DCIT, Circle-3(2), Hyd, Hyderabad V. Suryalakshmi Cotton Mills Ltd., Hyd, Secunderabad

ITA 1385/HYD/2015

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 5922 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 21-12-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 15-12-2016
• Assessment Year: 2008-2009
• Appeal Filed On: 11-12-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: G APARNA RAO
• Assessee Lawyers: V SIVA KUMAR
• Keywords: Additional evidence; Question of law
• Section: 143(3); 115JB

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SMT P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER ITA NO. 1299/HYD/2015 ASSESSMENT YEAR: 2008-09 M/S SURYALAKSHMI COTTON MILLS LTD., SECUNDERABAD PAN - AAECS1921R VS. DCIT, CIRCLE - 3(2 ). HYDERABAD (APPELLANT) (RESPONDENT) ITA NO. 1385/HYD/2015 ASSESSMENT YEAR: 2008-09 DCIT, CIRCLE - 3(2 ). HYDERABAD VS. SURYALAKSHMI COTTON MILLS LTD., SECUNDERABAD PAN - AAECS1921R (APPELLANT) (RESPONDENT) ASSESSEE BY : SHRI V. SIVA KUMAR REVENUE BY : S MT G. APARNA RAO DATE OF HEARING : 1 5 - 12 - 2016 DATE OF PRONOUNCEMENT : 21 - 12 - 2016 O R D E R PER B. RAMAKOTAIAH, A.M.: THESE ARE CROSS APPEALS BY ASSESSEE AND REVENUE AG AINST THE ORDER OF THE CIT(A)-3, HYDERABAD, DATED 04-09-201 4. ITA NO. 1299/HYD/2015 2. THIS IS AN ASSESSEES APPEAL IN WHICH ASSESSEE I S CONTESTING THE ADJUSTMENT MADE TO THE PRIOR PERIOD EXPENSES WHILE COMPUTING THE BOOK PROFIT U/S 115JB OF THE IT ACT. 2 1299 & 1385/HYD/2016 M/S. SURYA LAKSHMI COTTON MILLS LTD. 3. BRIEFLY STATED, ASSESSEE IS A PUBLIC LTD., COMPANY, ENGAGED IN THE BUSINESS OF MANUFACTURE AND SALE OF COTTON/BLEND ED YARN AND DENIM CLOTH. FOR THE A.Y. 2008-09, THE ASSESSEE F ILED ITS RETURN OF INCOME ON 30-09-08 DECLARING LOSS OF RS. 4 ,05,25,130/- UNDER NORMAL PROVISIONS OF THE ACT AND RS. 1,19,47,05 0/- UNDER THE PROVISION OF SECTION 115JB OF THE ACT. THE ASSESSM ENT WAS COMPLETED U/S 143(3) OF THE ACT, DETERMINING INCOME A T 5,42,40,381/- UNDER THE NORMAL PROVISIONS AND RS. 1, 46,50,347/- U/S 115JB OF THE ACT. THE ADJUSTMENTS MADE WAS OF PRI OR PERIOD EXPENDITURE TO THE EXTENT OF RS.27,03,302/- UNDER THE PR OVISIONS OF SEC.115JB. ASSESSEE STARTED THE COMPUTATION FROM THE NET PROFIT AND REDUCED DIVIDEND INCOME, AS PER THE PROVIS ION AND OFFERED BOOK PROFITS OF RS. 1,19,47,050/-. AO WITHOU T ANY DISCUSSION IN THE ORDER MADE PRIOR PERIOD ADJUSTMENT OF RS. 27,03,302/- AND REVISED BOOK PROFIT WAS DETERMINED AT RS. 1,46,50,347/-. ASSESSEE CONTESTED THE SAME BEFORE TH E LD. CIT(A) SUBMITTING THAT THE PRIOR PERIOD EXPENSES DEBITED TO PRO FIT AND LOSS ACCOUNT IS NOT ONE OF THE ITEMS TO BE ADDED BACK AS SPECIFIED IN THE EXPLANATION TO SECTION 115JB OF THE ACT AND HENCE, THERE IS NO JUSTIFICATION IN ADDING BACK THE AMOUNT AS WAS DONE BY THE A.O. IT WAS FURTHER SUBMITTED THAT IN VIEW OF THE DECISI ON OF THE HONBLE SUPREME COURT IN THE CASE OF APOLLO TYRES LTD. , VS CIT TO ITA NOS. 225 ITR 273 , NO ADJUSTMENT CAN BE MADE TO THE PROFIT AS PER PROFIT AND LOSS ACCOUNT. OTHER THAN THOSE SPECI FIED IN EXPLANATION TO SECTION 115JB. LD. CIT(A) HOWEVER, REJ ECTED THE CONTENTIONS BY STATING AS UNDER: FOR THE PURPOSE OF 115JB THE BOOK PROFIT TO BE CO NSIDERED IS NET PROFIT AS SHOWN IN P&L A/C OF RELEVANT PREVIOUS YEA R AS INCREASED BY / REDUCED BY CERTAIN ITEMS SPECIFICALLY MENTIONE D THEREIN. 3 1299 & 1385/HYD/2016 M/S. SURYA LAKSHMI COTTON MILLS LTD. THEREFORE, THE ASSESSING OFFICER IS CORRECT IN ADOP TING NET PROFIT AT RS. 1,46,50,347/-. THEREFORE, THIS GROUND OF APPEA L IS DISMISSED. 4. AFTER CONSIDERING THE RIVAL CONTENTIONS, WE ARE OF THE OPINION THAT CIT(A) IS NOT JUSTIFIED IN CONFIRMING THE ACTION O F THE AO. FIRST OF ALL, LD. CIT(A) HAS NOT DISCUSSED WHETHER THE PRIOR PERIOD EXPENDITURE CLAIMED IN THE PROFIT AND LOSS ACCOUNT CAN BE ADJUSTED WHILE COMPUTING THE INCOME U/S 115JB OF THE A CT. THIS IS NOT ONE OF THE ITEM WHICH IS TO BE CONSIDERED AS P ER EXPLANATION TO SECTION 115JB OF THE ACT. AS STATED EARLIER NEITHER THE A.O DISCUSSED IN THE ORDER WHILE MAKING ADJUSTMENT NOR TH E CIT(A) CONSIDERED THE SUBMISSIONS OF THE ASSESSEE IN DETAIL. WHILE REJECTING THE GROUND, THE CIT(A) GAVE VERY BRIEF REAS ON, WHICH IS NOT AS PER THE PROVISIONS. WE ARE OF THE OPINION THAT THE ACTION OF THE A.O. AND CIT(A), ARE NOT CORRECT AS THE PROVISIONS OF SECTION 115JB OF THE ACT DO NOT ALLOW SUCH AN ADJUSTMENT. THE HONBLE HIGH COURT OF MADRAS IN THE CASE OF TAMIL NADU CEMENTS CORPORATION LTD., VS JCIT CHENNAI, 23 TAXMAN.COM, 14 5 (MADRAS), HAS CONSIDERED SIMILAR ISSUE AND DECIDED THAT AN ASSESSEE IS ELIGIBLE TO ADJUST PRIOR PERIOD EXPENSES WHILE COMPUTING BOOK PROFIT U/S 115JA, IRRESPECTIVE OF AS TO WHETHER SUCH PRIOR PERIOD EXPENSES ARE SHOWN SEPARATELY OR NOT. IN THE SAID CASE, THE HONBLE MADRAS HIGH COURT HAS HELD AS UNDER: THE SUPREME COURT HAS IN THE DECISION OF APOLLO TY RES LTD. V. CIT, [2002J 2551TR 273/122 TAXMAN 962 POINTED OUT T HAT SUB-SECTION (1A) OF SECTION 115J DOES NOT EMPOWER T HE ASSESSING OFFICER TO EMBARK UPON A FRESH INQUIRY WI TH REGARD TO THE ENTRIES MADE IN THE BOOKS OF ACCOUNT OF THE COMPANY. THE SAID SUB-SECTION MANDATES THE COMPANY TO MAINTA IN ITS ACCOUNT IN ACCORDANCE WITH THE REQUIREMENTS OF THE COMPANIES ACT FOR THE LIMITED PURPOSE TO FIND OUT WHETHER THE COMPUTATION IS DONE IN ACCORDANCE WITH THE PROVISIONS OF THE CO MPANIES ACT. THE ASSESSING AUTHORITY HAS A LIMITED JURISDIC TION TO 4 1299 & 1385/HYD/2016 M/S. SURYA LAKSHMI COTTON MILLS LTD. SATISFY HIMSELF THAT THE ACCOUNTS ARE MAINTAINED IN ACCORDANCE WITH THE PROVISIONS OF THE COMPANIES ACT. BEYOND TH AT, THE ASSESSING AUTHORITY HAS NO JURISDICTION TO GO FURTH ER INTO ACCOUNTS. [PARA 9] THE DELHI HIGH COURT IN THE CASE OF CIT V. KHAITAN CHEMICALS AND FERTILIZERS LTD. [2008] 307 ITR 150/ 175 TAXMAN 195 WHILE DEALING WITH FACTS SIMILAR TO INSTANT CASE HA D POINTED TO THE ACCOUNTING STANDARD(AS-5) AND STATED THAT ACCOU NTING STANDARDS CLEARLY STIPULATES THAT PRIOR PERIOD ITEM S ARE INCOME OR EXPENSES WHICH ARISE 'IN THE CURRENT PERIOD' AS A RESULT OF ERRORS OR OMISSIONS IN THE PREPARATION OF THE FINAN CIAL STATEMENT OF ONE OR MORE PRIOR PERIODS. REFERRING T O PARAGRAPH 7 OF AS-5, THE DELHI HIGH COURT POINTED OUT THAT TH E NET PROFIT OR LOSS COMPRISE OF EXTRAORDINARY ITEMS AND THE SAME S HOULD BE DISCLOSED ON THE FACE OF THE STATEMENT OF PROFIT AN D LOSS. [PARA 12] PRIOR PERIOD ITEMS ARE ALSO ENUMERATED IN PARAGRAPH S 15 AND 19 OF ACCOUNTING STANDARD. DEALING WITH THE ACCOUNT ING STANDARD-5, THE DELHI HIGH COURT POINTED OUT THAT I NCOME OR EXPENSES RELATING TO PRIOR PERIOD ITEMS, MERIT TO B E INCLUDED IN THE DETERMINATION OF NET PROFIT OR LOSS. IT REASONE D OUT THAT BOTH THE PRIOR PERIOD ITEMS AND EXTRAORDINARY ITEMS ARE TO BE INCLUDED IN THE DETERMINATION OF THE NET PROFIT OR LOSS AND AS PER PARAGRAPH 15 OF THE AS-5, THAT PRIOR PERIOD ITE MS SHOULD BE SEPARATELY DISCLOSED IN THE STATEMENT OF PROFIT AND LOSS. [PARA 13 ] THUS, THE DELHI HIGH COURT HELD THAT WHETHER THE PR IOR PERIOD EXPENSES WERE SHOWN SEPARATELY OR NOT, THE ASSESSEE WOULD NEVERTHELESS BE ENTITLED TO HAVE THE ADJUSTMENT OF THE PRIOR PERIOD EXPENSES IN THE MATTER OF COMPUTING THE NET PROFIT OF THE ASSESSEE. THUS ON MERE FACT THAT THE ASSESSEE HAD S HOWN ITS PRIOR PERIOD EXPENSES IN THE EXTRAORDINARY ITEMS SE PARATELY, DID NOT MEAN THE NET PROFIT WAS ARRIVED AT DE HORS THESE ITEMS. THE DELHI HIGH COURT FURTHER POINTED OUT THAT THE A SSESSEE HAD NOT CLAIMED ANY DEDUCTION WITH THE NET PROFIT ON TH E BASIS OF ANY CLAUSES GIVEN IN THE EXPLANATION TO SECTION 115 JA(2). CONSEQUENTLY THE QUESTION WAS ANSWERED IN FAVOUR OF THE ASSESSEE. THE VIEW EXPRESSED BY THE DELHI HIGH COUR T IS AGREED WITH AND IS APPLIED TO THE INSTANT CASE. [PA RA 14] THUS GOING BY THE DECISION OF THE SUPREME COURT IN APOLLO TYRES LTD.'S CASE(SUPRA) AND APPLYING THE FACTS THU S FOUND THAT 5 1299 & 1385/HYD/2016 M/S. SURYA LAKSHMI COTTON MILLS LTD. IN COMPUTING THE NET PROFIT THE ASSESSEE HAD ADJUST ED PRIOR PERIOD EXPENSES, RIGHTLY, THE ASSESSEE OFFERED THE BOOK PROFIT FOR ASSESSMENT. NO EXCEPTION COULD BE TAKEN TO THE COURSE ADOPTED BY THE ASSESSEE IN ADJUSTING THE PRIOR PERI OD EXPENSES IN COMPUTING THE NET PROFIT. IN THE LIGHT OF THE LA W DECLARED BY THE SUPREME COURT AS TO THE JURISDICTION OF THE ASS ESSING OFFICER IN RESPECT OF THE MATTER OF MAT ASSESSMENT, IT IS TO BE HELD THAT ONCE THE OFFICER ACCEPTS THE BOOK PROFIT, HE CANNOT TRAVEL BEYOND WHAT HAD BEEN DISCLOSED IN THE BOOK P ROFIT. IN THE MATTER OF GRANTING ADJUSTMENT TO THE PRIOR PERI OD EXPENSES, APPLYING THE DECISION OF THE DELHI HIGH COURT IN TH E KHAITAN CHEMICAL & FERTILIZERS LTD.'S CASE (SUPRA), THE ORD ER OF THE TRIBUNAL IS TO BE SET ASIDE AND THE APPEAL IS TO BE ALLOWED. THE SUBSTANTIAL QUESTION OF LAW IS DECIDED INFAVOUR OF THE ASSESSEE. [PARA 16] 4.1 AS THE PROVISIONS OF SECTION 115JA ARE PARIPASSU WITH THE PROVISIONS OF SECTION 115JB, RESPECTFULLY FOLLOWING THE PRINCIPLES LAID DOWN BY THE HONBLE SUPREME COURT IN THE CASE OF APOLLO TYRES LTD. VS CIT), BY THE MADRAS HIGH COURT IN THE CAS E OF TAMIL NADU CEMENTS CORPORATION LTD., VS JCIT CHENNAI, (SUPRA ), WE HAVE NO HESITATION IN DELETING ADJUSTMENT SO MADE BY THE A.O. THE GROUND OF THE ASSESSEE IS ACCORDINGLY ALLOWED. 5. IN THE RESULT APPEAL OF THE ASSESSEE IS ALLOWED. ITA NO. 1385/HYD/2015 6. THIS IS A REVENUE APPEAL AGAINST THE INTEREST SUBSI DY OF RS.9,47,65,511/-, ADDED BY THE A.O. BUT DELETED BY THE LD. CIT(A). THE GROUNDS RAISED BY THE REVENUE ARE AS UNDER: 1. THE ORDER OF THE ASSESSING OFFICER IS ERRONEOUS AND CONTRARY TO LAW AND FACTS OF THE CASE. 2. A) THE ASSESSING OFFICER IS NOT JUSTIFIED IN CON SIDERING (9,47,65,511 (INTEREST SUBSIDY OF CURRENT YEAR AND EARLIER YEAR) AS INCOME OF THE APPELLANT FOR THE A Y 2008-09 IGNORIN G THE SUBMISSIONS OF THE APPELLANT. 6 1299 & 1385/HYD/2016 M/S. SURYA LAKSHMI COTTON MILLS LTD. B) THE ASSESSING OFFICER OUGHT TO HAVE SEEN THAT TH E INTEREST SUBSIDY OF (9,47,65,511 WAS REDUCED FROM THE INTERE ST EXPENDITURE EITHER IN THE EARLIER ASSESSMENT YEAR OR IN THE AY 2008-09 AS EXPLAINED IN THE STATEMENT OF FACTS AND HENCE THERE IS NO JUSTIFICATION IN MAKING ADDITION TOWARDS INTEREST S UBSIDY WHILE COMPUTING THE INCOME FOR THE AY 2008-09. 3. A) THE ASSESSING OFFICER GROSSLY ERRED IN DETERM INING THE BOOK PROFITS U/S 115JB AT N,46,50,347 BY ADDING BACK PRI OR PERIOD EXPENSES OF (27,03,302 DEBITED TO PROFIT AND LOSS A CCOUNT. THE ASSESSING OFFICER FAILED TO SEE THAT THE NET PROFIT AS PER PROFIT AND LOSS ACCOUNT FOR THE PURPOSE OF COMPUTING BOOK PROF ITS IS (1,20,49,145 BUT NOT (1,47,52,447 I. E. BEFORE CONS IDERING THE PRIOR PERIOD EXPENSES DEBITED TO PROFIT AND LOSS ACCOUNT. B) THE ASSESSING OFFICER OUGHT TO HAVE SEEN THAT IN VIEW OF THE DECISION OF THE HON'BLE SUPREME COURT IN THE CASE O F APOLLO TYRES LTD V. CIT 255 ITR 273 NO OTHER ADJUSTMENTS CAN BE MADE TO THE PROFIT AS PER PROFIT AND LOSS ACCOUNT OTHER THAN TH OSE SPECIFIED IN EXPLANATION TO SEC.115JB AND THEREFORE NOT CONSIDER ING PRIOR PERIOD ADJUSTMENTS FOR DEDUCTION FOR DEDUCTION FROM THE PR OFIT AS PER PROFIT AND LOSS ACCOUNT TO ARRIVE AT BOOK PROFIT IS NOT CO RRECT. 4. FOR ALL OF THE ABOVE AND SUCH OTHER GROUNDS TH AT MAY BE RAISED AT THE TIME OF HEARING. 7. BRIEFLY STATED, WHILE COMPLETING THE ASSESSMENT, THE A.O. HAS NOTICED THAT ASSESSEE HAS ACCRUED INTEREST AS ON 01- 04-2007, TO AN EXTENT OF RS. 6,53,83,545/-, OUT OF WHICH ASSESS EE RECEIVED OF R.S 4,46,09,949/- DURING THE ASSESSMENT YEAR 2008- 09, LEAVING THE BALANCE TO BE BROUGHT TO TAX OF RS. 2,07,73,596/-. IT IS FURTHER, OBSERVED THAT THE INTEREST ACCRUED DURING THE F .Y. WAS 7,39,91,915/-, WHICH WAS NOT OFFERED TO TAX. THUS HE MADE AN ADDITION OF RS. 9,47,65,519/-. 8. BEFORE THE LD. CIT(A), ASSESSEE MADE DETAILED SUBM ISSIONS ON FACTS. LD CIT(A) HAS CONSIDERED THE SAME IN DETAIL AND DELETED THE ADDITION BY STATING AS UNDER: 5.2 DURING THE COURSE OF APPEAL PROCEEDINGS, THE A PPELLANT SUBMITTED THAT AN AMOUNT OF ~ 65,383,545 WAS ALREAD Y BROUGHT TO TAX IN AY 2007-08 AS UNDER: 7 1299 & 1385/HYD/2016 M/S. SURYA LAKSHMI COTTON MILLS LTD. A. INTEREST SUBSIDY RECEIVABLE UPTO 31.03.2006 12,535,378 B. INTEREST SUBSIDY ACCRUED AND OFFERED AS INCOME IN AY 2007-08 75,164,325 C. INTEREST SUBSIDY RECEIVED DURING FY 2006-07 22,316,158 D. INTEREST SUBSIDY RECEIVED UPTO 31.03.2007 65,383,545 A+(B-C) FOR FY 2006-07 (AY 2007-08) THE FINANCE CH ARGES DEBITED TO P&L ETC WERE RS. 66,931,462 THE DETAILS OF WHICH ARE AS UNDER: INTEREST PAYABLE TO BANKS AND INSTITUTIONS 171,570,392 LESS: INTEREST SUBSIDY OFFERED TO TAX IN AY 2007-08 75,164,325 NET FINANCE CHARGES 96,406,067 LESS: INTEREST TRANSFERRED TO CAPITAL ALE 29,474 ,605 NET FINANCE CHARGES DEBITED TO P&L ALE 66,931,462 AS EVIDENT FOR ANNUAL REPORT OF ASSESSEE FOR FY 200 6-07 AND 2007- 08 THE FINANCE CHARGES DEBITED UNDER THE HEAD INTER EST ON TERM LOAN WAS RS. 66,931,462. THEREFORE IT IS EVIDENT TH AT THE INTEREST SUBSIDY OF RS. 65,383,545 WAS ALREADY OFFERED TO T AX IN AY 2007- 08 ITSELF. 5.3 SIMILARLY FOR AY 2008-09 THE INTEREST ACCRUED O F RS. 73,991,915 WERE ALREADY CONSIDERED BY THE ASSESSEE AS UNDER: INTEREST PAYABLE TO FINANCE INSTITUTIONS 156,806, 186 LESS: INTEREST SUBSIDY RECEIVED DURING YEAR 73,9 91,915 NET INTEREST DEBITED TO P&L ALE 82,814,272 THE FIGURES MENTIONED ABOVE, MATCHES WITH THE FIGUR ES MENTIONED IN ANNUAL REPORT OF THE ASSESSEE FOR FY 2006-07 AND 2007-08. THEREFORE THE ASSESSING OFFICER BROUGHT THE AMOUNTS TO TAX WITHOUT CALLING FOR I VERIFYING THE DETAILS WHETHER THE INT EREST SUBSIDY WAS OFFERED TO TAX OR NOT. THEREFORE THE ADDITION MADE BY THE ASSESSING OFFICER IS DELETED. 9. REVENUE IS CONTESTING THAT LD. CIT(A) ADMITTED THE ADDITIONAL EVIDENCE. AS SEEN FROM THE ORDER OF THE CI T(A), THERE IS 8 1299 & 1385/HYD/2016 M/S. SURYA LAKSHMI COTTON MILLS LTD. NO ADDITIONAL EVIDENCE FILED BY THE ASSESSEE AT ALL. IN FACT, ALL THOSE COMPUTATIONS MADE BY THE ASSESSEE IS FROM THE BAL ANCE SHEET OF THE ASSESSEE ITSELF. IN FACT LD. COUNSEL HAS POINTED OUT THAT THESE DETAILS WERE COMPLETELY AVAILABLE IN THE STATE MENT OF SUBSIDY FOR EACH ASSESSMENT YEAR PLACED BEFORE THE AU THORITIES BUT A.O HAS NOT EXAMINED/CONSIDERED THE SAME IN CORRE CT PERSPECTIVE. ON EXAMINATION OF THE DOCUMENTS PLACED IN THE SCHEDULES OF THE BALANCE SHEET IN THE PAPER BOOK PLACE D BY THE ASSESSEE, WE ARE OF THE OPINION THAT NO ADDITIONAL EVI DENCE HAS BEEN FILED BEFORE THE LD. CIT(A), THEREFORE, THE GROU NDS RAISED BY THE REVENUE DOES NOT HAVE ANY MERIT. EVEN OTHERWISE A LSO, THERE IS NO NEED TO MAKE ANY ADDITION AS THE ASSESSEE IS CO RRECTLY ACCOUNTING THE INTEREST ACCRUED IN RESPECTIVE ASSESSMEN T YEARS. ASSESSEE BEING A PUBLIC LIMITED COMPANY FILED ITS DETA ILS BY WAY OF SCHEDULES TO THE ACCOUNTS. IN VIEW OF THAT, WE WOULD NO T FIND ANY MERIT IN THE REVENUE CONTENTIONS, ACCORDINGLY THE GROUND S RAISED BY REVENUE ARE DISMISSED. 10. IN THE RESULT, REVENUE APPEAL IS DISMISSED. 11. TO SUM UP, ASSESSEES APPEAL IS ALLOWED AND THE REVENUE APPEAL IS DISMISSED. PRONOUNCED IN THE OPEN COURT ON 21 ST DECEMBER 2016. SD/- SD/- (P. MADHAVI DEVI) (B. RAMAKOTAIA H) JUDICIAL MEMBER ACCOUNTANT MEMBER HYDERABAD, DATED: 21 ST DECEMBER, 2016 KRK 9 1299 & 1385/HYD/2016 M/S. SURYA LAKSHMI COTTON MILLS LTD. COPY TO:- 1 M/S SURYALAKSHMI COTTON MILLS LTD. 105, 6 TH FLOOR, SURYA TOWERS S.P. ROAD, SECUNDERABAD 500 003. 2) DCIT, CIRCLE 3(2) HYDERABAD. 3) CIT(A)-3, HYDERABAD. 4 PR. CIT-3, HYDERABAD. 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDERAB AD. 6) GUARD FILE S.NO. DESCRIPTION DATE INTLS DS1. DRAFT DICTATED ON 15-12-16 PS 2. DRAFT PLACED BEFORE AUTHOR 19-12-16 PS 3 DRAFT PROPOSED & PLACED BEFORE THE SECOND MEMBER 4 DRAFT DISCUSSED/APPROVED BY SECOND MEMBER 5 APPROVED DRAFT COMES TO THE SR.P.S./PS 6. KEPT FOR PRONOUNCEMENT ON 7. FILE SENT TO THE BENCH CLERK 8 DATE ON WHICH FILE GOES TO THE HEAD CLERK 9 DATE OF DISPATCH OF ORDER