Agricultural Market Committee, Kubeer V. Income Tax Officer, Ward-1, Nirmal

ITA 2067/Hyd/2018

• Counselvise Citation: [2019] 115 COUNSELVISE.COM (IT) 3251 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 15-11-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB-A
• Assessment Year: 2005-2006
• Appeal Filed On: 23-10-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SUNKU SRINIVASDR
• Keywords: Charitable institution; Condonation of delay
• Section: 143(3); 12A; 12AA; 205; 250; 147; 148; 12; 11

Judgement Text

ITA NOS 2065 2066 AND 2067 OF 2018 AMC KUBEER. PAGE 1 OF 6 IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD A SMC BENCH, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER ITA NOS.2065, 2066 AND 2067/HYD/2018 ASSESSMENT YEARS: 2003-04, 2004-05 & 2005-06 AGRICULTURAL MARKET COMMITTEE, KUBEER PAN: AAALA0853F VS. INCOME TAX OFFICER, WARD-1 NIRMAL (APPELLANT) (RESPONDENT) ASSESSEE BY: SMT. S. SANDHYA REVENUE BY : SRI SUNKU SRINIVAS,DR DATE OF HEARING: 13/11/2019 DATE OF PRONOUNCEMENT: 15 /11/2019 ORDER THIS ARE ASSESSEES APPEALS FOR THE A.YS 2003-04 TO 2005-06 AGAINST THE ORDER OF THE CIT (A)-5, HYDERA BAD, DATED 13.08.2018 DENYING THE CLAIM OF EXEMPTION U/S 11 OF THE I.T. ACT TO THE ASSESSEE. 2. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE WA S A LOCAL AUTHORITY AND WAS ELIGIBLE FOR EXEMPTION U/S 10(20) OF THE ACT UPTO THE A.Y 2002-03. CONSEQUENT TO THE INSERTION O F EXPLANATION BELOW SECTION 10(20) BY THE FINANCE ACT, 2002 W.E.F . 01.04.2003, THE INCOMES OF LOCAL AUTHORITY NOT SPECIFIED IN T HE SAID EXPLANATION ARE NO LONGER EXEMPT FROM TAX. THE AO T HEREFORE, ISSUED NOTICE U/S 148 OF THE ACT, DATED 28.08.2007 REQUIRING IT TO FILE THE RETURN OF INCOME FOR THE A.Y 2003-04. THE ASSESSEE FILED THE RETURN OF INCOME ON 31.12.2008. FURTHER, AS THE ASSESSEE HAD NOT BEEN REGISTERED U/S 12A, THE EXEMPTION U/S 11 W AS DENIED TO THE ASSESSEE. THE ASSESSEE THEREAFTER FILED AN APPL ICATION FOR ITA NOS 2065 2066 AND 2067 OF 2018 AMC KUBEER. PAGE 2 OF 6 REGISTRATION U/S 12A OF THE ACT. THE DIT (E) DISMIS SED THE ASSESSEES APPLICATION. THEREAFTER, THE ASSESSEE FI LED AN APPEAL BEFORE THE ITAT AND THE ITAT DIRECTED THE DIT (E) T O CONDONE THE DELAY IN FILING OF THE APPLICATION U/S 12A AND ADJU DICATE THE ISSUE AFRESH. MEANWHILE, THE AO TOOK UP THE RETURN OF INC OME OF THE ASSESSEE FOR ASSESSMENT AND THE AO COMPLETED THE AS SESSMENT BY DENYING EXEMPTION U/S 11 OF THE ACT. AGGRIEVED, THE ASSESSEE PREFERRED AN APPEAL BEFORE THE CIT (A) WHO OBSERVED THAT CONSEQUENT TO THE ITAT ORDER, THE DIT (E) HAS GRANT ED REGISTRATION U/S 12A OF THE ACT ONLY W.E.F. 30.05.2007 I.E. THE DATE OF APPLICATION FILED BY THE ASSESSEE IN FORM NO.10A. T HEREFORE, THE CIT (A) HELD THAT THE ASSESSEE IS NOT ELIGIBLE FOR EXEMPTION PRIOR TO SUCH DATE. THUS, THE ASSESSEE WAS DENIED EXEMPTION FOR THE RELEVANT A.Y AND IS IN APPEAL BEFORE US. 3. THE LEARNED COUNSEL FOR THE ASSESSEE SUBMITTED T HAT SIMILAR ISSUE HAD COME UP BEFORE THE TRIBUNAL IN TH E CASE OF AMC BODHAN AND THE TRIBUNAL BY FOLLOWING THE DECISION O F THE COORDINATE BENCH AT AHMEDABAD IN THE CASE OF SHREE BHANUSHALI MITRA MANDAL TRUST VS. ITO (2016) 68 TAXMANN.COM 25 0 (AHMEDABAD TRIB) HAS TAKEN NOTE OF FIRST PROVISO OF SECTION 12A OF THE ACT AND HAS DIRECTED THE AO TO ALLOW THE ASSESS EES CLAIM OF EXEMPTION U/S 11 A OF THE ACT EVEN FOR THE A.Y PRIO R TO THE DATE OF REGISTRATION IF THE ASSESSMENTS FOR THOSE ASSESSMEN T YEARS WERE PENDING OR WERE REOPENED SUBSEQUENTLY U/S 147 OF TH E ACT PROVIDED, THE ASSESSEE SATISFIED THE OTHER CONDITIO NS OF SECTION 11. 4. THE LEARNED DR HOWEVER, SUPPORTED THE ORDERS OF THE AUTHORITIES BELOW. ITA NOS 2065 2066 AND 2067 OF 2018 AMC KUBEER. PAGE 3 OF 6 5. HAVING REGARD TO THE RIVAL CONTENTIONS AND THE M ATERIAL ON RECORD, I FIND THAT THE ISSUE BEFORE ME IS EXACT LY THE SAME AS IN THE CASE OF AMC, BODHAN. FOR THE SAKE OF CLARITY AN D READY REFERENCE, THE RELEVANT PARAS ARE REPRODUCED HEREUN DER:- 3. UPON HEARING BOTH THE PARTIES, WE FIND THAT UNDE R THE PROVISO TO SUB-SECTION (2) TO SECTION 12A OF THE ACT, THE PROVISI ONS OF SECTION 11 & 12 SHALL APPLY EVEN IN RESPECT OF THE ASSESSMENT YEARS PRIOR TO THE YEAR IN WHICH THE REGISTRATION U/S 12A WAS GRANTED , PROVIDED THE ASSESSMENTS FOR THOSE YEARS ARE PENDING AS ON THE DATE OF REGISTRATION AND THE OBJECTS AND ACTIVITIES OF SUCH TRUS T OR INSTITUTION REMAIN THE SAME FOR SUCH PRECEDING A.Y. THE SECOND PROVISO PROHIBITS ANY ACTION U/S 147 FOR ANY A.Y. PRECEDING TH E A.Y. IN WHICH REGISTRATION IS GRANTED ONLY FOR NON-REGISTRATION OF SUCH TRUST OR INSTITUTION FOR THE SAID AYS AND THE THIRD PROVISO STA TES THAT THE FIRST AND SECOND PROVISOS SHALL NOT APPLY IN CASE OF ANY TR UST OR INSTITUTION WHICH HAS BEEN REFUSED REGISTRATION OR THE REGISTRATIO N GRANTED WAS CANCELLED AT ANY TIME U/S 12AA OF THE ACT. THE SMC BEN CH OF ITAT AT AHMEDABAD HAS CONSIDERED THE EFFECT OF THESE PROVI SOS IN THE CASE OF SHREE BHANUSHALI MITRA MANDAL TRUST VS. ITO [2016] 68 TAXMANN.COM 250 (AHMEDABAD-TRIB.) AND AT PARAS 7.2 TO 7.4 HAS HELD AS UNDER: 7.2 IT IS ALSO RELEVANT TO REPRODUCE THE EXPLANATORY NOTES TO THE PROVISIONS OF FINANCE (NO.2) ACT, 2014 AS GIVEN IN CBDT CIRCUL AR NO.01/2015 DATED 21.01.2015 IN REFERENCE F. NO.142/13/2014-TPL , WHICH READ AS FOLLOWS: 'PARA 8.2 NON-APPLICATION OF REGISTRATION FOR THE PERIOD PRIO R TO THE YEAR OF REGISTRATION CAUSED GENUINE HARDSHIP TO CHARITABLE ORGANIZATIONS. DUE TO ABSENCE OF REGISTRATION, TAX LIABILITY IS FASTEN ED EVEN THOUGH THEY MAY OTHERWISE BE ELIGIBLE FOR EXEMPTION AND FULFILL OTHER SUBSTANTIVE CONDITIONS. HOWEVER, THE POWER OF CONDONATION OF DE LAY IN SEEKING REGISTRATION WAS NOT AVAILABLE.' THIS CLEARLY GOES TO PROVE THAT THE FIRST PROVISO T O SECTION 12A(2) WAS BROUGHT IN THE STATUTE ONLY AS A RETROSPECTIVE EFFE CT WITH A VIEW NOT TO AFFECT GENUINE CHARITABLE TRUSTS AND SOCIETIES CARR YING ON GENUINE CHARITABLE OBJECTS IN THE EARLIER YEARS AND SUBSTAN TIVE CONDITIONS STIPULATED IN SECTION 11 TO 13 HAVE BEEN DULY FULFI LLED BY THE SAID TRUST. THE BENEFIT OF RETROSPECTIVE APPLICATION ALO NE COULD BE THE INTENTION OF THE LEGISLATURE AND THIS POINT IS FURT HER STRENGTHENED BY THE EXPLANATORY NOTES TO FINANCE (NO.2) ACT, 2014 I SSUED BY THE CENTRAL BOARD OF DIRECT TAXES VIDE ITS CIRCULAR NO. 01/2015 DATED 21.1.2015. APPARENTLY THE STATUTE PROVIDES THAT REG ISTRATION ONCE GRANTED IN SUBSEQUENT YEAR, THE BENEFIT OF THE SAME HAS TO BE APPLIED IN THE EARLIER ASSESSMENT YEARS FOR WHICH ASSESSMEN T PROCEEDINGS ARE PENDING BEFORE THE LD. A.O., UNLESS THE REGISTRATIO N GRANTED EARLIER IS CANCELLED OR REFUSED FOR SPECIFIC REASONS. THE STAT UTE ALSO GOES ON TO PROVIDE THAT NO ACTION U/S147 COULD BE TAKEN BY THE AO MERELY FOR NON-REGISTRATION OF TRUST FOR EARLIER YEARS. 7.3 IN THE INSTANT CASE, IT IS NOT IN DISPUTE THAT RE GISTRATION WAS GRANTED W.E.F. 17.12.2013 BY THE ORDER OF CIT(A) DATED 08.0 5.2014. IT IS ALSO NOT IN DISPUTE THAT OBJECTS AND ACTIVITIES OF THE A SSESSEE TRUST ARE ITA NOS 2065 2066 AND 2067 OF 2018 AMC KUBEER. PAGE 4 OF 6 CHARITABLE IN NATURE DURING THE RELEVANT FINANCIAL YEAR. WHEN SECTION 12A OF THE ACT WAS AMENDED BY INTRODUCING NEW PROVI SOS TO SUB- SECTION (2) OF SECTION 12A BY FINANCE ACT, 2014 WIT H EFFECT FROM 01.10.2014, THE ASSESSMENT ORDERS PASSED BY THE ASS ESSING OFFICER IN RESPECT OF THE PRESENT ASSESSEE WERE PENDING IN APP EAL BEFORE THE FIRST APPELLATE AUTHORITY. DURING SUCH PENDENCY, THE ASSE SSEE WAS GRANTED REGISTRATION U/S. 12AA OF THE ACT ON 17.12.2013 W.E .F. THE ASSESSMENT YEAR 2013-14. THE APPEAL IS THE CONTINUATION OF THE ORIGINAL PROCEEDINGS AND THAT THE POWER OF THE COMMISSIONER OF INCOME-TAX WAS CO-TERMINUS WITH THAT OF THE ASSESSING OFFICER WERE TWO WELL ESTABLISHED PRINCIPLES OF LAW. IN VIEW OF THE ABOVE AND GOING BY THE PRINCIPLE OF PURPOSIVE INTERPRETATION OF STATUES, A N ASSESSMENT PROCEEDING WHICH IS PENDING IN APPEAL BEFORE THE AP PELLATE AUTHORITY SHOULD BE DEEMED TO BE 'ASSESSMENT PROCEEDINGS PEND ING BEFORE THE ASSESSING OFFICER' WITHIN THE MEANING OF THAT TERM AS ENVISAGED UNDER THE PROVISO. IT FOLLOWS THERE-FROM THAT THE ASSESSE E WHICH OBTAINED REGISTRATION U/S 12AA OF THE ACT DURING THE PENDENC Y OF APPEAL WAS ENTITLED FOR EXEMPTION CLAIMED U/S 11 OF THE ACT. 7.4 THE EXPLANATORY MEMORANDUM TO FINANCE (NO.2) BILL , 2014, WHICH SOUGHT TO AMEND SECTION 12A EXPLAINS THE OBJECTS AN D REASONS FOR MAKING SUCH AMENDMENTS. THE EXPLANATION MAKES IT CL EAR THAT IT WAS IN ORDER TO PROVIDE RELIEF TO SUCH TRUSTS IN RESPEC T OF WHICH, DUE TO ABSENCE OF REGISTRATION U/S 12AA TAX LIABILITY GOT ATTACHED THOUGH OTHERWISE THEY WERE ELIGIBLE FOR EXEMPTION BY FULFI LLING OTHER SUBSTANTIVE CONDITIONS THAT THE AMENDMENT WAS BROUG HT IN. THAT BEING SO, DENYING SUCH BENEFIT TO A TRUST LIKE THE ASSESSEE WHO HAD OBTAINED REGISTRATION U/S 12AA DURING THE PENDENCY OF THE APPEALS FILED AGAINST THE ORDERS OF THE ASSESSING AUTHORITY , BY NARROWLY INTERPRETING THE TERM, 'PENDING BEFORE THE ASSESSIN G OFFICER' SO AS TO EXCLUDE ITS PENDENCY BEFORE THE APPELLATE AUTHORITY , WILL BE DOING VIOLENCE TO THE PROVISIONS OF THE STATUTE AND, AS S UCH, LIABLE TO BE INTERFERED WITH. MOREOVER, UNDER THE SCHEME OF THE ACT, SECTIONS 11 AND 12 ARE SUBSTANTIVE PROVISIONS WHICH PROVIDE FOR EXEMPTIONS TO A RELIGIOUS OR CHARITABLE TRUST. SECTIONS 12A AND 12A A DETAIL THE PROCEDURAL REQUIREMENTS FOR MAKING AN APPLICATION T O CLAIM EXEMPTIONS UNDER SECTIONS 11 AND 12 BY THE ASSESSEE AND THE GRANT OR REJECTION OF SUCH APPLICATION BY THE COMMISSIONE R. THUS, IN MY VIEW, SECTIONS 12A AND 12AA ARE ONLY PROCEDURAL IN NATURE . HENCE, IT IS NOT THE REGISTRATION U/S 12AA BY ITSELF THAT OFFERS IMM UNITY FROM TAXATION. A RECEIPT WHETHER IT IS REVENUE OR CAPITAL IN NATUR E IS TO BE DECIDED AT THE ASSESSMENT STAGE. BEING PROCEDURAL IN NATURE, I N MY VIEW, LIBERAL INTERPRETATION WILL GIVE EFFECT TO THE INTENTION OF THE AMENDMENT, THEREBY REMOVING THE HARDSHIP IN GENUINE CASES LIKE THE PRESENT ASSESSEE UNDER CONSIDERATION. 4. IN THE CASE OF HMDA, THE COORDINATE BENCH OF THIS TR IBUNAL, WHEREIN ONE OF US (JM) IS A SIGNATORY TO THE ORDER, CONSIDERED THE ABOVE DECISION AND HAS HELD THAT ONCE REGISTRATION IS GRANTED , PROVISO TO SECTION 12A(2) WAS APPLICABLE EVEN TO THE PENDING AP PEALS FOR THE ASSESSMENT YEARS PRIOR TO REGISTRATION. FOR THE SAKE OF CONVENIENCE AND READY REFERENCE, THE RELEVANT PORTION OF THE TRIBUNAL S ORDER IS REPRODUCED HEREUNDER: 13. HOWEVER, SINCE THIS ISSUE IS TO BE CONSIDERED IN THE ASSESSMENTS U/S 143(3) OF THE IT ACT, WE REFRAIN FR OM GIVING ANY FINDING ON THIS ISSUE AT THIS STAGE. AS REGARDS TH E ASSESSEES PRAYER TO GRANT REGISTRATION W.E.F. 01-04-2002 AS T HE ASSESSMENTS FOR THE RELEVANT ASSESSMENT YEARS WERE PENDING AS O N THE DATE OF REGISTRATION IS CONCERNED, WE FIND THAT THE ASSESSE E HAS PLACED ITA NOS 2065 2066 AND 2067 OF 2018 AMC KUBEER. PAGE 5 OF 6 RELIANCE UPON THE DECISION OF THE SINGLE MEMBER CAS E SMC AT AHMADABAD IN THE CASE OF SHRI BHANUSHALI MITRAMANDA LI TRUST VS ITO REPORTED IN (2016) 68 TAXMAN.COM 205 AHMADABAD TRIBUNAL WHEREIN IT WAS HELD THAT WHERE THE REGISTRATION IS GRANTED IN THE SUBSEQUENT YEAR, THE BENEFIT OF THE SAME HAS TO BE APPLIED IN THE EARLIER ASSESSMENT YEARS ALSO UNDER THE FIRST PROVI SO TO SEC. 12A(2) OF THE ACT, AND THAT SUCH PROVISO IS APPLICABLE EVE N TO APPEALS PENDING BEFORE THE CIT(E). 14. THE LD. COUNSEL FOR THE ASSESSEE HAD SUBMITTED THAT THE APPLICATION U/S 12A OF THE IT ACT WAS INITIALLY REJ ECTED BY THE CIT(E) AND THE ISSUE WAS RESTORED TO THE FILE OF TH E CIT(A) BY THE ITAT, AND THEREFORE, THE EARLIER ORDER OF THE CIT(E ) GOT NULLIFIED AND THE ASSESSEES APPLICATION FOR REGISTRATION GOT RES TORED AND HAS TO BE CONSIDERED AS PENDING FOR CONSIDERATION BY THE C IT(E). HE SUBMITTED THAT AT THE TIME WHEN THE CIT(E) WAS CONS IDERING THE ASSESSEES APPLICATION AFRESH, THE ASSESSEE HAD FIL ED A LETTER SEEKING REGISTRATION W.E.F. 01-04-2002 AND THEREFOR E THE ISSUE WAS VERY MUCH BEFORE THE CIT(E) WHILE GRANTING REGISTRA TION W.E.F. A.Y 2007-08. HE SUBMITTED THAT AS PER THE FIRST PROVIS O OF 12A(2) OF THE IT ACT, THE REGISTRATION GRANTED IN THE SUBSEQUENT YEAR SHALL BE APPLIED TO THE EARLIER ASSESSMENT YEARS ALSO, WHERE VER THE ASSESSMENT PROCEEDINGS ARE PENDING BEFORE THE A.O. HE SUBMITTED THAT THE ASSESSMENTS IN THE CASE OF THE ASSESSEE FO R ALL THE ASSESSMENT YEARS FROM 2003-04 ON WARDS WERE PENDING BEFORE THE A.O AND HENCE THE PROVISO WAS APPLICABLE AND ASSESS EE SHOULD BE GRANTED REGISTRATION W.E.F 01-04-2002. 15. THE LD. SR. STANDING COUNSEL FOR THE DEPARTMENT , ON THE OTHER HAND, SUBMITTED THAT ASSESSEES APPLICATION W AS ALREADY REJECTED BY THE CIT(E) AND IN THE EARLIER APPLICATI ON THE ASSESSEE HAD NEVER CLAIMED THE EXEMPTION W.E.F 01-04-2002 NO R HAS IT FILED ANY APPLICATION FOR CONDONATION OF DELAY GIVING REA SONS AS TO WHY THE APPLICATION COULD NOT BE FILED EARLIER. 16. HAVING REGARD TO THE RIVAL CONTENTIONS AND THE MATERIAL ON RECORD, WE FIND THAT BY VIRTUE OF REMAND TO THE CIT (E) FOR RE- CONSIDERATION OF THE ASSESSEES APPLICATION FOR REG ISTRATION U/S 12A OF THE IT ACT, THE ASSESSEES APPLICATION HAS BEEN REVIVED. AS ON THE DATE WHEN THE CIT(E) WAS CONSIDERING THE APPLIC ATION FOR REGISTRATION PURSUANT TO THE REMAND BY THE ITAT, TH E PROVISO TO SEC. 12A(2) OF THE IT ACT HAS COME INTO THE STATUTE BOOK AND THEREFORE IT IS VERY MUCH APPLICABLE TO ALL THE PENDING ASSESSME NTS BEFORE THE A.O. THE SMC BENCH OF THIS TRIBUNAL AT AHMADABAD, IN THE CASE OF SHRI BHANUSHALI MITRAMANDALI TRUST VS ITO (CITED SU PRA) HAS ALSO HELD SO. PARTICULARLY IN THE CASE OF HAND, WE FIND THAT THERE IS NO CHANGE IN THE OBJECTS OF THE ASSESSEE FROM THE EARL IER AND IN THE SUBSEQUENT ASSESSMENT YEARS AND THERE IS NO FINDING THAT THE ASSESSEE HAS CARRIED ON ANY ACTIVITY NOT IN ACCORDA NCE WITH ITS OBJECTIVES. IN VIEW OF THE SAME, WE ARE OF THE OPI NION THAT THE ASSESSEE IS ELIGIBLE FOR REGISTRATION U/S 12A OF TH E IT ACT W.E.F 01- 04-2002 AND ACCORDINGLY, WE DIRECT THE CIT(E) TO MO DIFY THE ORDER OF REGISTRATION U/S 12AA OF THE ACT W.E.F. 01-04-20 02 I.E FROM A.Y 2003-04 ONWARDS. IN THE RESULT THE ASSESSEE APPEAL IN ITA NO. 03/HYD/2017 IS ALLOWED. 5. FOLLOWING THE ABOVE DECISION, WE SET-ASIDE THE ASS ESSMENTS AND REMAND THE SAME TO THE FILE OF THE ASSESSING OFFICE R WITH A DIRECTION TO ALLOW THE ASSESSEES CLAIM OF EXEMPTION U /S 11 OF THE ACT EVEN FOR THE ASSESSMENT YEARS PRIOR TO THE DATE OF REGIS TRATION WHERE ITA NOS 2065 2066 AND 2067 OF 2018 AMC KUBEER. PAGE 6 OF 6 THE ASSESSMENTS WERE PENDING OR WERE REOPENED SUBSEQU ENTLY U/S 147 OF THE ACT, PROVIDED, THE ASSESSEE SATISFIED THE OTH ER CONDITIONS OF SECTION 11, PARTICULARLY, SINCE THE APPLICATION FO R GRANT OF REGISTRATION W.E.F 01/04/2012 IS STILL PENDING BEFOR E THE DIT (E). THEREFORE, ALL THE APPEALS OF THE RESPECTIVE ASSESSEE S ARE TREATED AS ALLOWED FOR STATISTICAL PURPOSES. 6. RESPECTFULLY FOLLOWING THE SAME, I FIND THAT THE FIRST APPEAL BEFORE THE CIT (A) WAS PENDING WHEN THE REGI STRATION U/S 12A WAS GRANTED ON 11.4.2014 AND THE CIT (A) HAS AL SO REPRODUCED THE SAID ORDER OF REGISTRATION U/S 12A I N THE APPELLATE ORDER. THEREFORE, I DIRECT THE AO TO ALLOW EXEMPTIO N U/S 11 OF THE ACT TO THE ASSESSEE FOR THE A.YS BEFORE US AS THE F IRST APPEALS FOR THE RELEVANT A.YS WERE PENDING BEFORE THE CIT (A) A T THE TIME THE REGISTRATION U/S 12A WAS GRANTED BY THE CIT (A). 7. IN THE RESULT, ASSESSEES APPEALS ARE ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 15 TH NOVEMBER, 2019. SD/- (P. MADHAVI DEVI) JUDICIAL MEMBER HYDERABAD, DATED 15 TH NOVEMBER, 2019. VINODAN/SPS COPY TO: 1 AGRICULTURAL MARKET COMMITTEE, KUBEER, KUBEER MAN DAL, ADILABAD DISTT. 2 ITO WARD-1 NIRMAL, ADILABAD 3 CIT (A)-5 HYDERABAD 4 PR. CIT 5 HYDERABAD 5 THE DR, ITAT HYDERABAD 6 GUARD FILE BY ORDER