Appeal details
Counselvise Citation
[2021] 108 COUNSELVISE.COM (IT) 2482 (ITAT-BANGALORE)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
3 year(s) 10 month(s) 16 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
28-06-2021
Appeal Filed By
Department
Order Result
Dismissed
Bench Allotted
B
Next Hearing Date
29-03-2021
Assessment Year
2009-2010
Appeal Filed On
11-08-2017
Judgement Text
ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH: BANGALORE BEFORE SHRI GEORGE GEORGE K., JUDICIAL MEMBER AND SHRI B.R. BASKARAN, ACCOUNTANT MEMBER ITA NO.1688/BANG/2017 ASSESSMENT YEAR : 2009-10 ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT. LTD. HOSUR ROAD KORAMANGALA BANGALORE PAN NO : AAACR7108R VS. DEPUTY COMMISSIONER OF INCOME-TAX LARGE TAX PAYERS UNIT BANGALORE APPELLANT RESPONDENT ITA NO.1659/BANG/2017 ASSESSMENT YEAR : 2009-10 ACIT LTU, CIRCLE-1 BANGALORE VS. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT. LTD. HOSUR ROAD KORAMANGALA BANGALORE APPELLANT RESPONDENT APPELLANT BY : SHRI PERCY PADIWALA, SR. COUNSEL RESPONDENT BY : MS. NEERA MALHOTRA, D.R. DATE OF HEARING : 29.03.2021 DATE OF PRONOUNCEMENT : 28.06.2021 ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE PAGE 2 OF 9 O R D E R PER B.R. BASKARAN, ACCOUNTANT MEMBER: THESE CROSS APPEALS ARE DIRECTED AGAINST ORDER DATE D 31.5.2017 PASSED BY LD. CIT(A)-14, BENGALURU AND THEY RELATE TO THE ASSESSMENT YEAR 2009-10. AT THE TIME OF HEARING, B OTH THE PARTIES SUBMITTED THAT THE TAX EFFECT INVOLVED IN THE APPEA L FILED BY THE REVENUE IS LESS THAN RS.50 LAKHS AND HENCE, THE SAM E IS NOT MAINTAINABLE IN VIEW OF THE CIRCULAR NO.17/2019 DAT ED 08-08-2019 ISSUED BY CBDT. ACCORDINGLY, WE DISMISS THE APPEA L OF THE REVENUE IN LIMINE. 2. WE SHALL NOW TAKE UP THE APPEAL FILED BY THE ASS ESSEE. THE GROUNDS OF APPEAL AND ADDITIONAL GROUND RAISED BY T HE ASSESSEE READ AS UNDER. 1. THAT THE ORDER OF THE LEARNED CIT(A) LTU IS BAD IN LAW TO THE EXTENT CHALLENGED HEREIN. 2. HAVING REGARD TO THE FACTS, THE LEARNED CIT(A) ERRE D AN HOLDING THAT THE APPELLANT'S BUSINESS IS NOT EXCLUSIVELY IN SOFTWARE DEVELOPMENT SERVICES. 3. HAVING REGARD TO THE FACTS, THE LEARNED CIT(A) ERRE D IN HOLDING THAT THE APPELLANT IS ALSO INVOLVED IN THE BUSINESS OF RENDERING OF TE CHNICAL SERVICES. 4. WITHOUT PREJUDICE TO THE ABOVE, THE LEARNED CIT(A) WHILE COMING TO THE CONCLUSION THAT THE APPELLANT IS ALSO INVOLVED IN RENDERING TE CHNICAL SERVICES HAS NOT SPECIFICALLY MENTIONED WHICH PART OF THE SERVICES W OULD CONSTITUTE TECHNICAL SERVICE UNDER THE AGREEMENT. 5. WITHOUT PREJUDICE THE ABOVE, BOTH THE LEARNED CIT(A ) AS WELL AS THE LEARNED AO HAVE ERRONEOUSLY STATED THAT THE APPELLANT HAS EXCL UDED FOREIGN CURRENCY EXPENSES FROM ITS EXPORT TURNOVER WHILE COMPUTING DEDUCTION UNDER SECTION 10A OF THE INCOME-TAX ACT, 1961 ['THE ACT']. 6. THAT THE LEARNED CIT(A) ERRED IN NOT ADJUDICATING T HE GROUND NO.4 RAISED BY THE APPELLANT THAT EXPENDITURE IN FOREIGN CURRENCY AND TELECOMMUNICATION CHARGES, WHEN REDUCED FROM EXPORT TURNOVER, OUGHT TO BE REDU CED FROM TOTAL TURNOVER AS WELL. ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE PAGE 3 OF 9 7. THAT THE LEARNED CIT(A) ERRED IN NOT DIRECT5ING THE AO TO GRANT DEDUCTION U/S 10A IN RESPECT OF EXPORT PROCEEDS REALIZED BEYOND 6 MON THS FROM END OF PREVIOUS YER AS CONTEMPLATED IN THE PROVISIONS OF SEC 155 (11A) OF THE ACT. 8. FOR THESE AND OTHER GROUNDS THAT MAY BE URGED AT TH E TIME OF HEARING, THE APPELLANT PRAYS FOR APPROPRIATE RELIEF. ADDITIONAL GROUND: 1. HAVING REGARD TO THE FACTS AND CIRCUMSTANCES, THE A PPELLANT PLEADS THE HONBLE BENCH TO DIRECT THE A.O. TO GRANT ADDITIONAL FOREIG N TAX CREDIT OF RS.1,54,40,330/-. THE GROUND NO.1 TO 8 RAISED BY THE ASSESSEE RELATE TO DEDUCTION ALLOWED U/S 10A OF THE ACT. THE ADDITIONAL GROUND RELATE TO GRANTING OF FOREIGN TAX CREDIT. 3. THE ASSESSEE IS ENGAGED IN BUSINESS OF DEVELOPME NT OF SOFTWARE, DEALING IN AUTOMOTIVE COMPONENTS, MECHANI CAL AND ELECTRONIC DESIGNS, TRANSLATIONS ETC. THE ASSESSME NT FOR THE YEAR UNDER CONSIDERATION WAS COMPLETED BY THE A.O. U/S 1 43(3) R.W.S. 144C OF THE ACT. 4. THE FIRST ISSUE RELATES TO THE DEDUCTION ALLOW ED U/S 10A OF THE ACT. THE ASSESSEE CLAIMED A DEDUCTION OF RS.233.05 CRORES U/S 10A OF THE ACT WHICH CONSISTED OF CLAIM OF RS.174.94 CR ORES IN RESPECT OF STP UNDERTAKING LOCATED AT BENGALURU AND RS.58.11 C RORES IN RESPECT OF UNDERTAKING LOCATED AT COIMBATORE. THE A.O. NOT ICED THAT THE ASSESSEE HAS EXCLUDED 3 ITEMS, VIZ., COMMUNICATION CHARGES, EXPENDITURE INCURRED IN FOREIGN CURRENCY AND UNREAL IZED EXPORT PROCEEDS FROM THE AMOUNT OF EXPORT TURNOVER, WHIL E COMPUTING DEDUCTION U/S 10A OF THE ACT. THE A.O. HELD THAT T HE SAME IS IN ACCORDANCE WITH THE PROVISIONS OF SECTION 10A OF TH E ACT. THE A.O. ALSO NOTICED THAT THE ASSESSEE HAS REDUCED COMMUNIC ATION CHARGES AND EXPENSES IN FOREIGN CURRENCY FROM THE AMOUNT OF TOTAL TURNOVER ALSO, WHILE COMPUTING DEDUCTION U/S 10A OF THE ACT. THE A.O. TOOK THE VIEW THAT THE SAME IS NOT PERMISSIBLE UNDER THE PROVISIONS OF ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE PAGE 4 OF 9 SECTION 10A OF THE ACT. IN THIS REGARD, HE ALSO TO OK SUPPORT OF THE DECISION RENDERED BY CHENNAI BENCH OF TRIBUNAL IN T HE CASE OF CALIFORNIA SOFTWARE COMPANY LTD. (118 TTJ 844). AC CORDINGLY, HE DID NOT ALLOW DEDUCTION OF COMMUNICATION CHARGES AND EX PENSES INCURRED IN FOREIGN CURRENCY FROM THE TOTAL TURNOV ER, WHILE COMPUTING DEDUCTION U/S 10A OF THE ACT. 5. THE A.O. ALSO NOTICED THAT THE SALE CONSIDERATIO N TO THE EXTENT OF RS.5,30,985/- HAS NOT BEEN RECEIVED IN RESPECT O F BENGALURU UNIT. THE ASSESSEE SUBMITTED THAT IT IS A HOLDER OF EXPOR T HOUSE CERTIFICATE AND IT HAS GOT TIME OF 360 DAYS FOR RECEIVING THE S ALE CONSIDERATION. THE A.O. TOOK THE VIEW THAT THE PROVISIONS OF SECTI ON 10A OF THE ACT PROVIDE FOR A PERIOD OF 6 MONTHS ONLY FOR RECEIVING THE SALE CONSIDERATION. ACCORDINGLY, HE HELD THAT THE UNREA LIZED SALE CONSIDERATION OF RS.5,30,985/- IS REQUIRED TO BE EX CLUDED FROM THE AMOUNT OF EXPORT TURNOVER, WHILE COMPUTING DEDUCT ION U/S 10A OF THE ACT. ACCORDINGLY, THE A.O. ALLOWED DEDUCTION O F RS183.70 CRORES ONLY U/S 10A OF THE ACT, AS AGAINST THE CLAIM OF RS .233.05 CRORES. 6. BEFORE LD. CIT(A), THE ASSESSEE CONTENDED THAT T HE DEFINITION OF EXPORT TURNOVER GIVEN IN SEC.10A OF THE ACT PROVI DES FOR REDUCTION OF FREIGHT, TELECOMMUNICATION CHARGES AND INSURANCE ATTRIBUTABLE TO DELIVERY OF ARTICLES OR THINGS OR COMPUTER SOFTWARE OUTSIDE INDIA. THE SAID DEFINITION PROVIDES FOR REDUCTION OF EXPENSES IF ANY, INCURRED IN FOREIGN EXCHANGE ONLY IN RESPECT OF PROCEEDS RECEIV ED ON PROVIDING TECHNICAL SERVICES OUTSIDE INDIA . THE ASSESSEE SUBMITTED THAT IT IS ENGAGED IN THE BUSINESS OF DEVELOPMENT OF SOFTWA RE ONLY AND IT DID NOT PROVIDE ANY TECHNICAL SERVICE OUTSIDE INDIA. ACCORDINGLY, IT OBJECTED TO EXCLUSION OF EXPENDITURE IN FOREIGN CUR RENCY FROM THE AMOUNT OF EXPORT TURNOVER. WE NOTICED THAT THE AO DID NOT ALLOW EXCLUSION OF EXPENSES FROM THE TOTAL TURNOVER, WHIL E COMPUTING ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE PAGE 5 OF 9 DEDUCTION U/S 10A, EVEN THOUGH THOSE EXPENSES WERE REDUCED FROM EXPORT TURNOVER. IN THIS REGARD, THE ASSESSEE P LACED ITS RELIANCE ON THE DECISION RENDERED BY HONBLE JURISDICTIONAL KAR NATAKA HIGH COURT IN ITS OWN CASE IN ITA NO.697 OF 2009 RELATING TO A SSESSMENT YEAR 2003-04, WHEREIN IT WAS HELD THAT THE AMOUNT REDUCE D FROM THE EXPORT TURNOVER SHOULD ALSO BE REDUCED FROM THE TOT AL TURNOVER. THE ASSESSEE ALSO PLACED RELIANCE ON THE DECISION RENDE RED BY HYDERABAD BENCH OF TRIBUNAL IN THE CASE OF M/S. PATNI TELECOM PVT. LTD. VS. ITO (2009) 308 ITR 414. 7. THE LD. CIT(A), UPON EXAMINATION OF THE SERVICE AGREEMENTS, TOOK THE VIEW THAT THE ASSESSEE IS NOT PROVIDING SO FTWARE DEVELOPMENT SERVICES ALONE, SINCE THE SERVICE AGREEMENT ALSO RE FERRED TO CERTAIN TECHNICAL SERVICES. ACCORDINGLY, HE TOOK THE VIE W THAT THE SERVICES PERFORMED BY THE ASSESSEE OTHER THAN ITS &ITES, WOU LD FALL WITHIN THE AMBIT OF TECHNICAL SERVICES. ACCORDINGLY, HE HELD THAT THE REDUCTION OF EXPENDITURE INCURRED IN FOREIGN CURREN CY RELATABLE TO TECHNICAL SERVICES IS MANDATED BY LAW. ACCORDINGLY , HE DIRECTED THE A.O. TO SEGREGATE RECEIPTS INTO SOFTWARE SERVICES AND TECHNICAL SERVICES AND RE-COMPUTE THE DEDUCTION ACCORDINGLY. THE ASSESSE IS AGGRIEVED BY THE DECISION RENDERED SO BY LD. CIT(A) . 8. THE LD. A.R. SUBMITTED THAT THE ASSESSEE IS PROV IDING ONLY SOFTWARE DEVELOPMENT SERVICES AND IT DOES NOT PRO VIDE ANY TECHNICAL SERVICES AS OBSERVED BY LD. CIT(A). THE LD. A.R. S UBMITTED THAT AN IDENTICAL ISSUE WAS EXAMINED BY THE COORDINATE BENC H IN THE ASSESSEES OWN CASE IN ITA NO.412/BANG/2007 DATED 2 2.1.2014 RELATING TO ASSESSMENT YEAR 2007-08 AND THE MATTER HAS BEEN RESTORED TO THE FILE OF LD. CIT(A) FOR EXAMINING TH IS ISSUE AFRESH. IN ASSESSMENT YEAR 2004-05 ALSO, THE MATTER WAS RESTOR ED TO THE FILE OF LD. CIT(A) WITH A DIRECTION TO FOLLOW THE DECISION RENDERED BY ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE PAGE 6 OF 9 JURISDICTIONAL HIGH COURT IN THE CASE OF INFOSYS LT D. (ITA NO.2972, 2973, 2974 & 3015/2015 DATED 13.2.2013), WHEREIN IT WAS HELD THAT THE EXPENDITURE IN FOREIGN CURRENCY NEED NOT BE EXC LUDED FROM EXPORT PROCEEDS REALISED ON EXPORT OF COMPUTER SOFTWARE. THE LD. A.R. FURTHER SUBMITTED THAT THE AMOUNT DEDUCTED FROM EXP ORT TURNOVER IS ALSO REQUIRED TO BE DEDUCTED FROM THE TOTAL TURNOVE R, WHILE COMPUTING DEDUCTION U/S 10A OF THE ACT AS PER THE DECISIONS R ENDERED BY HONBLE KARNATAKA HIGH COURT AS WELL AS HONBLE SUP REME COURT. 9. THE LD. D.R., ON THE CONTRARY, SUPPORTED THE ORD ER PASSED BY LD. CIT(A). 10. WE HEARD THE PARTIES ON THIS ISSUE AND PERUSED THE RECORD. WE NOTICE THAT THE ISSUE WHETHER THE EXPENDITURE INCUR RED IN FOREIGN CURRENCY IS REQUIRED TO BE EXCLUDED FROM THE EXPORT TURNOVER OR NOT WHEN THE ASSESSEE IS EXPORTING ONLY SOFTWARE, WAS E XAMINED BY THE COORDINATE BENCH IN THE ASSESSEES OWN CASE IN ASSE SSMENT YEAR 2007-08 AND THE MATTER WAS RESTORED TO THE FILE OF THE LD. CIT(A) WITH THE FOLLOWING OBSERVATIONS: 16. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS. IT I S CLEAR FROM THE DECISION OF THE HYDERABAD BENCH OF THE ITAT THAT TO EXCLUDE EXPENSES INCURRED IN FOREIGN CURRENCY FROM THE EXPORT TURNOV ER, THE ASSESSEE SHOULD HAVE OBTAINED THE BENEFIT OF SECTION 10A ON INCOME FROM RENDERING TECHNICAL SERVICES OUTSIDE INDIA. THE ADMITTED FACT UAL POSITION IN THE PRESENT CASE IS THAT THE ASSESSEE IS IN THE BUSINES S OF EXPORTING COMPUTER SOFTWARE AND THEREFORE THE EXPENSES INCURR ED IN FOREIGN EXCHANGE CANNOT BE SAID TO BE ONE INCURRED BY THE A SSESSEE IN CONNECTION WITH PROVIDING TECHNICAL SERVICES OUTSIDE INDIA. TH E ASSESSEE DOES NOT CLAIM EXCLUSION OF TELECOMMUNICATION CHARGES OR INS URANCE ATTRIBUTABLE TO THE DELIVERY OF SOFTWARE OUTSIDE INDIA. THE CLAI M FOR EXCLUSION FROM THE ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE PAGE 7 OF 9 EXPORT TURNOVER IS MADE BY THE ASSESSEE ONLY IN RES PECT OF EXPENSES INCURRED IN FOREIGN CURRENCY IN PROVIDING TECHNICAL SERVICES OUTSIDE INDIA. WE HOWEVER DO NOT HAVE THE BREAK-UP OF THE ITEM OF EXPENDITURE INCURRED IN FOREIGN CURRENCY OUTSIDE INDIA. A COPY OF THE AG REEMENT BETWEEN THE ASSESSEE AND ROBERT BOSCH, GERMANY TITLED SOFTWARE PROJECT AGREEMENT (SPA) HAS BEEN FILED BEFORE US. WE DO NOT KNOW AS T O WHETHER THE ENTIRE EXPORT TURNOVER IS IN RELATION TO THIS CLIENT ALONE OR THERE WERE OTHER CLIENTS FOR WHOM THE ASSESSEE RENDERED COMPUTER SOF TWARE DEVELOPMENT SERVICES. A PERUSAL OF THE SPA FILED BEFORE US SHOW S THAT THE ASSESSEE AGREED TO CARRY OUT SOFTWARE DEVELOPMENT WORK FOR R OBERT BOSCH GERMANY AT GERMANY ALSO. THE TERMS OF THE AGREEMENT FOR RENDERING SERVICES ON-SITE AT CLAUSES-5.2 TO 5.2.6 OF THE AGR EEMENT DOES NOT INVOLVE RENDERING OF ANY TECHNICAL SERVICES. THE QUESTION A S TO WHETHER THE ENTIRE EXPENDITURE INCURRED IN FOREIGN EXCHANGE OUTSIDE IN DIA RELATES TO PROVIDING TECHNICAL SERVICES OUTSIDE INDIA CANNOT B E DECIDED IN THE ABSENCE OF THE REQUIRED INFORMATION AS STATED ABOVE . IF THE CLAIM OF THE ASSESSEE THAT THE ENTIRE EXPENDITURE INCURRED IN FO REIGN EXCHANGE OUTSIDE INDIA DOES NOT RELATE TO PROVIDING TECHNICAL SERVIC ES OUTSIDE INDIA, THEN THE SAME CANNOT BE EXCLUDED FROM THE EXPORT TURNOVE R. SINCE THE FACTUAL VERIFICATION IS REQUIRED FOR ADJUDICATING THE AFORE SAID ISSUE, WE DEEM IT APPROPRIATE TO SET ASIDE THE ORDER OF THE CIT(A) AN D REMAND THE ISSUE TO HIM WITH A DIRECTION TO DECIDE THE ISSUE WITH REGAR D TO GR.NO.2 AND 3 RAISED BY THE ASSESSEE BEFORE HIM. WE ACCORDINGLY A LLOW THE APPEAL OF THE ASSESSEE FOR STATISTICAL PURPOSE. 11. IN ASSESSMENT YEAR 2004-05 ALSO, THE COORDINATE BENCH RESTORED THE ISSUE TO THE FILE OF THE LD. CIT(A) FO R EXAMINING THIS ISSUE IN THE LIGHT OF DECISION RENDERED BY HONBLE JURISD ICTIONAL HIGH COURT IN THE CASE OF INFOSYS LTD. (SUPRA). CONSISTENT WI TH THE VIEW TAKEN IN THE ABOVE SAID TWO YEARS IN THE ASSESSEES OWN CASE , WE SET ASIDE THE ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE PAGE 8 OF 9 ORDER PASSED BY LD. CIT(A) ON THIS ISSUE AND RESTOR E THE SAME TO HIS FILE FOR EXAMINING IT AFRESH ON SIMILAR LINES. 12. THE NEXT ISSUE IS WHETHER THE AMOUNT DEDUCTED F ROM EXPORT TURNOVER IS ALSO REQUIRED TO BE DEDUCTED FROM TOTAL TURNOVER OR NOT. SINCE THIS ISSUE IS RELATED TO COMPUTATION OF DEDUC TION U/S 10A, THIS ISSUE ALSO RESTORED TO THE FILE OF THE LD. CIT(A) W ITH THE DIRECTION TO FOLLOW THE DECISION RENDERED BY HONBLE KARNATAKA H IGH COURT IN THE CASE OF TATA ELIXI LTD., AND ALSO DECISION RENDERED BY HONBLE SUPREME COURT IN THE CASE OF HCL TECHNOLOGIES LTD. 13. THE NEXT ISSUE RELATES TO DEDUCTION OF UNREALIZ ED AMOUNT OF RS.5,30,985/- FROM THE EXPORT PROCEEDS, WHILE COMPU TING DEDUCTION U/S 10A OF THE ACT, ON THE GROUND THAT THE SAME HAS NOT BEEN REALISED WITHIN A PERIOD OF 6 MONTHS. IN THIS REGARD, THE L D. A.R. INVITED OUR ATTENTION TO MASTER CIRCULAR NO.9/2008-09 DATED 1 ST JULY, 2008 ISSUED BY RBI. THE LD. A.R. SUBMITTED THAT THE RBI HAS GRANTED GENERAL PERMISSION TO REALIZE THE EXPORT PROCEEDS WITHIN A PERIOD OF 12 MONTHS FROM THE DATE OF EXPORT ON OR AFTER 1 ST SEPTEMBER, 2004. WE NOTICE THAT THE LD. CIT(A) HAS NOT ADJUDICATED T HIS ASPECT. ACCORDINGLY, WE RESTORE THIS ISSUE ALSO TO HIS FILE FOR EXAMINING THE SAME AFRESH BY CONSIDERING THE CIRCULAR ISSUED BY R BI. 14. THE ADDITIONAL GROUND RAISED BY THE ASSESSEE RE LATE TO CLAIM OF FOREIGN TAX CREDIT OF RS.1.54 CRORES. SINCE THIS I S A LEGAL GROUND AND ALL FACTS ARE AVAILABLE ON RECORD, WE ADMIT THE SAM E. SINCE THIS ISSUE REQUIRES EXAMINATION AT THE END OF AO, WE RESTORE T HIS ISSUE TO THE FILE OF THE A.O. FOR EXAMINING THE CLAIM OF THE ASS ESSEE IN ACCORDANCE WITH LAW. ITA NO.473&474/BANG/2020 M/S. VALENCIA NUTRITION LIMITED, BANGALORE PAGE 9 OF 9 15. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS TREATED AS ALLOWED FOR STATISTICAL PURPOSES AND THE APPEAL OF THE REVENUE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 28 TH JUNE, 2021 SD/- (GEORGE GEORGE K. ) JUDICIAL MEMBER SD/- (B.R. BASKARAN) ACCOUNTANT MEMBER BANGALORE, DATED 28 TH JUNE, 2021. VG/SPS COPY TO: 1. THE APPLICANT 2. THE RESPONDENT 3. THE CIT 4. THE CIT(A) 5. THE DR, ITAT, BANGALORE. 6. GUARD FILE BY ORDER ASST. REGISTRAR, ITAT, BANGALORE.
