOWEVER, DID NOT CONSIDER TH E EXPLANATION SUBMITTED. IT IS MENTIONED IN THE ORDER S PASSED BY HIM THAT AS THE APPELLANT HAS NOT DEDUCTE D TAX, THE COMPANY IS TREATED IN DEFAULT. THE ASSESSI NG OFFICER DID NOT CONSIDER THE FACT THAT THE AMOUNT W AS PAID TO GOVERNMENT AND NO TDS NEED BE MADE IN VIEW OF THE SEC. 196 OF THE ACT. IT IS SUBMITTED THAT FOR THE PURPOSE OF ESTABLISHIN G THE POWER PLANT IN CHHATTISGARH, THE LANDS WERE TO BE ALLOTTED BY THE GOVT. FOR THIS PURPOSE THE GOVERNMENT ALLOTTED ITS OWN LAND, BESIDES ACQUISITION OF PRIVA TE ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 4 OF 10 LANDS. COMPENSATION IS PAID TOWARDS THE ALLOTMENT ALL SUCH LANDS BELONGING TO OTHERS BY THE ASSESSEE TO THE GOVERNMENT. THE DETAILS OF THE LANDS ACQUIRED B Y THE GOVERNMENT FROM PRIVATE PARTIES AND THE LAND ALLOTTED BY THE GOVERNMENT ARE SUBMITTED IN AN ANNEXURE. WHEREVER THE ACQUISITION WAS MADE FROM PRIVATE PARTIES BY THE GOVERNMENT COMPENSATION FOR ACQUISITION IS PAYABLE BY THE GOVERNMENT TO THE PRIVATE PARTIES. THE ASSESSEE COMPANY REIMBURSED SUCH COMPENSATION TO THE GOVERNMENT BESIDES MAKING PAYMENT OF COMPENSATION FOR THE LANDS ALLOTTED BY THE GOVERNMENT. SUCH COMPENSATION PAYABLE IS PAID BY THE ASSESSEE TO THE GOVERNMENT THROUGH CSIDC. THE GOVERNMENT ALSO INCURS EXPENDITURE IN ACQUIRING THE LAND FROM THE PRIVATE PARTIES. SUCH EXPENDITURE INCURRED BY THE GOVERNMENT IN THE PROCESS OF ACQUISITION OF THE LAN DS IS REIMBURSED BY THE ASSESSEE THROUGH CSIDC AND THE SAID PAYMENT IS CALLED THE SERVICE CHARGES. THE ASSESSEE HUMBLY SUBMITS THAT EVEN THE SERVICE CHARGES ARE PAID TO THE GOVERNMENT. FURTHER, THE AMOUNT WAS NOT PAID FOR ANY SERVICES RENDERED TO THE ASSESSEE. IT MAY KINDLY BE SEEN THA T THE SERVICE CHARGES ARE WORKED AT 10% OF THE COST O F LAND ACQUIRED FROM PRIVATE PARTIES. NO SERVICES CHARGES ARE PAID WITH REGARD TO THE LAND ALLOTTED B Y THE GOVERNMENT TO THE ASSESSEE. THE. APPELLANT SUBMITS THAT THE SERVICE CHARGES ARE NOT FOR RENDERING ANY SERVICES TO THE ASSESSEE AND ARE PAID TO GOVERNMENT THROUGH CSIDC TOWARDS EXPENDITURE INCURRED BY GOVERNMENT IN ACQUIRING AND DEVELOPING THE LAND. THEREFORE, THERE IS NO REQUIREMENT FOR DEDUCTION OF TAX AT SOURCE AGAINST SERVICE CHARGES. IN SO FAR AS LEASE RENTS ARE CONCERNED, THE SAME WERE PAID TO GOVERNMENT. THE APPELLANT SUBMITS THAT THE ASSESSING OFFICER DI D NOT CONSIDER THE FACT WHETHER THE PROVISIONS OF SEC . 194-1 HAVE APPLICATION TO THE FACTS OR NOT. IT IS SUBMITTED THAT ACCORDING TO SEC. 194-1 ANY PERSON WHO IS MAKING PAYMENT OF RENT AT THE TIME OF CREDIT OF SUCH INCOME TO THE ACCOUNT OF THE PAYEE TAX HAS TO BE DEDUCTED AT SOURCE. THE INCOME OF THE CHHATISGARH STATE GOVERNMENT IS NOT ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 5 OF 10 ASSESSABLE TO TAX AND, THEREFORE, NO TAX NEED BE DEDUCTED AT SOURCE. ACCORDING TO THE PROVISIONS OF SEC. 196 OF THE I. T.ACT, THE PROVISIONS OF THE CHAPTER WOULD NOT APPLY TO ANY PAYMENTS MADE TO THE GOVERNMENT AND, THEREFORE, THERE IS NO OBLIGATION FOR THE APPELLANT HEREIN TO DEDUCT TAX A T SOURCE. IN THIS VIEW OF THE MATTER, THE APPELLANT SUBMITS THAT THE ASSESSING OFFICER IS NOT JUSTIFIED IN PASS ING AN ORDER TREATING THE APPELLANT AS IN DEFAULT AND CHARGING INTEREST AND THE TDS. IN THE CIRCUMSTANCES, THE APPELLANT PRAYS THE HON'BLE COMMISSIONER OF INCOME- TAX (APPEALS) TO KINDLY CANCEL THE ORDERS PASSED BY THE ASSESSING OFFICER. 4. THE CIT (APPEALS)-II, HYDERABAD, VIDE HER LETTER DATED 11-2- 2011 HAD CALLED FOR A REMAND REPORT FROM ITO 14(3)' HYDERABAD. THE AO, VIDE HIS LETTER DATED 18-5-2011, AFTER PERU SING RULE 10 OF THE CHATTISGARH INDUSTRIES (ALLOTMENT OF SHED, P LOTS AND LAND) RULES, 1974, HAD OPINED THAT THE SERVICES CHARGES COLLECTED BY THE CSIDC FROM THE ASSESSEE WAS FOR THE ACQUISITION OF THE PRIVATE LAND/GOVT. LAND. SINCE THE CSIDC WAS FACILI TATING THE ACQUISITION OF THE PRIVATE LAND/GOVT. LAND FROM THE STATE GOVT, THE SERVICES ARE AKIN TO THE TECHNICAL CONSULTANCY AND THE SAME SHALL FALL UNDER EXPLANATION OF 194J OF THE ACT. THE AO S TATED THAT THEY WERE NOT CHARGES OF THE NATURE OF REIMBURSEMEN T. FURTHER, CSIDC WAS INDEPENDENT ENTITY AS FROM THAT OF GOVT. OF CHHATTISGARH. ON THE CONTENTION OF THE ASSESSEE THA T THE ABOVE ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 6 OF 10 SERVICES CHARGES WERE SHOWN SEPARATELY UNDER CAPITA L ACCOUNT, THE AO OPINED THAT THAT WOULD NOT IN ANY WAY MITIGA TE THE LIABILITY OF TDS ON ACCOUNT OF DEDUCTOR AS THE DEDU CTEE I.E. SCIDC HAD NOT OFFERED THE ABOVE SERVICE CHARGES FOR INCOME AS IT WAS HELD IN THE CASE OF HINDUSTAN COCA-COLA BEVERA GE LTD VS. CIT (163 TAXMAN 355 (SC). 5. BEFORE THE CIT (A) THE ASSESSEE CONTENDED THAT T HE PAYMENTS WERE MADE TO CHHATTISGARH STATE INDUSTRIAL DEVELOPMENT CORPORATION LTD., ON BEHALF OF GOVERNME NT OF CHHATTISGARH AND SUCH AMOUNTS HAVE BEEN CREDITED TO THE ACCOUNT OF CHHATTISGARH STATE INDUSTRIAL DEVELOPMEN T CORPORATION LTD. THEREFORE, THE ASSESSEE CONTENDED THAT THE DEDUCTION OF TAX AT SOURCE U/S 194J NEED NOT BE EFF ECTED. 6. THE ASSESSEE FILED A COPY OF THE AGREEMENT BETWE EN THE ASSESSEE COMPANY AND GOVERNMENT OF CHHATTISGARH REP RESENTED BY CHHATTISGARH STATE INDUSTRIAL DEVELOPMENT CORPOR ATION LTD. THE ASSESSEE ALSO FILED COPY OF THE FINAL ACCOUNTS OF THE SAID CORPORATION WHICH SHOWS THAT THE AMOUNTS RECEIVED F ROM THE ASSESSEE WERE CREDITED TO THE ACCOUNT OF THE GOVERN MENT. IN VIEW OF THE ABOVE, THE ASSESSEE PLEADED THAT THE PAYMENT S WERE MADE ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 7 OF 10 TO THE GOVERNMENT OF CHHATTISGARH AND, THEREFORE, N O DEDUCTION OF TAX AT SOURCE NEED BE MADE. FURTHER IT IS ALSO S UBMITTED THAT THE SERVICE CHARGES HAVE BECOME PAYABLE IN CONNECTI ON WITH THE ACQUISITION OF PRIVATE LAND OR FOR ALLOTMENT OF GOV T. LAND. IT WAS SUBMITTED THAT THE PAYMENT WAS MADE PURELY IN CONNE CTION WITH THE ACQUISITION OF THE LAND AND THEREFORE, IS NOT L IABLE FOR DEDUCTION OF TAX AT SOURCE. THE ALTERNATIVE SUBMISS ION OF THE ASSESSEE IS THAT THE CHHATTISGARH STATE INDUSTRIAL DEVELOPMENT CORPORATION LTD IS ASSESSED TO TAX AND FILED ITS RE TURN OF INCOME FOR THE AY 2006-07. THEREFORE, THE ORDER U/S 201(1) IS NOT JUSTIFIED AND INTEREST SHOULD BE LIMITED TO THE DAT E OF FILING OF RETURN OF INCOME BY THE CHHATTISGARH STATE INDUSTRI AL DEVELOPMENT CORPORATION LTD. 7. THE LD CIT (A) HELD THAT HE HAD VERIFIED THE REC ORD AND FOUND THAT THE AMOUNTS WERE PAID TOWARDS ACQUISITIO N OF LAND WHICH IS NOT GOVERNED BY THE PROVISIONS OF SEC 194J OF THE ACT. THE CIT (A) ALSO FOUND THAT CHHATTISGARH STATE INDU STRIAL DEVELOPMENT CORPORATION LTD IS THE REPRESENTATIVE O N BEHALF OF THE GOVT. OF CHHATTISGARH AND THEREFORE, THE PROVIS IONS OF SEC 194J ARE NOT APPLICABLE. THE CIT (A) AGREED WITH TH E CONTENTIONS OF THE ASSESSEE AND CANCELLED THE LEVY U/S 201(1) & 201(1A) OF ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 8 OF 10 THE I.T. ACT CHARGED BY THE AO. 8. THE REVENUE HAS RAISED THE FOLLOWING GROUNDS: 1. THE ORDER OF THE CIT (A) IS ERRONEOUS BOTH ON F ACTS AND IN LAW. 2. THE CIT (A) ERRED IN HOLDING THAT THE SERVICE CHARGES PAID TO CHATTISGARH STATE INDUSTRIAL DEVELOPMENT CORPORATION (CSDIC) IS NOT GOVERNED BY THE PROVISIONS U/S 194J OF THE I.T. ACT BY TREATING THE SAME AS PAYMENT TO GOVT. 3. THE CIT (A) ERRED IN IGNORING THE FACT THAT CHATTISGARH STATE INDUSTRIAL DEVELOPMENT CORPORATIO N (CSIDC) IS SEPARATE LEGAL ENTITY ASSESSED TO TAX AN D NOT PART OF THE STATE GOVT. AND HENCE THE SERVICE CHARGES PAID TO IT ARE GOVERNED BY THE PROVISIONS U /S 194J OF THE I.T. ACT. 9. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE R ECORD CAREFULLY. SIMILAR ISSUE WAS ADJUDICATED BY THE TR IBUNAL RELATING TO THE ISSUE OF DEMAND RAISED U/S 201(1) AND INTERE ST CHARGED U/S 201(1A) OF THE ACT FOR NOT DEDUCTING TAX AT SOU RCE U/S 194I OF THE ACT, WHEREIN THE TRIBUNAL IN ITA NO.1775 TO 1778 OF 2012 IN ASSESSEES OWN CASE HELD AS FOLLOWS: 8. WE HAVE CONSIDERED RIVAL SUBMISSIONS OF THE PARTIES AND PERUSED THE MATERIAL ON RECORD. THE DISPUTE IN THE PRESENT CASE IS LIMITED TO THE FACT AS TO WHETHER AS PER THE CLAIM OF THE ASSESSEE, THE LEASE RENTALS WERE ACTUALLY PAID TO THE STATE GOVT. OF CHATTISGARH AND CSIDC WAS ACTING MERELY AS AN AGENT OF STATE GOVT. OR WHETHER THE LEASE RENTALS W ERE PAID TO CSIDC ITSELF. ON PERUSAL OF SUMMARY OF THE ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 9 OF 10 STATE GOVERNMENT WHICH FORMS PART OF THE FINAL ACCOUNTS OF CSIDC AS ON 31.03.2005 IT IS SEEN THAT IT IS A STATEMENT SHOWING RECEIPTS ON BEHALF OF THE ST ATE GOVT. FROM ENTREPRENEURS WHEREIN THE LEASE RENTALS ALSO FINDS PLACE. IT IS ALSO A FACT THAT IN COURSE OF THE APPEAL PROCEEDINGS BEFORE THE CIT (A) A REMAND REPO RT WAS CALLED FOR FROM THE AO. ON PERUSAL OF THE REMAN D REPORT BY THE AO, A COPY OF WHICH IS AT PAGE 60 OF THE PAPER BOOK, WE FIND NO MENTION ABOUT TO WHOM THE LEASE RENTALS WERE PAID. IT ONLY DEALS WITH PAYMENT OF SERVICE CHARGES. EVEN SO FAR AS PAYMENT OF SERVICE CHARGES ARE CONCERNED, IT IS THE CONTENTION OF THE LD AR THAT IT HAS BEEN PAID TO THE DISTRICT ADMINISTRA TION AS PER RULE 10 OF THE INDUSTRIAL POLICY OF GOVT. OF CHATTISGARH. IN FACT, THE CIT (A) HAS ALSO TOTALLY IGNORED THIS REMAND REPORT SUBMITTED BY THE AO. CONSIDERING THE TOTALITY OF FACTS AND THE CIRCUMSTANCES OF THE CASE, WE DEEM IT JUST AND PROP ER TO REMIT THESE MATTERS TO THE FILE OF THE AO FOR VE RIFYING THE FACT TO WHOM THE LEASE RENTALS AND SERVICES CHARGES HAVE BEEN PAID. ACCORDINGLY, WE SET ASIDE THE ORDERS PASSED BY THE CIT (A) FOR THE YEARS UNDE R CONSIDERATION AND DIRECT THE AO TO DECIDE THE ISSUE AFRESH AFTER VERIFYING THE FACT OF PAYMENT OF LEASE RENTALS AND SERVICE CHARGES WHICH WERE CLAIMED TO HAVE BEEN PAID TO STATE GOVT. THE AO SHALL AFFORD A REASONABLE OPPORTUNITY OF BEING HEARD TO THE ASSESS EE BEFORE DECIDING THE ISSUE FOR ALL THE YEARS UNDER CONSIDERATION. 10. RESPECTFULLY FOLLOWING THE DECISION OF THE COOR DINATE BENCH, WE DEEM IT JUST AND PROPER TO REMIT THESE MATTERS T O THE FILE OF THE AO FOR VERIFYING THE FACT TO WHOM THE LEASE REN TALS AND SERVICES CHARGES HAVE BEEN PAID. ACCORDINGLY, WE SE T ASIDE THE ORDERS PASSED BY THE CIT (A) FOR THE YEARS UNDER CO NSIDERATION AND DIRECT THE AO TO DECIDE THE ISSUE AFRESH AFTER VERIFYING THE ITA NO.1261 OF 2014 LANCO AMARKANTAK POWER PVT LTD HYDERABAD PAGE 10 OF 10 FACT OF PAYMENT OF LEASE RENTALS AND SERVICE CHARGE S WHICH WERE CLAIMED TO HAVE BEEN PAID TO STATE GOVT. THE AO SHA LL AFFORD A REASONABLE OPPORTUNITY OF BEING HEARD TO THE ASSESS EE BEFORE DECIDING THE ISSUE FOR ALL THE YEARS UNDER CONSIDER ATION 11. IN THE RESULT APPEAL FILED BY THE REVENUE IS AL LOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 20 TH MARCH, 2015. S D/ - S D/ - (P.M. JAGTAP) (ASHA VIJAYARAGHAVAN) ACCOUNTANT MEMBER JUDICIAL MEMBER HYDERABAD, DATED 20 TH MARCH, 2015. VNODAN/SPS COPY TO: 1. THE DY. COMMISSIONER OF INCOME TAX CIRCLE 14(2) TDS RANGE 14, IT TOWERS, 4 TH FLOOR, B BLOCK, HYDERABAD 2. M/S. LANCO AMARKANTAK POWER (P) LTD, PLOT NO.4, SOF TWARE UNITS LAYOUT, MADHAPUR, HYDERABAD 3. THE CIT(A) - V HYDERABAD 4. THE CIT I HYDERABAD 5. THE DR, ITAT, HYDERABAD 6. GUARD FILE BY ORDER
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