M/s Iconic Designs Private Limited, Hyderabad V. ITO, Ward 2(1), Hyderabad

ITA 1719/HYD/2012

• Counselvise Citation: [2013] 140 COUNSELVISE.COM (IT) 69756 (ITAT-HYDERABAD)
• Duration Of Justice: 9 month(s) 1 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-08-2013
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2008-2009
• Appeal Filed On: 29-11-2012
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: R LAXMAN
• Assessee Lawyers: T CHAITANYA KUMAR
• Keywords: Business expenditure
• Section: 143(3)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES A : HYDERABAD BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER ITA.NO.1719/HYD/2012 ASSESSMENT YEAR 2008-2009 M/S. ICONIC DESIGNS PVT. LTD. HYDERABAD 500 081. PAN AADCP4869Q VS. I.T.O. WARD 2 (1) HYDERABAD. (APPELLANT) (RESPONDENT) FOR APPELLANT : SHRI T.CHAITANYA KUMAR (A.R.) FOR RESPONDENT : SHRI R.LAXMAN (D.R.) DATE OF HEARING : 20.06.2013 DATE OF PRONOUNCEMENT : 30.08.2013 ORDER PER SAKTIJIT DEY, J.M. THE ASSESSEE IN THE PRESENT APPEAL HAS BASICALLY CH ALLENGED THE ADDITION OF RS.2,78,42,337/- AS INCOME FROM OTHER S OURCES WITHOUT ALLOWING CLAIM OF EXPENDITURE THEREFROM. 2. BRIEFLY THE FACTS ARE, THE ASSESSEE IS A COMPANY I N WHICH THE PUBLIC ARE NOT SUBSTANTIALLY INTERESTED. THE ASSESSEE, AS C LAIMED BY IT, HAS BEEN CARRYING OUT THE OPERATIONS OF SOFTWARE DEVELOPMENT AND INFORMATION TECHNOLOGY ENABLED SERVICES, INFRASTRUCTURE DEVELOPM ENT SUCH AS DEVELOPMENT OF INFORMATION TECHNOLOGY PARK AND COMME RCIAL COMPLEX. FOR THE IMPUGNED ASSESSMENT YEAR THE ASSESSEE FILES ITS RETURN OF INCOME DECLARING TOTAL INCOME OF RS.9,59,802/-. IN COURSE OF THE ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER NOTICED THAT THE ASSESSEE HAD SHOWN INTEREST INCOME OF RS.2,78,42,337/- ON DEPOSITS KEP T IN BANKS AND DEBITED AN AMOUNT OF RS.2,49,98,538/- TO THE P & L A/C. UND ER ADMINISTRATIVE AND OTHER EXPENSES. THE ASSESSING OFFICER FURTHER NOTICE D THAT THE NOTES ON ACCOUNTS IN THE ANNUAL REPORT READ AS UNDER : 2 THE COMPANY WAS INCORPORATED ON FEBRUARY 6 TH , 2003 AS PIONEER TELAFONE PVT. LTD. AND CHANGED ITS NAME ON MARCH 14 TH , 2007 AS ICONIC DESIGNS PVT. LTD. COMPANY WAS INIT IALLY FORMED TO RENDER SERVICES IN I.T. AND ITES SECTOR W .E.F. NOVEMBER 24 TH , 2006 COMPANY CHANGED ITS LINE OF BUSINESS FROM IT RELATED ACTIVITIES TO INFRASTRUCTURE DEVELO PMENT SUCH AS DEVELOPMENT OF INFORMATION TECHNOLOGY PARK AND COMM ERCIAL COMPLEXES. 3. THE ASSESSING OFFICER, THEREFORE, ISSUED SUMMONS TO THE MANAGING DIRECTOR OF THE ASSESSEE TO APPEAR AND EXPLAIN, WHY T HE INTEREST ON DEPOSITS SHOULD NOT BE TREATED AS INCOME FROM OTHER SOURCES WITHOUT ALLOWING THE EXPENDITURE CLAIMED THEREFROM IN TERMS WITH THE RATI O LAID DOWN BY THE HONBLE SUPREME COURT IN CASE OF TUTICORIN ALKALI CH EMICALS & FERTILIZERS LTD. VS. CIT 227 ITR 172. THE ASSESSEE OBJECTED INTER ALIA , ON THE GROUND THAT THE COMPANY WAS INCORPORATED IN THE FINANCIAL YE AR 2003-2004 AND COMMENCED ITS BUSINESS DURING THAT YEAR ONLY. IT RECE IVED INVESTMENT BY WAY OF SHARE CAPITAL FOR EXPANSION OF BUSINESS ACTIVI TIES TO INFRASTRUCTURE DEVELOPMENT APART FROM I.T. RELATED ACTIVITIES DURI NG THE FINANCIAL YEAR 2006- 2007. THE INTEREST INCOME RECEIVED WAS ON THESE INV ESTMENTS RECEIVED AND NOT ON SHORT TERM INVESTMENTS ON FUNDS BORROWED FOR SETTING-UP OF FACTORY AND DURING CONSTRUCTION OF FACTORY BEFORE COMMENCEME NT OF BUSINESS. THERE IS NO CHANGE OF LINE OF BUSINESS BUT IT IS ONLY EXPAN SION OF THE BUSINESS ACTIVITIES. AS THE INCOME RECEIVED ON INVESTMENTS W AS NOT FOR SETTING UP OF ANY FACTORY BEFORE COMMENCEMENT OF BUSINESS BUT ON SH ORT TERM INVESTMENTS OUT OF FUNDS RECEIVED FOR EXPANSION OF I TS BUSINESS ACTIVITIES THE EXPENDITURE HAS TO BE REDUCED FROM SUCH INCOME. 4. THE ASSESSING OFFICER, HOWEVER, DID NOT ACCEPT T HE CONTENTIONS OF THE ASSESSEE BY OBSERVING THAT THOUGH THE COMPANY WAS NOT SETTING UP A FACTORY BUT IT IS DEVELOPING INFRASTRUCTURE, WHICH INVOLVES BUILDING I.T. PARKS AND COMPLEXES AND CONSTRUCTION ACTIVITY WAS GOING ON. TH OUGH THE INCOME WAS ON SHORT TERM INVESTMENTS NOT OUT OF BORROWED FUNDS FOR SETTING UP OF FACTORY BUT OUT OF FUNDS RECEIVED TOWARDS INVESTMENT FOR EXPANSION OF 3 BUSINESS ACTIVITIES, BUT STILL THEN INTEREST EARNED ON DEPOSITS MADE OUT OF CAPITAL CONTRIBUTION IS TO BE TREATED AS INCOME FRO M OTHER SOURCES. THE ASSESSING OFFICER FURTHER HELD THAT DIRECTORS ANNUA L REPORT IN SCHEDULE N UNDER SIGNIFICANT ACCOUNT POLICIES AND NOTE TO THE ACCOUNTS CLEARLY ESTABLISHES THAT THERE IS NOT MERELY A CHANGE IN THE NAME BUT A TOTAL CHANGE IN LINE OF BUSINESS W.E.F. 24.11.2006 FROM I.T. REL ATED ACTIVITIES TO INFRASTRUCTURE DEVELOPMENT. THE ASSESSING OFFICER O PINED THAT HAD IT BEEN AN EXPANSION OF THE BUSINESS ACTIVITY, THE ASSESSEE W OULD HAVE CONTINUED THE EARLIER BUSINESS OF I.T. AND ITES ACTIVITIES IN ADDITION TO THE NEW BUSINESS OF INFRASTRUCTURE DEVELOPMENT. WHEREAS, IN THE P & L ACCOUNT FOR THE YEAR UNDER DISPUTE, THE ASSESSEE HAS NOT SHOWN A NY INCOME ON ACCOUNT OF ITS EARLIER BUSINESS ACTIVITIES. IT WAS FURTHER NOTED BY THE ASSESSING OFFICER THAT THOUGH IN THE IMMEDIATELY PRECEDING FINANCIAL YE ARS 2005-06 AND 2006- 2007, THE ASSESSEE HAD SHOWN INCOME FROM I.T. AND I TES SERVICES AT RS. 2.39 CRORES AND RS.44,78,000/- RESPECTIVELY, BUT NO SUCH INCOME WAS SHOWN BY THE ASSESSEE IN THE YEAR UNDER DISPUTE WHICH REVEALS THE FACT THAT THE ASSESSEE HAS COMPLETELY STOPPED THE EARLIER BUSI NESS OF IT AND ITES. THE ASSESSING OFFICER FURTHER CONCLUDED THAT AS THE ASS ESSEE HAD CHANGED ITS LINE OF BUSINESS TO INFRASTRUCTURE DEVELOPMENT ACTI VITY W.E.F. 24.11.2006 AND THE NAME WAS CHANGED TO M/S. ICONIC DESIGNS PVT. LT D. ON 14.3.2007, IT BECOMES CLEAR THAT THE ASSESSEE HAS NOT COMMENCED I TS BUSINESS ACTIVITY OF CONSTRUCTION. HE, THEREFORE, RELYING UPON THE DECISI ON OF THE HONBLE SUPREME COURT IN CASE OF TUTICORIN ALKALI CHEMICALS AND FERTILIZERS LTD. VS. CIT (SUPRA) AND CIT VS. COROMANDEL CEMENTS LTD. 234 ITR 412 HELD THAT THE INTEREST INCOME HAS TO BE TREATED AS INCOME FROM OT HER SOURCES. THE ASSESSING OFFICER FURTHER HELD THAT AS THE INTEREST INCOME WAS EARNED DURING CONSTRUCTION AND BEFORE COMMENCEMENT OF BUSINESS, T HE INTEREST INCOME CANNOT BE SET OFF AGAINST LOSS OF THE COMPANY. HE FU RTHER HELD THAT THE INTEREST INCOME ALSO CANNOT BE REDUCED FROM THE COS T OF CONSTRUCTION AS IT HAS NO NEXUS WITH THE CONSTRUCTION. HE ACCORDINGLY C OMPLETED THE ASSESSMENT BY DETERMINING THE TAXABLE INCOME AT RS.2, 78,42,337/-. 4 5. THE ASSESSEE BEING AGGRIEVED OF THE ASSESSMENT O RDER PREFERRED AN APPEAL BEFORE THE CIT(A). HOWEVER, AS THE ASSESSEE DID NOT APPEAR, THE APPEAL WAS DECIDED EX-PARTE BY THE CIT(A) BY HOLDING AS UNDER : 6.4. DURING THE F.Y. 2006-07 THE APPELLANT COMPANY RECEIVED SHARE PREMIUM OF RS.89,14,64,794/-. THIS AMOUNT WAS RECEIVED FOR COMMENCEMENT OF NEW BUSINESS. A FURTHE R FINANCIAL ANALYSIS SHOWS HOW THE OLD BUSINESS WAS STOPPED AND THE NEW UNRELATED BUSINESS WAS STARTED. F.Y. TURNOVER ON ACCOUNT OF IT SERVICES REMAKRS 2005 - 06 2.23 CRORE OLD COMPANY, OLD BUSINESS OF IT SERVICES 2006 - 07 0.44 CRORE NOV 24, 2006, NEW NAME OF COMPANY. OLD BUSINESS BEING WOUND UP. SHARE PREMIUM OF 89 CRORE RECEIVED. 2007 - 08 0 NO OLD BUSINESS. NEW BUSINESS IN THE PROCESS OF COMMENCEMENT. 6.5. FROM THE ABOVE CHART, THE FACT ILLUSTRATE HOW THE OLD BUSINESS WAS STOPPED, NEW EQUITY RECEIVED AND THE N EW BUSINESS WAS IN THE PROCESS OF BEING STARTED. THE ASSERTION OF THE APPELLANT THAT THERE WAS EXPANSION OF THE OLD BUSINESS IS ABSOLUTELY UNFOUNDED. THE AFOREMENTIONED FACTS CLEARLY ILLUSTRATE THE TRANSIT ION FROM AN IT SERVICES COMPANY CALLED PIONEER TALAFONE LTD . TO :ICONIC DESIGNS PVT. LTD., A NEW COMPANY ENGAGED I N THE BUSINESS OF INFRASTRUCTURE DEVELOPMENT. 6.6. IT IS CLEAR THAT THE ASSESSING OFFICER HAS RIG HTLY APPLIED THE JUDGMENT OF THE HONBLE APEX COURT IN THE CASES OF TUTICORIN ALKALI CHEMICALS AND FERTILIZERS LTD. VS. CIT IN 227 ITR 172; AND CIT VS. COROMANDEL CEMENTS LTD. IN 234 ITR 412. THERE IS NO DOUBT THAT THE SHARE PREMI UM AMOUNT RECEIVED WAS INVESTED IN SHORT TERM FUNDS. A T THIS STAGE, THE NEW BUSINESS FOR WHICH THE FUNDS HA D 5 BEEN RECEIVED HAD NOT COMMENCED WHILE THE OLD ONE H AD CEASED. THEREFORE, I AGREE WITH THE A.O. THAT THE I NCOME EARNED ON INTEREST ON DEPOSITS WAS TO BE CLASSIFIED AS INCOME FROM OTHER SOURCES. 6. THE LEARNED A.R REITERATING THE STAND TAKEN BEFO RE THE REVENUE AUTHORITIES SUBMITTED THAT THERE IS NO CHANGE IN LI NE OF BUSINESS BUT THERE IS ONLY A CHANGE OF NAME. REFERRING TO THE MEMORANDUM O F ASSOCIATION OF THE EARLIER COMPANY M/S. PIONEER TALAFONE PVT. LTD. AND THE ASSESSEE COMPANY, THE LEARNED AR SUBMITTED THAT THE OBJECTS OF BOTH CO MPANIES ARE VIRTUALLY THE SAME AND THE COMPANY HAS BEEN FILING ITS RETURN OF INCOME REGULARLY. IT WAS SUBMITTED THAT THE MANAGEMENT OF THE COMPANY IS ALSO SAME AND THE COMPANY HAS ALREADY COMMENCED ITS BUSINESS AND CONTIN UING THE SAME BUSINESS ACTIVITIES SINCE THE INCORPORATION IN THE YEAR 2003-2004. SUBSEQUENTLY, IN THE YEAR 2006 THE ASSESSEE IN ADDITI ON TO ITS EARLIER LINE OF BUSINESS AS EXTENDED TO THE ACTIVITY OF INFRASTRUCTU RE DEVELOPMENT. IT WAS SUBMITTED THAT THE ASSESSEE ITSELF HAS ADMITTED INT EREST EARNED AS INCOME FROM OTHER SOURCES BUT THE ASSESSING OFFICER DID NO T ALLOW THE EXPENDITURE BY TREATING IT AS RELATING TO PRE-COMMENCEMENT PERIO D WHICH IS NOT A CORRECT FACT AS THE ASSESSEE IN FACT HAS BEEN CONTINUING WI TH ITS EARLIER BUSINESS ACTIVITY. IT WAS SUBMITTED THAT ONLY BECAUSE THE ASSE SSEE DID NOT HAD ANY INCOME FROM BUSINESS, FOR WHATEVER MAY BE THE REASON , IT CANNOT BE SAID THAT THE ASSESSEE HAS STOPPED ITS EARLIER BUSINESS ACTIVITIES. THE LEARNED A.R. THEREFORE, SUBMITTED THAT THE EXPENDITURE CLAI MED UNDER THE HEAD ADMINISTRATIVE AND OTHER EXPENSES SHOULD BE ALLOWE D TO BE SET OFF AGAINST THE INTEREST INCOME AND THE ASSESSEE IS ENTITLED TO AVAIL THE BENEFIT UNDER SECTION 71 OF THE ACT. THE LEARNED A.R. FURTHER SUB MITTED THAT IN THE ASSESSMENT YEAR 2009-2010 THE ASSESSING OFFICER ALLO WED THE SET OFF OF EXPENDITURE CLAIMED UNDER ADMINISTRATIVE AND OTHER E XPENSES AGAINST THE INTEREST INCOME WHILE COMPLETING THE ASSESSMENT UND ER SECTION 143(3) OF THE ACT. IN THIS REGARD, THE LEARNED A.R. ALSO SUBMITTE D A COPY OF THE ASSESSMENT ORDER DATED 20.02.2011 PASSED FOR THE ASSESSMENT YEA R 2009-2010. THE LEARNED A.R. ALSO RELIED UPON THE FOLLOWING DECISIO NS : 6 (I) CIT V. DALMIA PROMOTERS DEVELOPERS P. LTD. ( 2006) 281 ITR 346 (DEL.) (II) DCIT V. ASSAM ASBESTOS LTD., (2003) 263 ITR 357 (GAU.) (III) SUJAY TRADING P.LTD. V. JCIT (2008)111 ITD 249 (MU M.) (TM) (IV) CIT V. HAVELLS INDIA LTD. (2012) 253 CTR 27 1 (DEL.) 7. THE LEARNED DR ON THE OTHER HAND STRONGLY SUPPORT ED THE ORDERS OF THE CIT(A) AND SUBMITTED THAT THERE IS NO CONTINUIT Y OF BUSINESS WHICH WOULD BE EVIDENT FROM THE P & L ACCOUNT AS THE ASSE SSEE HAS NOT DECLARED ANY INCOME FROM BUSINESS. IT WAS SUBMITTED THAT AFTE R FORMATION OF NEW COMPANY, THE EARLIER BUSINESS WAS TOTALLY STOPPED AND THE ASSESSEE HAS CHANGED OVER TO COMPLETELY NEW LINE OF BUSINESS WHIC H IS NOT YET COMMENCED. THEREFORE, THE EXPENDITURE/LOSS RELATING TO PRE-COMMENCEMENT PERIOD CANNOT BE SET OFF AGAINST THE INTEREST INCOM E WHICH IS TO BE ASSESSED UNDER THE HEAD INCOME FROM OTHER SOURCES. IN SUPP ORT OF HIS CONTENTION, THE LEARNED DR REFERRED TO THE NOTE OF THE MANAGING DIRECTOR AS CONTAINED IN THE NOTES ON ACCOUNTS OF THE ANNUAL REPORT. THE LEA RNED DR ALSO RELIED UPON THE FOLLOWING DECISIONS : (I) TUTICORIN ALKALI CHEMICALS & FERTILIZERS LTD. V. CIT (1997) 227 ITR 172 (SC) (II) CIT V. COROMANDEL CEMENTS LTD. (1998) 234 I TR 412 (SC) 8. WE HAVE HEARD SUBMISSIONS OF THE PARTIES AND PER USED THE MATERIALS ON RECORD AS WELL AS THE ORDERS OF THE REVENUE AUTH ORITIES. AT THE OUTSET WE MAY PUT IT ON RECORD THAT THERE IS NO CONTROVERSY WIT H REGARD TO THE FACT THAT THE INTEREST INCOME IS TO BE ASSESSED UNDER THE HEA D INCOME FROM OTHER SOURCES. THE ASSESSEE NOT ONLY ITSELF IN THE COMPUT ATION OF INCOME FILED WITH THE RETURN OF INCOME FOR THE IMPUGNED ASSESSME NT YEAR HAS TREATED IT AS INCOME FROM OTHER SOURCES BUT HAS REITERATED THE SAME BEFORE US ALSO. THEREFORE, IN THE AFORESAID FACTUAL BACKDROP, IT HA S TO BE EXAMINED WHETHER THE ADMINISTRATIVE AND OTHER EXPENDITURE CAN BE SET OFF AGAINST THE INTEREST INCOME. ON A PERUSAL OF THE ASSESSMENT ORDER AS WEL L AS THE ORDER OF THE 7 CIT(A) IT WOULD BE EVIDENT THAT SET OFF OF BUSINESS EXPENDITURE/LOSS WAS DENIED ON THE GROUND THAT THE ASSESSEE HAS COMPLETE LY STOPPED ITS EARLIER BUSINESS ACTIVITY OF IT AND ITES SERVICES AND CHANGE D TO A NEW LINE OF BUSINESS OF INFRASTRUCTURE DEVELOPMENT AND COMMERCI AL COMPLEXES. HOWEVER, IT IS THE CONTENTION OF THE ASSESSEE THROU GHOUT THAT IT IS ONLY A CHANGE OF NAME OF THE COMPANY INCORPORATED IN THE YEA R 2003-04 AND THERE IS CONTINUITY OF THE EARLIER BUSINESS ACTIVITY IN ADD ITION TO THE NEW ACTIVITY OF INFRASTRUCTURE DEVELOPMENT. IT WAS, THEREFORE, CONT ENDED THAT THE LOWER AUTHORITIES WERE NOT CORRECT IN DENYING SET OFF OF B USINESS LOSS UNDER SEC. 71 OF THE ACT ON THE GRANT OF NON-COMMENCEMENT OF BUSI NESS ACTIVITIES. 9. THE CERTIFICATE OF INCORPORATION ISSUED BY REGIST RAR OF COMPANIES (ROC) DOES INDICATE THAT IT IS NOT AN INCORPORATION OF NEW COMPANY BUT CHANGE OF NAME OF EARLIER COMPANY VIZ., PIONEER TALA FONE PVT. LTD. TO ICONIC DESIGNS PVT. LTD. ON GOING THROUGH THE MEMORANDUM O F ASSOCIATION OF BOTH THE COMPANIES, WHICH ARE AT PAGES 2 AND 14 OF THE P APER BOOK ALSO REVEAL THAT THE OBJECTS ARE COMMON IN NATURE. CLAUSE 5 OF T HE OBJECT CLAUSE, AS PER THE MOA OF ASSESSEE ALSO ENUMERATES PROVIDING IT AN D ITES RELATED SERVICES. ON A PERUSAL OF THE WRITTEN SUBMISSION, STATED TO H AVE BEEN FILED BEFORE THE CIT(A), IT IS TO BE SEEN THAT THE ASSESSEE HAS SPEC IFICALLY SUBMITTED THAT IT HAS NOT DISCONTINUED ITS EARLIER BUSINESS BUT AS IT DID NOT RECEIVE ANY INCOME DUE TO NON-CONFIRMATION OF ANY ORDERS FROM IT S VENDORS NO INCOME FROM BUSINESS ACTIVITIES WAS REPORTED IN THE IMPUGN ED ASSESSMENT YEAR. WHEN THERE IS ONLY A CHANGE IN THE NAME OF THE COMP ANY AND ALL OTHER THINGS INCLUDING THE MANAGEMENT OF THE COMPANY REMAI NS UNCHANGED, THEN IT CANNOT BE SAID THAT THE ASSESSEE HAS NOT COMMENC ED ITS BUSINESS ACTIVITIES AND IN THAT EVENT BENEFIT UNDER SEC. 71 OF THE ACT CANNOT BE DENIED TO THE ASSESSEE. ONLY BECAUSE THE ASSESSEE HAS NOT R EPORTED ANY INCOME FROM BUSINESS IN THE ASSESSMENT YEAR UNDER DISPUTE, IT CANNOT AUTOMATICALLY LEAD TO THE CONCLUSION THAT IT HAS STO PPED ITS EARLIER BUSINESS ACTIVITIES. FURTHER, ON PERUSAL OF THE ASSESSMENT O RDER PASSED FOR THE ASSESSMENT YEAR 2009-2010, IT APPEARS THAT THE ASSES SING OFFICER HAS ALLOWED SET OFF OF ADMINISTRATIVE AND OTHER EXPENSES AGAINST INTEREST INCOME 8 WHILE COMPLETING ASSESSMENT UNDER SECTION 143(3) OF THE ACT. THEREFORE, IN THE AFORESAID VIEW OF THE MATTER, THE EXPENDITURE CL AIMED CANNOT BE DISALLOWED AND HAS TO BE SET OFF AGAINST THE INTERE ST INCOME EARNED DURING THE ASSESSMENT YEAR UNDER DISPUTE. ACCORDINGLY, WE DI RECT THE ASSESSING OFFICER TO DO SO. THE GROUNDS RAISED ARE ALLOWED. 10. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWE D. ORDER PRONOUNCED IN THE OPEN COURT ON 30 TH AUGUST, 2013. SD/- SD/- (CHANDRA POOJARI) (SAKTIJIT DEY) ACCOUNTANT MEMBER JUDICIAL MEM BER HYDERABAD DATE 30 TH AUGUST, 2013. VBP/- COPY TO 1. M/S. ICONIC DESIGNS PVT. LTD. PLOT NO.16, PIONE ER TOWERS, SOFTWARE UNITS LAYOUT, MADHAPUR, HI-TECH CITY, HYDERABAD 500 08 1.PAN AADCP4869Q 2. INCOME TAX OFFICER, WARD 2 (1), HYDERABAD. 3. CIT(A)-III, HYDERABAD. 4. CIT-II, HYDERABAD 5. D.R. A BENCH, ITAT, HYDERABAD.