Vemula Laxminarayana, Hyderabad V. ACIT., .Cir-1, Warangal

ITA 1660/HYD/2013

• Counselvise Citation: 166022514 RSA 2013
• Duration Of Justice: 1 year(s) 7 month(s) 20 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 22-07-2015
• Appeal Filed By: Assessee
• Bench Allotted: B
• Next Hearing Date: 16-07-2015
• Assessment Year: 2010-2011
• Appeal Filed On: 02-12-2013
• Court: TRIBUNAL
• Department Lawyers: J SIRI KUMAR
• Assessee Lawyers: P MURALI MOHAN RAO
• Keywords: Depreciation; Assessment record
• Section: 143(3); 142(1); 133A; 263

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES B (SMC), HYDERABAD BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER I.T.A. NO. 1660/HYD/2013 ASSESSMENT YEAR: 2010-11 VEMULA LAXMINARAYANA , WARANGAL [PAN: ADIPV7622C] VS THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-I, WARANGAL (APPELLANT) (RESPONDENT) FOR ASSESSEE : SHRI P. MURALI MOHAN RAO , AR FOR REVENUE : S HRI J. SIRI KUMAR , CIT - DR DATE OF HEARING : 1 7 - 0 7 - 201 5 DATE OF PRONOUNCEMENT : 22 - 0 7 - 2015 O R D E R THIS APPEAL BY ASSESSEE IS AGAINST THE ORDER OF TH E COMMISSIONER OF INCOME TAX-VI, HYDERABAD DT. 30-10-2013 SETTING ASIDE THE ASSESSMENT ORDER U/S. 143(3) OF THE INCOME TAX ACT [ACT] COMPLETED ON 20-03-2013. 2. BRIEFLY STATED, ASSESSEE FILED RETURN OF INCOME FOR AY. 2010-11 ON 28-02-2011 ADMITTING TOTAL INCOME OF RS. 2,21,540/- . IN THE FINANCIAL YEAR RELEVANT FOR THE ASSESSMENT YEAR, A SURVEY OPE RATION U/S. 133A HAD BEEN CONDUCTED ON 22-12-2009 AND THE CASE WAS SELEC TED FOR SCRUTINY. IN THE SCRUTINY ASSESSMENT COMPLETED, ASSESSING OFF ICER (AO) DISALLOWED VARIOUS AMOUNTS THEREBY DETERMINED THE TOTAL INCOME AT RS.11,63,000/-. THIS ORDER OF AO IS SUBJECT MATTER OF APPEAL BEFORE THE LD. CIT. IN THE MEAN TIME, LD. CIT HAD AN OCCASION TO EXAMINE THE A SSESSMENT RECORDS. I.T.A. NO. 1660/HYD/2013 VEMULA LAXMINARAYANA :- 2 -: HE NOTICED THAT ASSESSEE HAS CLAIMED A TDS AMOUNT O F RS. 23,297/- AND THE CORRESPONDING INCOME OF RS. 2,32,964/- WAS NOT OFFERED TO TAX. HE ALSO NOTICED THAT ASSESSEE CLAIMED DEPRECIATION OF RS. 5,492/- AND THE PROOF OF USING THE ASSETS FOR THE PURPOSE OF BUSINE SS WAS NOT EXAMINED BY THE AO. HE ALSO NOTICED THAT, ASSESSEE HAS ADMI TTED PERSONAL EXPENDITURE TO THE TUNE OF RS. 2,40,000/- AND AO HA S NOT CONSIDERED THIS ISSUE WHILE COMPLETING THE ASSESSMENT. ON THE ABOVE GROUNDS, A NOTICE U/S. 263 DT. 25-09-2013 WAS ISSUED TO ASSESS EE TO SHOW CAUSE AS TO WHY THE ASSESSMENT SHOULD NOT BE REVISED OR SET ASIDE. 2.1 ASSESSEE SUBMITTED THAT TDS AMOUNT CLAIMED WAS ON THE INTEREST RECEIVED BY ASSESSEE IN THE BUSINESS OF BILL DISCOU NTING AND SUBMITTED THAT THE ENTIRE COMMISSION AS WELL AS INTEREST INCO ME WAS OFFERED TO TAX. IT WAS SUBMITTED THAT AN AMOUNT OF RS. 3,21,540/- W AS INCOME ADMITTED WHICH INCLUDED INTEREST RECEIVED. WITH REFERENCE T O DEPRECIATION CLAIMED, IT WAS SUBMITTED THAT ASSESSEE PURCHASED A SCOOTER WHICH WAS USED FOR THE PURPOSE OF BUSINESS. AS FAR AS PERSON AL DRAWINGS, IT WAS SUBMITTED THAT ASSESSEE HAD DEBITED AN AMOUNT OF RS . 3,08,760/- TOWARDS DRAWINGS. ON THE REASON THAT THESE ASPECTS HAVE NOT BEEN EXAMINED BY THE AO, LD. CIT SET ASIDE THE ASSESSMEN T BY STATING AS UNDER: '6. I HAVE PERUSED THE EXPLANATION OF THE ASSESSEE OBJECTING TO THE PROPOSED ISSUES EMANATING FROM THE SHOW CAUSE NOTICE U/S. 263 OF THE I T ACT. IT IS CLARIFIED BY THE AUTHORIZED REPRESENTATIVE THAT THE AMOUNT OF RS. 12,01,742/- DISCLOSED IN THE PRO FIT & LOSS ACCOUNT INCLUDING THE INTEREST INCOME OF RS. 2,81,210/-. THEREFORE, THERE IS NO CAUSE FOR REVISITING THE SAME ISSUE IN THE PRES ENT PROCEEDINGS INITIATED U/S. 263 OF THE INCOME TAX ACT. HOWEVER , ON PERUSAL OF THE ASSESSMENT RECORD, IT IS NOTICED THAT THE ASSESSEE NEVER DISCLOSED THE INTEREST INCOME OF RS. 2,81,210/- SEPARATELY E ITHER IN THE INCOME TAX RETURN OR IN THE PROFIT AND LOSS ACCOUNT FILED DURING THE COURSE OF SCRUTINY PROCEEDINGS. IN FACT, IN A SEPARATE N OTE ON INCOME, THE ASSESSEE HAS CLEARLY STATED THAT IN THE ACTIVITY O F CHEQUE I.T.A. NO. 1660/HYD/2013 VEMULA LAXMINARAYANA :- 3 -: DISCOUNTING RECEIVED COMMISSION OF RS. 12,01,742/- IN THE FINANCIAL YEAR 2009-10 AND THE SAME WAS SHOWN AS INCOME IN T HE PROFIT & LOSS ACCOUNT. IT SHOWS THAT THESE DETAILS HAVE NO T BEEN CALLED FOR IN ORDER TO EXAMINE BY THE AO AT THE TIME OF SCRUTINY PROCEEDINGS AND COMPLETED THE ASSESSMENT WITHOUT EXAMINING WHETHER THE ASSESSEE HAS DISCLOSED INTEREST INCOME OR NOT. 6.1 THE NEXT ISSUE IS IN RESPECT OF PERSONAL DRAW INGS. IN THE COURSE OF REVISION PROCEEDINGS, THE ASSESSEE HAS F ILED CAPITAL ACCOUNT FOR THE FINANCIAL YEAR 2009-10 SHOWING DRA WINGS OF RS. 3,08,760/-, HENCE IT IS SUFFICE TO THE PERSONAL DR AWINGS OF THE ASSESSEE. BUT, THE DETAILS ARE NOT MADE AVAILABLE TO THE AO NOR CALLED FOR BY THE AO AT THE TIME OF SCRUTINY PROCE EDINGS SO AS TO EXAMINE THE SAME IN PROPER PROSPECTIVE. 7. THEREFORE, WITHOUT APPLICATION OF MIND AND WIT HOUT CALLING FOR THE BASIS DETAILS, THE AO COMPLETED THE ASSESS MENT THEREBY THERE IS ERROR EREPT IN THE ASSESSMENT ORDER FRAME D BY THE AO WHICH IS PREJUDICIAL TO THE INTEREST OF THE REVENUE AND DESERVES TO BE SET ASIDE AND THE COMMISSIONER IS EMPOWERED TO REVISE SUCH ASSESSMENT BY INVOKING PROVISIONS OF SECTION 263. THERE ARE VARIOUS JUDICIAL DECISIONS IN SUPPORT OF SUCH PROP OSITION WHICH ARE AS UNDER: I. RAMPYARI DEVI SAROGI VS CIT (SC) 67 ITR 84 II. MALABAR INDUSTRIAL CO. LTD VS CIT (SC) 243 ITR 83 III. SWARUP VEGETABLE PRODUCTS INDUSTRIES LTD VS CIT(ALL ) 187 ITR 412 IV. GEE VEE ENTERPRISES VS ADDL. CIT & ORS (DEL) 99 ITR 375 V. RAJALAKSHMI MILLS LTD VS ITO (ITAT, SB-CHENNAI) 121 ITD 343, 313 ITR(AT) 182. VI. SRM SYSTEMS & SOFTWARE PVT. LTD. VS ACIT 2010-TIOL- 646- HC-MAD-IT. VII. DELOITTE HASKINS & SELLS, CHENNAI V. DCIT ITA NO. 1164/MDS/12 DTD. 4.7.2013. ACCORDINGLY, THE ASSESSMENT ORDER OF THE AO FOR T HE AY. 2010- 11 IS SET ASIDE WITH A DIRECTION TO REDO THE SAME AFTER EXAMINING THE DETAILS AS PER THE LAW, AFTER PROVIDING SUFFICIENT OPPORTUNITY TO THE ASSESSEE'. 3. LD. COUNSEL REFERRING TO THE PAPER BOOK PLACED O N RECORD AND THE REPLIES SUBMITTED TO CIT STATED THAT ASSESSEE HAS S HOWN GROSS I.T.A. NO. 1660/HYD/2013 VEMULA LAXMINARAYANA :- 4 -: COMMISSION INCOME OF RS. 12,01,742/- WHICH INCLUDED THE IMPUGNED INTEREST INCOME. IT WAS SUBMITTED THAT AS AGAINST THE ABOVE COMMISSION, ASSESSEE CLAIMED VARIOUS EXPENDITURE OF SALARIES AN D INTEREST PAID. AO IN THE SCRUTINY ASSESSMENT DISALLOWED THE SALARIES AND ALSO AN AMOUNT OF RS. 6,41,462/- U/S. 40(A)(IA). IT WAS FURTHER S UBMITTED THAT THE TDS CLAIM WAS MADE IN THE RETURN OF INCOME AND THE SAME IS ALSO FIGURING IN THE DEPARTMENTAL DATA BASE AND THE AO HAS GIVEN CRE DIT AS PER 26AS. HE ALSO REFERRED TO THE DETAILED SUBMISSIONS MADE B EFORE CIT, PARTICULARLY TO PAGE 20 OF THE PAPER BOOK, WHEREIN IT WAS SUBMITTED THAT ASSESSEE HAD COMMISSION AMOUNT OF RS. 9,20,532/- AN D THE INTEREST AMOUNT OF RS. 2,81,210/- TOTALING TO RS. 12,01,742/ -. IT WAS FURTHER SUBMITTED THAT AS AGAINST THIS AMOUNT, AFTER CLAIMI NG VARIOUS EXPENDITURES, THE NET PROFIT TRANSFERRED TO CAPITAL ACCOUNT WAS AT RS. 3,21,540/- WHICH WAS THE GROSS TOTAL INCOME OFFERED . ASSESSEE CLAIMED VARIOUS OTHER EXPENDITURES INCLUDING PF AND NSC. T HESE ASPECTS WERE EXAMINED BY THE AO AND REFERRED TO THE SHOW CAUSE N OTICE ISSUED BY THE AO IN THE COURSE OF SCRUTINY PROCEEDINGS ON 15-02-2 013. HE ALSO REFERRED TO THE ASSESSMENT ORDER WHEREIN AO HAS GIV EN A FINDING THAT AFTER EXAMINING THE MATERIAL FURNISHED, TOTAL INCOM E RETURNED BY ASSESSEE WAS COMPUTED. LD. COUNSEL FURTHER SUBMITT ED THAT CIT CANNOT DIRECT TO MAKE ROVING ENQUIRIES, AS CONSIDERED BY T HE ANDHRA PRADESH HIGH COURT IN THE CASE OF SPECTRA SHARES AND SCRIPS PVT. LTD., VS. CIT [354 ITR 35] (AP). 4. LD. CIT IN REPLY HOWEVER, SUBMITTED THAT ASSESSE E HAS NOT GIVEN ANY INFORMATION ABOUT THE RECEIPTS AND AO ALSO HAS NOT EXAMINED WHETHER THE AMOUNT WAS INCLUDED IN THE ABOVE, WHILE GIVING CREDIT TO THE TAX. IN VIEW OF THIS, HE SUPPORTED THE ORDERS OF C IT INVOKING JURISDICTION. I.T.A. NO. 1660/HYD/2013 VEMULA LAXMINARAYANA :- 5 -: 5. I HAVE CONSIDERED THE ISSUE AND EXAMINED THE REC ORD. AS SEEN FROM THE ORDER OF CIT, IT IS VERY MUCH EVIDENT THAT THE ISSUES WHICH WERE TAKEN UP BY THE CIT ARE SO TRIVIAL NO SEPARATE FIND INGS ARE REQUIRED TO BE GIVEN IN THE ASSESSMENT ORDER, IF SCRUTINY WAS COMP LETED BY THE AO. IN FACT IN THIS CASE, THERE WAS SURVEY DURING THE COUR SE OF ACCOUNTING YEAR ITSELF AND ALSO ON THE BASIS OF THE SURVEY, THE CAS E WAS SELECTED FOR SCRUTINY. THE TDS MADE ON BEHALF OF ASSESSEE WAS I TSELF REFLECTED IN 26AS OF THE DEPARTMENT AND THE SAME AMOUNT WAS GIVE N CREDIT. IN VIEW OF THIS, THE LD. CITS PRESUMPTION THAT THIS AMOUNT OF INCOME COVERED BY TDS WAS NOT OFFERED TO TAX AND ASSESSEES CONCEALED INCOME CANNOT BE ACCEPTED. WITH REFERENCE TO THE DEPRECIATION CLAIM ED OF RS. 5,698/- IT WAS THE CONTENTION THAT ASSESSEE PURCHASED A SCOOTE R AND THE SAME WAS BEING USED IN THE BUSINESS. IN THE EVENT THE ASSET IS NOT FIGURING IN ASSESSEES BALANCE SHEET OR ACCOUNTS SCHEDULES, ON E CAN DOUBT THE CLAIM OF DEPRECIATION. ASSESSEE IS DOING SMALL BUSI NESS OF BILL DISCOUNTING AND USE OF SCOOTER BY ASSESSEE IN THE P ROPRIETARY CONCERN BUSINESS CANNOT BE DOUBTED. AS FAR AS THIRD ISSUE OF PERSONAL DRAWINGS AT RS. 20,000/- PER MONTH, THE SAME WAS ALSO FOUND DEBITED IN THE PERSONAL ACCOUNT. IN VIEW OF THE ABOVE, CONSIDERIN G THE FACT THAT AO HAS COMPLETED THE ASSESSMENT U/S. 143(3) AFTER ISSUING THE SHOW CAUSE NOTICE DT. 15-02-2013 U/S. 142(1) CALLING VARIOUS D ETAILS UNDER 11 HEADS INCLUDING CONFIRMATION OF LOANS AND ADVANCES IN RES PECT OF CHEQUES DISCOUNTED, SOURCE OF ADVANCES MADE IN THE FINANCE BUSINESS ETC. THESE INDICATE THAT ALL ASPECTS HAVE BEEN EXAMINED BY THE AO. THEREFORE, THE CITS OBSERVATION THAT AO HAS NOT EXAMINED THESE IS SUES DOES NOT HAVE ANY BASIS. MOREOVER, WHEN ASSESSEE HAS POINTED OUT THE SAME BEFORE THE CIT IN THE PROCEEDINGS U/S. 263, IT IS INCUMBENT UP ON THE CIT TO EXAMINE THE CONTENTIONS AND GIVE FINDINGS RATHER TH AN SETTING ASIDE THE ASSESSMENT, WHICH IS ALREADY SUBJECT MATTER OF APPE AL BEFORE CIT(A) ON OTHER ISSUES. I.T.A. NO. 1660/HYD/2013 VEMULA LAXMINARAYANA :- 6 -: 6. THE HONBLE AP HIGH COURT IN THE CASE OF SPECTRA SHARES AND SCRIPS PVT. LTD., VS. CIT [354 ITR 35] (AP), AFTER ANALYZING THE PRINCIPLES GOVERNING THE EXERCISE OF JURISDICTION BY THE COMMI SSIONER U/S. 263 HAS CULLED OUT THE FOLLOWING PRINCIPLES: 'A) THE COMMISSIONER HAS TO BE SATISFIED OF TWIN CO NDITIONS, NAMELY, (I) THE ORDER OF THE ASSESSING OFFICER SOUGHT TO BE REVISED IS ERRONEOUS; AND (II) IT IS PREJUDICIAL TO THE INTERE STS OF THE REVENUE. IF ERRONEOUS BUT IS NOT PREJUDICIAL TO THE REVENUE OR IF IT IS NOT ERRONEOUS BUT IT IS PREJUDICIAL TO THE REVENUE RE COURSE CANNOT BE HAD TO SEC.263 (1) OF THE ACT. B) EVERY LOSS OF REVENUE AS A CONSEQUENCE OF AN ORD ER OF THE ASSESSING OFFICER CANNOT BE TREATED AS PREJUDICIAL TO THE INTERESTS OF THE REVENUE. FOR EXAMPLE, WHEN AN INCOME-TAX OFFICE R ADOPTED ONE OF THE COURSES PERMISSIBLE IN LAW AND IT HAS RESULT ED IN LOSS OF REVENUE: OR WHERE TWO VIEWS ARE POSSIBLE AND THE IN COME-TAX OFFICER HAS TAKEN ONE VIEW WITH WHICH THE COMMISSIO NER DOES NOT AGREE, IT CANNOT BE TREATED AS AN ERRONEOUS ORDER P REJUDICIAL TO THE INTERESTS OF THE REVENUE, UNLESS THE VIEW TAKEN BY THE INCOME-TAX OFFICER IS UNSUSTAINABLE IN LAW. C) TO INVOKE SUO MOTU REVISIONAL POWERS TO REOPEN A CONCLUDED ASSESSMENT UNDER SEC.263, THE COMMISSIONER MUST GIV E REASONS; THAT A BARE REITERATION BY HIM THAT THE ORDER OF TH E INCOME TAX OFFICER IS ERRONEOUS IN SO FAR AS IT IS PREJUDICIAL TO THE INTERESTS OF THE REVENUE, WILL NOT SUFFICE; THAT THE REASONS MUST BE SUCH AS TO SHOW THAT THE AND MUST IRRESISTIBLY LEAD TO THE CONCLUSI ON THAT THE ORDER OF THE INCOME TAX OFFICER WAS NOT ONLY ERRONEOUS BUT W AS PREJUDICIAL TO THE INTERESTS OF THE REVENUE. THUS, WHILE THE IN COME TAX OFFICER IS NOT CALLED UPON TO WRITE AN ELABORATE JUDGMENT GIVI NG DETAILED REASONS IN RESPECT OF EACH AND EVERY DISALLOWANCE, DEDUCTION, ETC., IT IS INCUMBENT UPON THE COMMISSIONER NOT TO EXERCI SE HIS SUO MOTU REVISIONAL POWERS UNLESS SUPPORTED BY ADEQUATE REAS ONS FOR DOING SO; THAT IF A QUERY IS RAISED DURING THE COURSE OF THE SCRUTINY BY THE ASSESSING OFFICER, WHICH WAS ANSWERED TO THE SATISF ACTION OF THE ASSESSING OFFICER, BUT NEITHER THE QUERY NOR THE AN SWER WERE REFLECTED IN THE ASSESSMENT ORDER, THIS WOULD NOT B Y ITSELF LEAD TO THE CONCLUSION THAT THE ORDER OF THE ASSESSING OFFI CER CALLED FOR INTERFERENCE AND REVISION. I.T.A. NO. 1660/HYD/2013 VEMULA LAXMINARAYANA :- 7 -: E) THE COMMISSIONER CANNOT INITIATE PROCEEDINGS WIT H A VIEW TO START FISHING AND ROVING INQUIRIES IN MATTERS OR ORDERS W HICH ARE ALREADY CONCLUDED; THAT THE DEPARTMENT CANNOT BE PERMITTED TO BEGIN FRESH LITIGATION BECAUSE OF NEW VIEWS THEY ENTERTAIN ON F ACTS OR NEW CIRCUMSTANCE; THAT IF THIS IS PERMITTED, LITIGATION WOULD HAVE NO END EXCEPT WHEN LEGAL INGENUITY IS EXHAUSTED. F) WHETHER THERE WAS APPLICATION OF MIND BEFORE ALL OWING THE EXPENDITURE IN QUESTION HAS TO BE SEEN; THAT IF THE RE WAS AN INQUIRY, EVEN INADEQUATE THAT WOULD NOT BY ITSELF GIVE OCCAS ION TO THE COMMISSIONER TO PASS ORDERS UNDER SEC.263 MERELY BE CAUSE HE HAS A DIFFERENT OPINION IN THE MATTER; THAT IT IS ONLY IN CASES OF LACK OF INQUIRY THAT SUCH A COURSE OF ACTION WOULD BE OPEN; THAT AN ASSESSMENT ORDER MADE BY THE INCOME TAX OFFICER CAN NOT BE BRANDED AS ERRONEOUS BY THE COMMISSIONER SIMPLY BEC AUSE, ACCORDING TO HIM, THE ORDER SHOULD HAVE BEEN WRITTE N MORE ELABORATELY; THERE MUST BE SOME PRIMA FACIE MATERIA L ON RECORD TO SHOW THAT THE TAX WHICH WAS LAWFULLY EXIGIBLE HAS N OT BEEN IMPOSED OR THAT BY THE APPLICATION OF THE RELEVANT STATUTE ON AN INCORRECT OR INCOMPLETE INTERPRETATION, A LESSER TA X THAN WHAT WAS JUST, HAS BEEN IMPOSED. G) THE POWER OF THE COMMISSIONER UNDER SEC.263 (1) IS NOT COMMISSIONER IS ENTITLED TO EXAMINE ANY OTHER RECOR DS WHICH ARE AVAILABLE AT THE TIME OF EXAMINATION BY HIM AND TO TAKE INTO CONSIDERATION EVEN THOSE EVENTS WHICH AROSE SUBSEQU ENT TO THE ORDER OF ASSESSMENT'. 7. IN THIS CASE, AS CAN BEEN SEEN FROM THE NOTICE I SSUED AND THE ASSESSMENT ORDER BY AO DO INDICATE THAT HE HAS APP LIED HIS MIND TO THE ISSUES. IF THERE WAS AN ENQUIRY, EVEN IF IT IS INA DEQUATE THAT WOULD NOT BY ITSELF GIVE OCCASION TO THE CIT TO PASS ORDER U/ S. 263. RESPECTFULLY FOLLOWING THE PRINCIPLES LAID DOWN BY THE JURISDICT IONAL HIGH COURT, I AM OF THE OPINION THAT PROPER CASE HAS NOT BEEN MADE O UT BY THE LD. CIT IN EXERCISING JURISDICTION U/S. 263. NOT ONLY THAT CO NSIDERING THE EXPLANATION GIVEN BY ASSESSEE, HE SHOULD HAVE DROPP ED PROCEEDINGS RATHER THAN DIRECTING THE AO TO MAKE UNNECESSARY EN QUIRIES WHICH ARE I.T.A. NO. 1660/HYD/2013 VEMULA LAXMINARAYANA :- 8 -: NOT WARRANTED IN THIS CASE. IN VIEW THIS, ASSESSEE S GROUNDS ARE ALLOWED AND ORDER OF THE CIT DT. 30-10-2013 IS SET ASIDE. 8. IN THE RESULT, APPEAL IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 22 ND JULY, 2015. SD/- (B. RAMAKOTAIAH) ACCOUNTANT MEMB ER HYDERABAD, DATED 22 ND JULY, 2015 TNMM COPY TO : 1. VEMULA LAXMINARAYANA, WARANGAL, C/O. P. MURALI & CO., CHARTERED ACCOUNTANTS, 6-3-655/2/3, I FLOOR, SOMAJI GUDA, HYDERABAD. 2. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, WARANGAL 3. CIT-VI, HYDERABAD. 4. THE ADDL. CIT, WARANGAL RANGE, WARANGAL. 5. D.R. ITAT, HYDERABAD. 6. GUARD FILE.