K.CH.Subba Rao, Hyderabad V. Asst.CIT, Central Circle-3, Hyderabad

ITA 1658/HYD/2013

• Counselvise Citation: [2014] 120 COUNSELVISE.COM (IT) 7668 (ITAT-HYDERABAD)
• Duration Of Justice: 9 month(s) 14 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-09-2014
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2009-2010
• Appeal Filed On: 02-12-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: P SOMASEKHAR REDDY
• Assessee Lawyers: P MURALI MOHAN RAO
• Keywords: Unexplained cash credit; Business income; Search and seizure; Loose papers; Document seized; Documents seized

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B ', HYDERABAD BEFORE SHRI B.RAMAKOTAIAH, ACCOUNTANT MEMBER AND SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER ITA NO.1 657 /HYD/13 : ASSESSMENT YEAR 200 8 - 0 9 ITA NO.1658/HYD/13 : ASSESSMENT YEAR 2009 - 10 SHRI K.CH.SUBBA RAO, HYDERABAD ( PAN - AYFPS 9511 H) V/S. ASSTT. COMMISSIONER OF INCOME - TAX CENTRAL CIRCLE 3, HYDERABAD. (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI P.MURALI MOHAN RAO RESPONDENT BY : SHRI P.SOMA SEKHAR REDDY, DR DATE OF HEARING 16 .0 7 .2014 DATE OF PRONOUNCEMENT 16.09.2014 O R D E R PER SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER: THESE TWO APPEALS BY THE ASSESSEE ARE DIRECTED AGAINST SIMILAR BUT SEPARATE ORDERS OF THE COMMISSIONER OF INCOME - TAX(APPEALS) I, HYDERABAD BOTH DATED 3.10.2013 FOR THE ASSESSMENT YEARS 2008 - 09 AND 2009 - 10. SINCE COMMON ISSUES ARE INVOLVED, THESE APPEALS ARE BEING DISPOSED OF WITH THIS COMMON ORDER FOR THE SAKE OF CONVENIENCE. 2. SEARCH AND SEIZURE OPERATION UNDER S.132 OF THE INCOME - TAX ACT, 1961 WAS CONDUCTED IN THE CASE OF THE ASSESSEE ON 29.12.2008 AND ASSESSMENTS WERE COMPLETED UNDER S.143(3) READ WITH S.153A FOR THE ASSESSMENT YEAR 2008 - 09 AND UNDER S.143(3) FOR THE ASSESSMENT YEAR S 2009 - 10. THE ASSESSEE FILED RETURNS OF INCOME FOR THE ASSESSMENT YEARS 2008 - 09 AND 2009 - 10, ADMITTING THE TOTAL INCOMES OF RS.4,39,450 AND RS.5,01,980 RESPECTIVELY. IN THE ASSESSMENT COMPLETED FOR THE ASSESSMENT YEAR 2008 - 09, THE ASSESSING OFFICER ESTIMATED THE INCOME OF THE ASSESSEE FROM COAL BUSINESS AND MADE AN ADDITION OF RS.40,00,000 ON PROTECTIVE BASIS. HE ITA NO. 16 57 & 165828 /HYD/201 3 SHRI K.CH.SUBBA RAO, HYDERABAD 2 ALSO MADE AN ADDITION OF RS.1,04,73,034, ON ACCOUNT OF UNEXPLAINED CASH CREDITS. SIMILARLY, FOR THE ASSESSMENT YEAR 2009 - 10, INCOME FROM COAL BASIS WAS ESTIMATED AND ADDITION OF RS.66,22,467 WAS MADE ON PROTECTIVE BASIS, BESIDES THE ADDITION OF RS.2,80,00,000 MADE ON ACCOUNT OF UNEXPLAINED CASH CREDITS. 3. ACCORDING TO THE ASSESSING OFFICER, CERTAIN LOOSE SHEETS BELONGING TO THE FIRM, M/S. BALAJI TRANSPORT AGENCY WERE FOUND AND SEIZED DURING THE SEARCH PROCEEDINGS. ON EXAMINATION OF THE LOOSE SHEETS, THE ASSESSING OFFICER CONCLUDED THAT IT BELONGED TO THE F IRM IN RESPECT OF INCOME PERTAINING TO THE COAL BUSINESS AND ACCORDINGLY HE BROUGHT TO TAX ON SUBSTANTIVE IN THE HANDS OF THE FIRM, M/S. BALAJI TRANSPORT AGENCY AND PROTECTIVE BASIS IN THE HANDS OF THE ASSESSEE TOWARDS INCOME FROM COAL BUSINESS. THE ASSES SING OFFICER, BASED ON PART OF THE SAME MATERIAL SEIZED, MADE THE ADDITIONS TOWARDS UNEXPLAINED CASH CREDITS IN THE HANDS OF THE ASSESSEE - PARTNER. 4. AGGRIEVED BY THE ADDITIONS MADE BY THE ASSESSING OFFICER, APPEALS WERE PREFERRED BEFORE THE CIT(A). L EARNED CIT(A) DELETED THE ADDITION OF RS. 4 0 LAKHS FOR THE ASSESSMENT YEAR 2008 - 09 AND RS.66,22,000 FOR THE ASSESSMENT YEAR 2009 - 10 MADE TOWARDS INCOME FROM COAL BUSINESS, VIDE PARA 8 OF THE IMPUGNED ORDER FOR BOTH THE ASSESSMENT YEARS SINCE THE TRIBUNA L VIDE PARA 2.5 OF ITS ORDER IN ITA NOS.387 TO 389/HYD/2012 HAD CONFIRMED THE ADDITIONS MADE ON SUBSTANTIVE BASIS IN THE HANDS OF THE FIRM, BY OBSERVING AS FOLLOWS - .HOWEVER, KEEPING THE APPLICABILITY OF THE PROVISIONS OF SEC.132(4A) OF THE IT ACT, 196 1, SINCE INCOME IS TAXABLE IN THE HANDS OF THE FIRM, IN WHOSE CASE THE INCRIMINATING MATERIAL WAS FOUND, WHICH STOOD UNEXPLAINED. IN THE INSTANT CASE, THE INFORMATION FOUND IN THE POSSESSION OF THE ASSESSEE AS SUCH ONUS LIES ON IT. 5. HOWEVER, THE LE ARNED CIT(A) CONFIRMED THE ADDITIONS MADE TOWARDS UNEXPLAINED CASH CREDITS OF RS.1,04,73,034 FOR THE ASSESSMENT YEAR 2008 - 9 AND RS.2,80,00,000 FOR THE ASSESSMENT YEAR 2009 - 10. IT WAS ITA NO. 16 57 & 165828 /HYD/201 3 SHRI K.CH.SUBBA RAO, HYDERABAD 3 SUBMITTED BY THE LEARNED AUTHORISED REPRESENTATIVE FOR THE ASSESSEE BEFORE THE CIT(A) THAT CERTAIN LOOSE SHEETS BELONGING TO THE FIRM, M/S. BALAJI TRANSPORT AGENCY WERE FOUND AND SEIZED, WHEREIN CERTAIN NOTINGS OF THE CASH RECEIVED AND PAYMENTS WERE NOTED. THE AMOUNTS WERE ADOPTED BY THE REVENUE AUTHORITIES, F ROM UNSI GNED ROUGH NOTINGS CONTAINED IN SOME LOOSE PAPERS, SEIZED DURING THE SEARCH PROCEEDINGS . IT WAS SUBMITTED THAT THE LOOSE PAPERS CONTAINING THE SAID NOTINGS, BEAR NO SIGNATURES AND THEY HAV E NO EVIDENTIARY VALUE. IT WAS SUBMITTED THAT T HE DOCUMENTS FOUND DURING THE SEARCH ARE THUS DUMB DOCUMENTS, WHICH DO NOT CONVEY CLEARLY AS TO WHOM THE DOCUMENTS BELONG TO, AND ALSO AS TO WHO HAS AUTHORED THE SAME , AND WHAT IS THE SIGNIFICANCE OF THE NOTINGS THEREIN . THERE IS THUS NO CLARITY IN THE DOCUMENTS AND THE EVI DENTIARY VALUE IS ABSENT. IT WAS ALSO SUBMITTED THAT THE ASSESSING OFFICER HAD ERRED IN MAKING ADDITIONS TO THE INCOME OF THE ASSESSEE BY MERELY RELYING ON THE STATEMENTS RECORDED AT THE TIME OF SEARCH AND POST SEARCH PERIOD WITHOUT BRINGING ANY CORROBORA TIVE EVIDENCE ON RECORD. THE LEARNED AUTHORISED REPRESENTATIVE FOR THE ASSESSEE RELIED ON THE CIRCULAR OF THE CBDT BEING NO.286/2/2003 - IT(INV), WHICH CLEARLY STATED THAT IN CASES OF SEARCH AND SEIZURE CASES, ADDITIONS CANNOT BE MADE ON THE BASIS OF SWO RN STATEMENTS, WITHOUT HAVING ANY DOCUMENTARY EVIDENCES. THE ASSESSEE RELIED ON THE DECISION OF THE TRIBUNAL IN THE CASE OF ITO V/S. HALLMARK CONSTRUCTIONS (ITA NO.694/HYD/2009); AND ACIT V/S. GYAN KUMAR AGARWAL(IT(SS)A NO.3/HYD/2013). THE LEARNED AUTHORI SED REPRESENTATIVE FOR THE ASSESSEE ALSO BROUGHT TO THE NOTICE OF THE CIT(A) THAT THE ASSESSEE IS HAVING ONLY PARTNERSHIP INCOME AND INTEREST FROM THE FIRM AND THE ASSESSEE IS NOT HAVING ANY OTHER BUSINESS INCOME. THE ADDITIONS MADE ON THE BASIS OF LOOSE SHEETS A/KCSR/RES/04, 05 AND 06 ARE BUSINESS TRANSACTIONS AND THE TRIBUNAL HAS CONFIRMED THAT LOOSE SHEETS BELONG TO THE FIRM AND COAL BUSINESS HAS BEEN DONE BY THE FIRM. HENCE, IT WAS SUBMITTED THAT ONCE IT WAS ESTABLISHED THAT LOOSE SHEETS BELONGED TO T HE FIRM, ADDITIONS CANNOT BE MADE ON PEAK CASH CREDIT, WHICH IS THE CASH FLOW OF THE FIRM. IT WAS ALSO SUBMITTED THAT ADDITIONS IN THE CASE OF THE FIRM WERE SUSTAINED BY REJECTING THE BOOKS OF ACCOUNT AND ITA NO. 16 57 & 165828 /HYD/201 3 SHRI K.CH.SUBBA RAO, HYDERABAD 4 INCOME WAS ESTIMATED FOR THE YEARS UNDER CONSIDERAT ION. HENCE, THE ADDITIONS IN QUESTION NEED TO BE DELETED. THE CIT(A), HOWEVER, REJECTED THE CONTENTIONS OF THE ASSESSEE AND SUSTAINED THE ADDITIONS MADE FOR BOTH THE YEARS, BY THE ASSESSING OFFICER TOWARDS UNEXPLAINED CASH CREDITS. 6. AGGRIEVED, ASSESSEE IS IN SECOND APPEAL BEFORE US FOR BOTH THE YEARS. 7. THE LEARNED LEARNED AUTHORISED REPRESENTATIVE FOR THE ASSESSEE BESIDES REITERATING THE CONTENTIONS URGED BEFORE THE REVENUE AUTHORITIES SUBMITTED THAT TH E IMPUGNED ADDITIONS ARE UNJUSTIFIED AND SHOULD BE DELETED. IN THE ALTERNATIVE, THE LEARNED AUTHORISED REPRESENTATIVE FOR THE ASSESSEE ALSO SUBMITTED THAT THE ASSESSING OFFICER AND THE CIT(A) OUGHT TO HAVE ALLOWED TELESCOPING OF ADDITIONS MADE IN THE ASSE SSMENT YEARS 2008 - 09 OF RS.1,04,73,034 IN ASSESSMENT YEAR 2009 - 10. HE ALSO SUBMITTED IN THE ALTERNATIVE THAT THE ADDITIONS MADE IN THE HANDS OF THE ASSESSEE, SHOULD BE CONSIDERED FOR BEING TELESCOPED AGAINST THE ADDITIONS OFFERED/SUSTAINED IN THE ASSESS MENTS FOR THE YEARS UNDER APPEAL IN THE CASE OF THE FIRM. 8. THE LEARNED DEPARTMENTAL REPRESENTATIVE ON THE OTHER HAND, STRONGLY SUPPORTED THE ORDERS OF THE REVENUE AUTHORITIES AND SUBMITTED THAT THE ADDITIONS TOWARDS UNEXPLAINED CASH CREDITS HAVE BEEN CORRECTLY MADE AND THE SAME SHOULD BE SUSTAINED. 9. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS OF THE REVENUE AUTHORITIES AND OTHER MATERIAL AVAILABLE ON RECORD. IT WAS SUBMITTED BY THE LEARNED COUNSEL THAT DURING THE COURSE O F SEARCH PROCEEDINGS, CERTAIN LOOSE SHEETS BELONGING TO THE FIRM, M/S. BALAJI TRANSPORT AGENCY WERE FOUND AND SEIZED. THOSE LOOSE SHEETS CONTAINED CERTAIN NOTINGS WITH REGARD TO TAX RECEIPTS AND PAYMENTS. AS HELD BY THE CIT(A) AT PARA 11.2, THE ASSESSEE WAS IN A CONFUSED STATE OF MIND AND GAVE DIFFERENT STATEMENTS ON 28.1.2009, ITA NO. 16 57 & 165828 /HYD/201 3 SHRI K.CH.SUBBA RAO, HYDERABAD 5 5.2.2009, 23.2.2009 WITH REGARD TO THE QUERY RAISED WITH RESPECT TO THE AMOUNTS COLLECTED FROM VARIOUS PERSONS. FINALLY, THE ASSESSEE HAS MODIFIED THE ABOVE STATEMENTS VIDE ANSWER TO THE QUESTIONNAIRE ON 20.9.2010 STATING THAT ENTRIES APPEARING IN THE LOOSE SHEETS ARE ROUGH NOTINGS AND ARE DUMB MATERIAL AND THE STATEMENTS GIVEN AT THE TIME OF SEARCH AND POST SEARCH PERIOD WERE GIVEN IN A CONFUSED STATE OF MIND. THE ASSESSEE HAS ALSO FILED COPIES OF THE SEIZED DOCUMENTS IN QUESTION BEING A/KCSR/RES/01; AND A/KCSR/RES/03 AT PAGES 7 TO 40 AND 41 TO 53 RESPECTIVELY, OF THE PAPER - BOOK FILED BEFORE US. MOST OF THOSE PAGES ARE EITHER HAND - WRITTEN SCRIBBLINGS LISTING OUT CERTAIN NAMES W ITH CERTAIN FIGURES/AMOUNTS STATED THEREAGAINST; OR COMPUTERISED SHEETS LISTING OUT CERTAIN NAMES WITH COLUMN - WISE DATEWISE FIGURES UNDER VARIOUS HEADS STATED THEREAGAINST. THERE ARE BLANK PATCHES WITH IRREGULAR WORKINGS AND ROUGH NOTINGS ON SOME OF THE PAPERS, AND EXCEPTING FOR ONE OR TWO, NONE OF THESE PAGES CONTAIN THE SIGNATURE OF ANYONE. THESE LOOSE PAPERS, BESIDES LACKING ANY SIGNATURES, DO NOT REFLECT ANY CLARITY AS TO WHOM THEY BELONG TO AND WHO HAS AUTHORED THEM, MUCH LESS INDICATIVE OF THE TRAN SACTIONS INVOLVED OR THE PARTIES TO SUCH TRANSACTIONS. IN THE CIRCUMSTANCES OF THE CASE THEREFORE, THE ONLY INESCAPABLE CONCLUSION THAT CAN BE ARRIVED AT IS IS THAT THOSE LOOSE SHEETS ARE MERE DUMB DOCUMENTS, HAVING NO EVIDENTIARY VALUE, UNLESS CORROBORAT IVE EVIDENCE HAS BEEN BROUGHT ON RECORD. ADMITTEDLY, IN THIS CASE, NO CORROBORATIVE EVIDENCE HAS BEEN BROUGHT ON RECORD BY THE REVENUE AUTHORITIES, TO IDENTIFY AND LINK UP THE TRANSACTIONS RECORDED IN THOSE DOCUMENTS TO THE BUSINESS OF THE ASSESSEE, IN WHOSE HANDS IMPUGNED ADDITIONS HAVE BEEN MADE BY THE ASSESSING OFFICER. IN THE ABSENCE OF ANY CORROBORATIVE EVIDENCE BROUGHT ON RECORD BY THE REVENUE AUTHORITIES, BASED ON MERE DUMB DOCUMENTS, HAVING NO EVIDENTIARY VALUE, NO ADDITION COULD BE MADE. WE A RE SUPPORTED IN THIS BEHALF BY THE CONSISTENT VIEW TAKEN BY THE COORDINATE BENCHES OF THE TRIBUNAL IN SIMILAR CIRCUMSTANCES, FOLLOWING THE DECISION OF THIS TRIBUNAL IN THE CASE OF GYANKUMAR AGARWAL V/S. ASSTT. COMMISSIONER OF INCOME - TAX (146 TTJ 334). EV EN OTHERWISE, THE SAME DOCUMENTS WERE SEIZED AND RELIED UPON BY THE DEPARTMENT IN THE CASE OF M/S. ITA NO. 16 57 & 165828 /HYD/201 3 SHRI K.CH.SUBBA RAO, HYDERABAD 6 BALAJI TRANSPORT AGENCY. IT IS APT TO REFER AT THIS STAGE TO THE RELEVANT PORTION OF THE ARGUMENTS OF THE LEARNED DEPARTMENTAL REPRESENTATIVE BEFORE THIS TRI BUNAL IN THE CASE OF M/S. BALAJI TRANSPORT AGENCY, HYDERABAD, WHICH APPEARS IN PARA 4.2 OF THE ORDER OF THE TRIBUNAL DATED 2.8.2013 IN ITA NO.8999/HYD/2012 AND OTHERS IN THAT CASE, ON PAGE 28 THEREOF, AND READ AS FOLLOWS - 4.2 THE DR SUBMITTED THAT DURING THE COURSE OF SEARCH, THREE SCRIBBLING PADS WERE FOUND AND SEIZED AS ANNEXURE A/KCSR/RES/04 - 06. THESE SCRIBBLING PADS CONTAIN HAND WRITTEN DETAILS OF DAILY ACCOUNT OF CASH R ECEIVED AND CASH PAID. IN OTHER WORDS, THESE PADS ARE THE CASH BOOKS MAINTAI NED BY SRI. K.CH. SUBBA RAO FOR KEEPING TRACK OF THE CASH TRANSACTIONS. THE SCRIBBLING PAD SEIZED AND MARKED AS A/KCSR/RES/05 CONTAINS HAND WRITING OF SRI. K. SUBBA RAO, ASSISTANT OF THE MANAGING PARTNER, WHEREAS, THE OTHER TWO SCRIBBLING PADS CONTAIN THE HAND WRITING OF SRI. K. CH. SUBBA RAO. THESE SCRIBBLING PADS MAINLY SHOW CASH PAYMENTS MADE TO 'TRUCK PROCUREMENT AGENTS' FOR ARRANGING TRUCKS AND MAKING CASH ADVANCES TO THE TRUCK OWNERS IN VARIOUS PLACES FROM WHERE COAL ETC., IS TO BE LOADED. THERE ARE I NSTANCES WHEN THE TRUCK PROCUREMENT AGENTS RETURN THE CASH GIVEN TO THEM IN ADVANCE BY THE PARTNERS OF THE FIRM. THE ENTRIES IN THE SEIZED DOCUMENTS CLEARLY INDICATE THAT THE ASSESSEE IS POOLING IN CASH FROM ALL THE AVAILABLE SOURCES TO MAKE ADVANCE PAYME NTS TO THE TRUCK PROCUREMENT AGENTS, WHO IN TURN MAKE CASH PAYMENTS TO THE TRUCK DRIVERS. THESE ENTRIES FURTHER SUBSTANTIATE THE STATEMENT GIVEN BY SRI. K.CH. SUBBA RAO EXPLAINING THE MODUS OPERANDI OF THE ASSESSEE FIRM . THE TRIBUNAL HELD IN THAT CASE T HAT IN INCOME FROM COAL BUSINESS IS TO BE CONSIDERED IN THE HANDS OF M/S. BALAJI TRADING AGENCY O NLY. WE ALSO NOTE THAT THE RECEIPT AND PAYMENT DETAILS ARE CORRELATED TO THE SAID BUSINESS. HOWEVER, ASSESSING OFFICER TOOK THE CREDITS IN THE DOCUMENTS AS T HAT OF INDIVIDUAL. THIS STAND OF THE ASSESSING OFFICER CANNOT BE APPROVED. SINCE THE SEIZED DOCUMENTS ARE STATED TO BE THAT OF THE FIRM, M/S. BALAJI TRADING AGENCY, THE SAID ADDITIONS CANNOT BE MADE IN INDIVIDUAL HANDS. WE FIND THAT FROM THE SAME SET OF DOCUMENTS SEIZED DURING THE SEARCH AND SEIZURE OPERATIONS, IT WAS CONSIDERED BY THE ASSESSING OFFICER THAT AN AMOUNT OF RS.40,00,000 IS TO BE PROTECTIVELY ASSESSED IN THE HANDS OF THE ASSESSEE ALSO. HOWEVER, THE CIT(A) DELETED THE ADDITION OF RS.40 LAKHS M ADE BY THE ASSESSING OFFICER ON PROTECTIVE BASIS, IN ITA NO. 16 57 & 165828 /HYD/201 3 SHRI K.CH.SUBBA RAO, HYDERABAD 7 THE HANDS OF THE ASSESSEE WHEN THE ORDER OF ITAT HOLDING THAT ADDITION IS TO BE MADE ON SUBSTANTIVE BASIS IN THE HANDS OF THE FIRM, WAS PRODUCED BEFORE THE CIT(A). THE ASSESSING OFFICER HAS MADE BOTH TH E ADDITIONS, I.E RS.40 LAKHS AS INCOME FROM COAL BUSINESS AND ADDITION OF UNEXPLAINED CASH CREDITS OF RS.1,04,73,034. ON THE BASIS OF LOOSE SHEETS CONTAINING ROUGH NOTINGS. THE CIT(A) WHILE DELETING THE ADDITION OF RS.40 LAKHS HAS UPHELD THE ADDITION OF RS .1,04,73,034, WHICH IS NOT JUSTIFIED. IN THIS VIEW OF THE MATTER, WE SET ASIDE THE IMPUGNED ORDERS OF THE CIT(A), AND DELETE THE ADDITIONS OF RS.1,04,73,034 FOR THE ASSESSMENT YEAR 2008 - 09 AND RS.2,80,00,000 FOR THE ASSESSMENT YEAR 2009 - 10, ALLOWING TH E MAIN GROUNDS OF THE ASSESSEE IN THESE APPEAL S . HAVING ALLOWED THE MAIN GROUNDS OF THE ASSESSEE, AND DELETE D THE ENTIRE ADDITIONS MADE, WE ARE NOT INCLINED TO GO INTO THE MERITS OF THE ALTERNATIVE GROUNDS RAISED. 10. IN THE RESULT, BOTH THE APPEALS OF THE ASSESSEE ARE ALLOWED. O RDER PRONOUNCED IN THE COURT ON 16 TH SEPTEMBER, 2014 SD/ - SD/ - ( B.RAMAKOTAIAH ) (ASHA VIJAYARAGHAVAN) ACCOUNTANT MEMBER JUDICIAL MEMBER DT/ - 16 TH SEPTEMBER, 2014 COPY FORWARDED TO: 1. SHRI K.CH.SUBBA RAO, C/O. M/S. P.MURALI & CO., CHARTERED ACCOUNTANTS, 6 - 3 - 655/2/3, 1 ST FLOOR, SOMAJIGUDA, HYDERABAD 500 082 2 . ASST. COMMISSIONER OF INCOME - TAX CENTRAL CIRCLE 3, HYDERABAD 3. COMMISSIONER OF INCOME - TAX(APPEALS) I HYDERABAD 4. COMMISSIONE R OF INCOME - TAX, CENTRAL, HYDERABAD 5 DEPARTMENTAL REPRESENTATIVE, ITAT, HYDERABAD. B.V.S