Chinimilli Venkata Ramana Kumari, Hyderabad V. ITO, Ward-6(2), Hyderabad, Hyderabad

ITA 1923/HYD/2014

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 6297 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 8 month(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 02-09-2016
• Appeal Filed By: Assessee
• Bench Allotted: B
• Next Hearing Date: 19-05-2016
• Assessment Year: 2010-2011
• Appeal Filed On: 26-12-2014
• Court: TRIBUNAL
• Department Lawyers: U MINICHANDRAN
• Keywords: Sale consideration of property below Jantri Value; Capital asset; Gift; Principle of natural justice; Cost of acquisition
• Section: 50C

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES B, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER I.T.A. NO. 1923/HYD/2014 ASSESSMENT YEAR: 2010-11 SMT CHINIMILLI VENKATA RAMANA KUMARI, HYDERABAD [PAN: ADPPC8637H] VS THE INCOME TAX OFFICER, WARD-6(2), HYDERABAD (APPELLANT) (RESPONDENT) FOR ASSESSEE : NONE FOR REVENUE : SMT U. MINICHANDRAN, DR DATE OF HEARING : 25-08-2016 DATE OF PRONOUNCEMENT : 02-09-2016 O R D E R PER B. RAMAKOTAIAH, A.M. : THIS IS AN APPEAL BY ASSESSEE AGAINST THE ORDER OF TH E COMMISSIONER OF INCOME TAX (APPEALS)-IV, HYDERABAD, DATED 05-09-2014 ON THE ISSUES OF ADDITION OF AMOUNT U/S. 50 C OF THE INCOME TAX ACT [ACT] AND CONSEQUENT COMPUTATION OF CAP ITAL GAINS AND THE TREATMENT GIVEN BY THE ASSESSING OFFICER (AO) TO WARDS SALE OF SHARES AS SHORT TERM CAPITAL GAIN AND NOT AS LON G TERM CAPITAL GAIN AS CLAIMED BY ASSESSEE. I.T.A. NO. 1923/HYD/2014 :- 2 -: 2. BRIEFLY STATED, ASSESSEE ADMITTED AN INCOME OF RS. 1,81,260/- IN HER RETURN OF INCOME. SHE ALSO ADMITTED LOSS FROM CAPITAL GAINS DURING THE YEAR. AO IN THE SCRUTINY ASS ESSMENT HAS NOTICED THAT SUB-REGISTRAR OFFICER VALUATION ON SALE OF LAND WAS AT RS. 1,32,00,000/- AS AGAINST RS. 20 LAKHS ADMITTED BY ASSESSEE. IT WAS CONTENDED BY ASSESSEE THAT SHE AND HER TWO MINOR CHILDREN HAVE EXECUTED THE DOCUMENT OF SALE I.E., SALE OF PLOT NO. 19 ADMEASURING 1200 SQ. YDS., SITUATED AT RAMANNAGUDA VILLAGE, SERILINGAMPALLY MANDAL TO SMT. E. BRAMARA W/O. SRI SHYAM PRASAD ON 29-07-2009 IN SPECIAL CIRCUMSTANCES. HER HUSBAND LATE KASI VISWESWARA VARA PRASAD HAS PROMISED TO GI FT THE SAID LAND TO HER AS THEIR FAMILY HELPED THEM ON SEVERAL OC CASIONS. SUDDENLY ON 21-06-2009, SHRI KASI VISWESWARA VARA P RASAD EXPIRED IN AN ACCIDENT AND SO AFTER THE DEATH OF HER HU SBAND, ASSESSEE CAME TO KNOW THAT A LOAN WAS OUTSTANDING AGAI NST THE LAND AND DOCUMENTS WERE WITH HDFC BANK. SMT. BRAMARA CLEARED THE DOCUMENTS AND PAID AN AMOUNT OF RS. 3,18,000/- AN D ASKED FOR REGISTRATION OF PROPERTY. IT WAS REGISTERED AT HER INSTANCE AS PER THE PROMISE MADE TO HER BY LATE HUSBAND. IT WAS FURTHE R SUBMITTED THAT SHE HAS NOT VERIFIED THE MARKET VALUE OR HO W MUCH STAMP DUTY WAS PAID AS THOSE WERE LOOKED AFTER BY SMT . BRAMARA. IT WAS EXPLAINED THAT SHE WAS NOT AWARE OF THE PROVISIO NS OF THE ACT AS SHE WAS DISTURBED AFTER THE DEATH OF HER HUSBAND A ND WITHIN A SHORT PERIOD OF FORTY DAYS, THE PROPERTY WAS REGISTER ED. SHE ALSO SUBMITTED THAT PROPERTY SOLD AS AGRICULTURAL LAND, CONS ISTING OF BIG WELL USED FOR AGRICULTURAL PURPOSES AND AREA IS WITH IN FULL TANK LEVEL OF THE TANK. CONSEQUENTLY, SHE ALSO FILED OBJEC TIONS CONTESTING THAT THE MARKET VALUE IS LESS. AO, IN VIEW OF THE SUBMI SSIONS DISPUTING THE MARKET VALUE OF THE PROPERTY, REFERRED T HE ISSUE TO I.T.A. NO. 1923/HYD/2014 :- 3 -: VALUATION OFFICER OF THE DEPARTMENT REQUESTING TO INSPECT THE PROPERTY AND DETERMINE THE TRUE AND CORRECT VALUE OF T HE PROPERTY AS PER SECTION 50C OF THE ACT. REFERENCE WAS MADE ON 21-03-2013 AND THE VALUATION OFFICER VIDE LETTER DT. 26-03-2013 HA S DETERMINED THE VALUE OF PROPERTY AT RS. 79,20,000/-, AS ON JULY 2009. THE AO ADOPTED THE VALUE AS DETERMINED BY THE V ALUATION OFFICER AND AFTER GIVING CREDIT TO THE COST OF ACQUISI TION AS CLAIMED, DETERMINED THE LONG TERM CAPITAL GAIN AT RS. 69,01,731 /- AND BROUGHT TO TAX THE ABOVE AMOUNT. IN ADDITION TO THAT, ASS ESSEE CLAIMED LOSS OF RS. 18,17,147/- ON SALE OF SHARES O F M/S. CHINIMILLI DRUGS PVT. LTD., BELONGING TO HER AND HER HUSBAND. IN COMPUTATION OF INCOME, SHE ADMITTED SALE PRICE OF RS. 1,52,03,220/- AND PURCHASE COST ALSO RS. 1,52,03,220 /-. THE INDEXATION COST WAS ARRIVED AT RS. 1,70,20,367/- AND L OSS OF RS. 18,17,147/- WAS CLAIMED. THE AO NOTICED THAT ASSESSEE AND HER HUSBAND WERE HAVING ONLY 10,000 SHARES OF RS. 10/- EACH AMOUNTING TO RS. 1 LAKH BUT MADE INVESTMENTS TOWARDS SHAR E APPLICATION MONEY FOR 19,55,000 SHARES. THE SHARES WERE ALLOTTED I.E., 19,55,000/- AGAINST THE SHARE APPLICATION MONEY ON 31-10- 2009 AND THESE WERE SOLD AT RS. 10/- EACH. AO WAS O F THE VIEW THAT SINCE THE SHARES WERE ALLOTTED ONLY ON 31-10-2009, THE SALE OF SHARES WOULD RESULT IN SHORT TERM CAPITAL GAIN, HE ACC ORDINGLY, DETERMINED THE SHORT TERM CAPITAL GAIN AT NIL AND LONG TERM CAPITAL GAIN WHICH RESULTED IN A LOSS OF RS. 21,117/- WAS ALLOWED TO BE SET-OFF TO THE LONG TERM CAPITAL GAIN ARRIVED AT B Y THE AO IN THE SALE OF PLOT. ASSESSEE IS AGGRIEVED AND PREFERRE D AN APPEAL BEFORE THE CIT(A). I.T.A. NO. 1923/HYD/2014 :- 4 -: 3. LD. CIT(A) AFTER ADMITTING AN AFFIDAVIT FROM SMT. BRAMARA, INDICATING THAT THE PROPERTY WAS ORIGINALLY INTENDED TO BE GIFT, BUT AFTER UNEXPECTED DEATH OF KASI VISWESWARA V ARA PRASAD, THE DOCUMENT WAS EXECUTED BY ASSESSEE AND HER CHILDR EN AND SHE HAD PAID ONLY RS. 20 LAKHS OF WHICH RS. 8.49 LAKHS BEFORE HIS DEATH AND RS. 11.51 LAKHS AFTER HIS DEATH TOWARDS CLEAR ING THE DOCUMENTS FROM HDFC BANK AND CASH PAYMENT OF RS. 3,18 ,000/-. EVEN THOUGH, AFFIDAVIT INDICATES THAT THE PROPERTY WAS TO BE A GIFT LD. CIT(A), HOWEVER, DID NOT AGREE WITH THE ABOVE CON TENTION AND AFFIRMED THE ACTION OF THE AO BY STATING AS UNDER: 8. THERE IS NO REFERENCE IN THE SALE DEED TO THE I NTENT OF EITHER THE APPELLANT OR THE APPELLANTS HUSBAND TO MAKE A GIFT TO THE VENDEE. THE CLAIM THAT THE REGISTRATION WAS DONE F OR AN AMOUNT LESSER THAN THE SROS RATE IS, THEREFORE, NOT SUPPO RTED BY ANY EVIDENCE. IT HAS ALSO NOT BEEN EXPLAINED BY THE AR , EITHER DURING THE ASSESSMENT PROCEEDINGS OR DURING THE APPELLATE PROCEEDINGS, WHY THE APPELLANT EXECUTED A SALE DEED WHEN THE INT ENT WAS TO GIFT THE LAND TO THE VENDEE. 9. THE APPELLANTS CLAIMS REGARDING THE EXTRANEOUS CIRCUMSTANCES LEADING TO THE EXECUTION OF THE SALE DEED AT A RATE LESS THAN THE SROS RATE IS NEITHER EXPLAINED SATIS FACTORILY NOR SUPPORTED BY ANY EVIDENCE. THE CLAIM THAT SEC. 50C WAS NOT APPLICABLE TO THE APPELLANT IS, THEREFORE, REJECTED AND THE ASSESSMENT OF LONG TERM CAPITAL GAINS AT RS. 69,01, 731 IS UPHELD. 3.1. EVEN THOUGH, ASSESSEE HAS RAISED THE GROUNDS ON THE TREATMENT OF SALE OF SHARES [GROUND 1(II)], THE LD. CI T(A) DID NOT ADJUDICATE THE ISSUE. ASSESSEE IS AGGRIEVED AND RAIS ED THE GROUNDS ON THE ABOVE TWO ISSUES. IN THE COURSE OF PRESENT HE ARING, ASSESSEE FILED A PAPER BOOK CONTAINING PGS. 1 TO 45 A ND AUTHORISATION IN THE NAME OF SHRI AMRIT KUMAR KOTA. H OWEVER, AR HAS NOT APPEARED WHEN THE CASE WAS POSTED NUMBER OF TIMES BUT FILED WRITTEN SUBMISSIONS AS UNDER: I.T.A. NO. 1923/HYD/2014 :- 5 -: 1. THE ASSESSEE CHINAMALLI VENKATA RAMANA KUMARI IS AN INDIVIDUAL FILED HER INCOME TAX RETURNS FOR THE A.Y 2010-11 ON 15.07.2010. 2. THERE ARE TWO GROUNDS OF APPEAL. (A) SALE OF SHARES (B) SALE OF PROPERTY 3. DURING THE ASSESSMENT YEAR THE ASSESSEE SOLD 20, 55,000 SHARES. 4. THE ASSESSEE HAS TRANSFERRED THE PROPERTY SITUAT ED AT SURVEY NOS. 11,12 (PART) AND 15 ADMEASURING 1200 SQ. YARDS SITU ATED AT RAMANNAGUDA VILLAGE, SERILINGAMPALLY MANDAL, R.R DI STRICT ALONG WITH HER MINOR DAUGHTER KUMARI CH. JAAHNAVI AND MASTER C H. VIJAYA SESHAGIRI AS LEGAL HEIRS OF C KASI VISWESWARA VARA PRASAD, HUSBAND OF THE ASSESSEE. 5. THE SAID PROPERTY WAS ORIGINALLY AGREED TO GIVE AS A GIFT TO SMT. E. BRAMARA AS GRATITUDE FOR THE HELPS AND SUPPORT TO T HE ASSESSEE. 6. UNFORTUNATELY, THE ASSESSEE'S HUSBAND C KASI VIS WESWARA VARA PRASAD WAS MET WITH AN ACCIDENT AND EXPIRED ON 21.0 6.2009 WITHOUT HONOURING THE WORD TO SMT. E. BRAMARA. 7. SMT E.BRAMARA HAS APPROACHED THE FAMILY MEMBERS AND SOUGHT FOR THE EXECUTION OF DOCUMENTS TO FULFILL THE PROMISE. 8. THOUGH THE ASSESSEE WAS IN DEEP SHOCK WITHOUT HA VING, ANY SECOND THOUGHT AGREED TO FULFILL THE WORD GIVEN BY HER DEC EASED HUSBAND. SHE REQUESTED E.BRAMARA TO PREPARE THE DOCUMENTS FOR CO MPLETION OF THE FORMALITIES OF TRANSFER OF THE PROPERTY AS SHE CANN OT COME OUT OF THE HOUSE AND BOTH THE CHILDREN ARE MINORS AND HAVING NO ACKN OWLEDGE ABOUT THE FORMALITIES OF TRANSFER OF THE PROPERTY. 9. THE BUYER PREPARED THE DOCUMENTS AND THE ASSESSE E EXECUTED THE WITHOUT THINKING THE CONSEQUENCES. 10. THE ASSESSING OFFICER IS OF THE OPINION THAT IT IS A SALE AND NOT A GIFT. 11. THE ASSEESSEE APPROACHED E.BRAMARA AND BRIEFED ABOUT THE OPINION OF THE INCOME TAX OFFICER. 12. SUBSEQUENTLY E.BRAMARA HAS GIVEN AN AFFIDAVIT D ULY NOTARIZED STATING THE FACTS THAT THE PROPERTY HAS BEEN RECEIVED AS A GIFT. 13. EVEN THE PURCHASER HAS ACCEPTED ALL THE FACTS M ENTIONED ABOVE IN HER AFFIDAVIT AND .FURTHER CONFIRMED THAT, THE PROPERTY HAS BEEN TRANSFERRED AS I.T.A. NO. 1923/HYD/2014 :- 6 -: GRATITUDE BY THE DECEASED FAMILY AGAINST THE HELP E XTENDED BY HIM IN THE PAST. 14. IT IS EVIDENT FROM THE AFFIDAVIT THAT THE PROPE RTY WAS TRANSFERRED AS A GIFT. 15. THIS IS A UNIQUE SITUATION, WHERE THE PROPERTY HAS BEEN TRANSFERRED FOR A CONSIDERATION DETERMINED BY THE BUYER (THE AMOUNT PAID TOWARDS REPAYMENT OF THE LOAN TO RELEASE THE DOCUMENTS). IN CASE, THERE IS ANY INADEQUATE CONSIDERATION COMPONENT IN THE SAID SALE TRANSACTION, THEN IT MUST BE ONLY A GIFT THAT WAS GIVEN BASED ON PROMISE OF THE DECEASED. IN THE SAID CIRCUMSTANCES, THE AMOUNT PAID RS.20,00,00 0/- HAS TO BE TREATED AS INADEQUATE CONSIDERATION TOWARDS THE GIFT. 4. AS THE CASE WAS POSTED ON 14-10-2015, 26-11-2015 , 29-02-2016, 19-05-2016 AND 24-08-2016, WE HAVE CONS IDERED THE ISSUES ON MERITS, AFTER CONSIDERING THE WRITTEN SUBMI SSIONS OF THE LD. COUNSEL. 5. LD. DR HOWEVER, SUPPORTED THE ORDERS OF THE AO. W HEN IT WAS SPECIFICALLY ASKED, HOW THE ENTIRE CAPITAL GAIN ON TRANSFER OF LAND WAS ASSESSED IN THE HANDS OF ASSESSEE, LD. DR S UBMITTED THAT OTHER TWO BEING MINOR CHILDREN, THEIR INCOMES WERE AL SO CLUBBED WITH THE INCOME OF THE MOTHER. 6. AFTER CONSIDERING THE RIVAL CONTENTIONS AND PERUSIN G THE DOCUMENTS ON RECORD, WE ARE OF THE OPINION THAT THE ASSE SSMENT REQUIRES TO BE RE-DONE, AS THE AO HAS NOT DONE THE ASSE SSMENT PROPERLY. FIRST OF ALL, THE AO HAS REFERRED THE VAL UATION TO THE VALUATION OFFICER AND ADOPTED THE VALUE OF RS. 79,20,0 00/- WHICH IS INDEED VERY MUCH LESS THAN THE MARKET VALUE FOR STAM P DUTY PURPOSES BUT MORE THAN WHAT ASSESSEE HAS RECEIVED. A O HAS TO GIVE A FAIR OPPORTUNITY TO ASSESSEE WITH REFERENCE TO THE VALUATION I.T.A. NO. 1923/HYD/2014 :- 7 -: OFFICERS REPORT AND OBTAIN OBJECTIONS IF ANY FROM ASS ESSEE, BEFORE DETERMINING THE VALUE WHEN ASSESSEE ADMITS THAT THE PROP ERTY WAS SOLD FOR RS. 20 LAKHS ON CERTAIN SPECIAL CONSIDERATIO NS. SINCE NO OPPORTUNITY WAS GIVEN TO ASSESSEE BEFORE ADOPTING THE VALUE, WE ARE OF THE OPINION THAT ASSESSEE SHOULD BE GIVEN DUE O PPORTUNITY BY FOLLOWING THE PRINCIPLES OF NATURAL JUSTICE. ON THAT REASON ALONE ADOPTION OF THE SALE VALUE CANNOT BE APPROVED. 7. THE NEXT ISSUE TO BE EXAMINED IS HOW THE AO COULD BRING THE ENTIRE AMOUNT TO TAX IN THE HANDS OF ASSESSEE? AS SEEN FROM THE SALE DEED PLACED IN THE PAPER BOOK AT PG. 4, SMT. CH.V. RAMANI AND HER CHILDREN HAS INHERITED THE PROPERTY AF TER THE SUDDEN DEMISE OF HER HUSBAND AND SHE HAS SIGNED FOR HERSELF AND ALSO FOR TWO MINOR CHILDREN KUMARI CH. JAAHNAVI (17 ) AND MASTER CH. VIJAYA SESHAGIRI (16), AS MINOR GUARDIAN. SINCE ASSESSEE IS ONLY HAVING 1/3 RD SHARE IN THE PROPERTY SOLD, CAPITAL GAINS TO THAT EXTENT ALONE SHOULD BE TAXED IN HER HAND. AS FAR AS THE INCOME OF THE MINORS ARE CONCERNED, IF THE CAPITAL GAINS IF ANY ARISES IN THEIR HAND, THAT HAS TO BE DETERMINED FIRST SEPARATELY AND TH EN ONLY THE SAME CAN BE CLUBBED IN THE HANDS OF THE MOTHER. THE AO HAS NOT CONSIDERED THIS ASPECT AT ALL AND ENTIRE SALE CONSIDER ATION IS BROUGHT TO TAX IN THE HANDS OF ASSESSEE ALONE. HE SHO ULD HAVE DETERMINED THE SHARE OF EACH PERSON SEPARATELY, DETE RMINE THE CAPITAL GAINS IN EACH HAND AND THEN ONLY PROVISIONS O F SECTION 64 & 65 CAN BE INVOKED. SINCE AOS COMPUTATION IS PER SE NOT ACCORDING TO THE PROVISIONS OF THE ACT, THAT ALSO REQUIR ES RE-CONSIDERATION. I.T.A. NO. 1923/HYD/2014 :- 8 -: 8. NEXT ASPECT WHICH REQUIRES FURTHER EXAMINATION IS THE CIRCUMSTANCES IN WHICH THE PROPERTY HAS BEEN SOLD. A T ONE END, SMT. BRAMARA SAYS THAT PROPERTY IS TO BE GIFTED TO HER, BUT AS SEEN FROM PG. 3 OF THE SALE DEED, IT INDICATES THAT AN AMOUNT OF RS. 7,49,000/- WAS ALREADY PAID TO THE VENDOR AT THE TIME OF AGREEMENT OF SALE DT. 03-04-2009. THAT MEANS, THERE IS AN AGREEM ENT OF SALE. IF THERE IS AN AGREEMENT OF SALE AND ADVANCE WAS PAID TO LATE KASI VISWESWARA VARA PRASAD, THEN WHETHER THE POSSESSION WA S GIVEN AT THE TIME OF AGREEMENT OF SALE OR NOT ALSO DETERMINES IN WHOSE HAND THE INCOME IS TO BE ASSESSED. IN CASE THE POSSESSION WAS ALSO HANDED OVER AT THE TIME OF AGREEMENT OF SALE, THEN, THE INCOME GETS CRYSTALISED IN THE HANDS OF SRI KASI VISWESWARA VARA PRASAD, AND NOT IN THE HANDS OF ASSESSEE, WHO HAS SUBSEQUENTLY EX ECUTED THE DOCUMENT. HOWEVER, IF THERE IS NO AGREEMENT OF SALE, THEN THE PAYMENT OF RS. 7,49,000/- REQUIRES EXAMINATION, BECAU SE THERE CANNOT BE ANY CONSIDERATION IN MONETARY TERMS, WHEN THE PROPERTY IS TO BE GIFTED TO HER AS CLAIMED. THESE ASPECTS HAVE NOT BEEN EXAMINED AND SMT. BRAMARA HAS NOT BEEN ENQUIRED. IN VIEW OF THIS, WE ARE OF THE OPINION THAT THERE ARE ENQUIRIES TO BE CONDUCTED NOT ONLY WITH REFERENCE TO THE NATURE OF TRANSACTIONS, BU T ALSO THE QUANTUM OF COMPUTATION TO BE ASSESSED IN EACH HANDS A ND WHETHER THE CONTENTIONS RAISED IN THE AFFIDAVIT FILED BEF ORE THE LD. CIT(A) HAS ANY BEARING ON THE DETERMINATION OF VALUAT ION. IN ORDER TO EXAMINE THESE ASPECTS AND COMPLETE THE ASSESSMENT AS PER THE PROVISIONS OF THE ACT, WE HEREBY SET ASIDE THE ORDER O F AO AND CIT(A) ON THIS ISSUE. 9. WITH REFERENCE TO CAPITAL GAINS COMPUTATION ON SALE OF SHARES, THE AO IS DIRECTED TO EXAMINE THE ISSUE AGAIN AS ASSESSEE I.T.A. NO. 1923/HYD/2014 :- 9 -: HAS GIVEN VARIOUS DATES FOR ACQUISITION OF SHARES. EV EN THOUGH SHARES COULD HAVE BEEN ALLOTTED LATER, WHETHER ASSESSE E CAN GET BENEFIT OF COST OF INDEXATION HAVING INVESTED THE MONEY MUCH EARLIER IN THE COMPANY WHICH IS THEIR PRIVATE LIMITED COMPANY. SINCE, THESE ASPECTS REQUIRES RE-EXAMINATION, WE HEREB Y SET ASIDE THE COMPUTATION OF LONG TERM CAPITAL GAIN AND SHORT TERM CAPITAL GAIN ON SALE OF SHARES FOR RE-EXAMINATION. T HE SALE DEEDS INDICATE THAT THE SHARES WERE SOLD PIECE-MEAL DURING THE YEAR UNDER CONSIDERATION. WHETHER ONLY ONE PERSON HAS PUR CHASED OR DIFFERENT PERSONS HAVE PURCHASED THE SHARES ALSO REQU IRE EXAMINATION IN VIEW OF THE SPECIAL CIRCUMSTANCES IN WH ICH ASSESSEE WAS DIVESTED OF THE SHARES AS WELL AS LANDED PROPER TY AFTER THE DEATH OF HER HUSBAND. WITH THESE OBSERVATIONS, THE ENTI RE ASSESSMENT IS RESTORED TO THE FILE OF AO BY SETTING ASID E THE ORDERS OF AO AND CIT(A). GROUNDS ARE ALLOWED FOR STATISTICAL PURPOSES. 10. IN THE RESULT, APPEAL IS ALLOWED FOR STATISTICAL PU RPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 2 ND SEPTEMBER, 2016 SD/- SD/- (P. MADHAVI DEVI) (B. RAMAKOTAIAH) JUDICIAL MEMBER ACCOUNTANT MEM BER HYDERABAD, DATED 2 ND SEPTEMBER, 2016 TNMM I.T.A. NO. 1923/HYD/2014 :- 10 -: COPY TO : 1. CHINIMILLI VENKATA RAMANA KUMARI, HYDERABAD. C /O. SPAD & ASSOCIATES, CHARTERED ACCOUNTANTS, 6-3-609/1 95, ANAND NAGAR, KAIRATABAD, HYDERABAD. 2. THE INCOME TAX OFFICER, WARD-6(2), HYDERABAD. 3. CIT(APPEALS)-IV, HYDERABAD 4. CIT-III, HYDERABAD. 5. D.R. ITAT, HYDERABAD. 6. GUARD FILE.