Instrument Technologies, , Visakhapatnam V. The Assistant Commissioner Of Income Tax, Circle-3(1), , Visakhapatnam

ITA 228/VIZ/2020

• Counselvise Citation: [2021] 109 COUNSELVISE.COM (IT) 9006 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 1 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 06-01-2021
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: 2013-2014
• Appeal Filed On: 19-11-2020
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: B RAMA KRISHNA
• Keywords: Depreciation; Application of stay; Set aside
• Section: 195; 13

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM (THROUGH WEB - BASED VIDEO CONFERENCING PLATFORM) . , . . , BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER& SHRI D.S. SUNDER SINGH, ACCOUNTANT MEMBER S . A.NO. 49 /VIZ/2020 (ARISING OUT OF I.T.A. NO.2 28 /VIZ/2020) ( / A SSESSMENT Y EAR : 20 1 3 - 14 ) INSTRUMENT TECHNOLOGIES D.NO.50 - 63 - 03, GAYATRI NILAYAM RAJENDRA NAGAR SEETHAMMAPETA VISAKHAPATNAM [PAN : A AAFI9931J] VS . ASST.COMMISSIONER OF INCOME TAX CIRCLE - 3(1) VISAKHAPATNAM ( / APPELLANT) ( / RESPONDENT) I.T.A. NO.228/VIZ/2020) ( / A SSESSMENT Y EAR : 2013 - 14) INSTRUMENT TECHNOLOGIES D.NO.50 - 63 - 03, GAYATRI NILAYAM RAJENDRA NAGAR SEETHAMMAPETA VISAKHAPATNAM [PAN : AAAFI9931J] ASST.COMMISSIONER OF INCOME TAX CIRCLE - 3(1) VISAKHAPATNAM / APPELLANT BY : SHRI G.V.N.HARI, AR / RESPONDENT BY : SHRI B.RAMA KRISHNA, DR / DATE OF HEARING : 27.11.2020 / DATE OF PRONOUNCEMENT : 06.01.2021 2 S.A. NO. 49 /VIZ/2020 AND I.T.A. 2 28 /VIZ/2020,A.Y. 20 13 - 14 INSTRUMENT TECHNOLOGIES , VISAKHAPATNAM / O R D E R P ER SHRI D.S.SUNDER SINGH, ACCOUNTANT MEMBER : THE ASSESSEE FILED APPEAL WITH THE DELAY OF 195 DAYS AND FILED PETITION FOR CONDONATION STATING THAT THE DELAY WAS DUE TO LOCKDOWN AND CORONA PANDEMIC. AFTER HEARING BOTH THE PARTIES, THE DELAY IS CONDONED AND THE APPEAL IS ADMITTED . SINCE THE APPEAL IS TAKEN UP FOR HEARING, THE STAY APPLICATION OF THE ASSESSEE BECOMES INFRUCTUOS, HENCE DISMISSED. 2. THE ONLY ISSUE IN THIS APPEAL IS WITH REGARD TO SUSTAINING THE ADDITION OF RS.1,27,80,000/ - MADE BY THE ASSE SSING OFFICER (AO) RESTRICTING THE DEPRECIATION ON BIO METRIC DEVICES TO 15% AS AGAINST 60% CLAIMED BY THE ASSESSEE. DURING THE ASSESSMENT PROCEEDINGS, THE AO FOUND THAT THE ASSESSEE HAS PURCHASED BIOMETRIC DEVICES FOR RS.5,68,00,000/ - AND CLAIMED THE DEP RECIATION @60%. BEFORE THE AO THE ASSESSEE SUBMITTED THAT THE ASSESSEE HA S PURCHASED THE BIO METRIC DEVICES WHICH ARE COMPUTER ACCESSORIES AND THEY ARE NOT USEFUL UNLESS THE Y ARE ATTACHED TO THE COMPUTER OR LAPTOP AND HENCE, THE SAME IS TO BE TREATED ON PAR WITH COMPUTER AND HENCE, CLAIMED THE DEPRECIATION AT HIGHER RATE . 3. THE AO NOT BEING CONVINCED WITH THE EXPLANATION OF THE ASSESSEE HELD THAT BIOMETRIC DEVICES ARE CAPABLE OF FUNCTION ING INDEPENDENTLY AND NEED NOT NECESSARILY ATTACH TO THE COMPUTER FOR ITS WORKING. THE AO FURTHER VIEWED 3 S.A. NO. 49 /VIZ/2020 AND I.T.A. 2 28 /VIZ/2020,A.Y. 20 13 - 14 INSTRUMENT TECHNOLOGIES , VISAKHAPATNAM THAT THEY ARE NOT THE INTEGRAL PART OF THE COMPUTERS. RELYING ON THE DECISIONS OF ITAT MUMBAI IN THE CASE OF VENTURE INFOTEK GLOBAL LTD. V.DCIT (2008 - TIOL - 526 - ITAT - MUM) THE AO REJECTED THE CONTENTION OF THE ASSES SEE THAT IT IS COMPUTER AND HENCE , TREATED THE SAME AS PLANT AND MACHINERY AND ALLOWED THE DEPRECIATION @15% AS AGAINST THE CLAIM OF 60% AND ACCORDINGLY DISALLOWED THE SUM OF RS.1,27,80,000/ - . 4. AGAINST WHICH THE ASSESSEE WENT ON APPEAL BEFORE THE CIT(A) AND THE LD.CIT(A) HELD THAT THE AO HA S DEMONSTRATED THAT THE INPUT DEVICES CAN FUNCTION INDEPENDENTLY WITHOUT COMPUTERS, THEREFORE, CONFIRMED THE ADDITION MADE BY THE AO AND DISMISSED THE APPEALS OF THE ASSESSEE. 5. AGAINST WHICH THE ASSESSEE FILED APPEAL BEFORE THIS TRIBUNAL AND RELIED ON THE FOLLOWING CASE LAWS. I) DATA CRAFT INDIA LTD. [133 ITJ 0377 (MUM TRIBUNAL)] II) JOKAI INDIA LTD. [251 ITR 39] III) CACTUS IMAGING INDIA (P) LTD. [2018) 40 6 ITR 406 (MADRAS)] IV) SE SA RESOURCES LTD. [404 ITR 707] V) SARASWAT INFOTECH [ITA NO.3606/MUM/2011/A.Y.2008 - 09] 6. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE MATERIAL PLACED ON RECORD. THE ASSESSEE HAS PURCHASED BIOMETRIC DEVICES FOR AADHAR ENROLM ENT, FINGER PRINT CUM IRIS ENROLMENT USED TO ENROLL LARGE GROUPS OF PEOPLE FOR 4 S.A. NO. 49 /VIZ/2020 AND I.T.A. 2 28 /VIZ/2020,A.Y. 20 13 - 14 INSTRUMENT TECHNOLOGIES , VISAKHAPATNAM CERTAIN SCHEMES MOSTLY PROMOTED BY GOVERNMENT AND NGOS. THEY ARE WIDELY USED FOR ENROLLING CITIZENS BY LOCAL OR CENTRAL GOVERNMENT ORGANIZATIONS , UID AADHAR, NPR, NATIONAL ID PROJECTS, WORLD BANK AND UNESCO SCHEMES. 6.1. IN THE INSTANT CASE, THE LD.DR SUBMITTED THAT BIOMETRIC DEVICES CAN INDEPENDENTLY FUNCTION AND ARE NOT INTEGRAL PART OF COMPUTERS, THEREFORE, ARGUED THAT HIGHER DEPRECIATION IS NOT ALLOWABLE. WHEREAS, THE LD.A R SUBMITTED THAT UNLESS THE BIO METRIC DEVICES ARE ATTACHED TO THE COMPUTER, THE SAME CANNOT FUNCTION INDEPENDENTLY AND THE OUTPUT CANNOT BE TAKEN. THE AO IN HIS ORDER ELABORATED THE BIOMETRICS AS UNDER: 3.2. BIOMETRICS IS THE IDENTIFICATION OF A PERSON BY THE MEASUREMENT OF THEIR BIOLOGICAL FEATURES. WHEN COMPARED TO A PASSWORD, THIS TYPE OF SYSTEM IS MUCH MORE DIFFICULT TO FAKE SINCE IT IS UNIQUE TO THE PERSON. A BIOMETRIC INPUT DEVICE MEASURES A UNIQUE PHYSICAL CHARACTERISTIC OF A PERSON. THE MOST COMM ON BIOMETRIC DEVICES ARE USED TO INPUT A PERSONS FINGERPRINT INTO A COMPUTER. MORE SOPHISTICATED DEVICES USE A CAMERA TO INLAND DESCRIPTION OF A PERSON'S IRIS (THE COLOUR ED PART OF EYE). 3.3. BIOMETRIC DEVICES ARE USUALLY USED FOR SECURITY PURPOSES A RECORD OF A PERSONS FINGERPRINT OR IRIS PATTERN IS STORED IN A DATABASE. LATER ON THE IDENTITY OF A PERSON CAN BE DETERMINED BY RESCANNING THE FINGER OR EYE AND LOOKING UP THE RESULTS OF THE SCAN IN THE DATABASE. BIOMETRIC DEVICES PROVIDE A VERY RELIABLE WAY OF IDENTIFYING PEOPLE. A BIOMETRIC KIT USUALLY CONTAINS A LIVE SCAN FOR TEN FINGERPRINT CAPTURE, A HIGH SPEED DUAL IRIS SCANNER AND IN ADDITION A WEB CAMERA FOR CAPTURING PHOTOGRAPHS. THE COMPONENTS OF A BIOMETRIC DEVICE USUALLY INCLUDE AN INPUT DEVICE , A DATABASE CONTAINING POTENTIAL MATCHES, AND A CONTROL PROGRAM TO DETERMINE THE ACTION BASED ON AUTHENTICATION RESULTS. 3.4 AADHAR ENROLLMENT KITS (FINGERPRINT CUM IRIS ENROLLRNENT KIT) ARE GENERALLY USED TO ENROLL LARGE GROUPS OF PEOPLE FOR CERTAIN SCH EMES MOSTLY PROMOTED BY GOVERNMENT &NGOS. THEY ARE USED WIDELY FOR ENROLLING CITIZENS BY LOCAL OR CENTRAL GOVERNMENT ORGANIZATIONS, UID AADHAR . 5 S.A. NO. 49 /VIZ/2020 AND I.T.A. 2 28 /VIZ/2020,A.Y. 20 13 - 14 INSTRUMENT TECHNOLOGIES , VISAKHAPATNAM 6.2. THE ASSESSEE SUBMITTED THE DETAILED WRITE UP BEFORE THE LD.CIT(A) WITH REGARD TO BIOMETRIC USAGE AS UNDER: 1. 3MTM CIS 202 HIGH SPEED DUAL IRIS SCANNER THE ABOVE MACHINE IS A HIGH SPEED LEIS IMAGE CAPTURE DEVICE THAT CAN SIMULTANEOUSLY CAPTURE BOTH EYE RISES IN LESS THAN 2 SECOND. COMPLIANT WITH N I ST SAP LEVEL 40% CIS 202 GAS NEAR INFRA RED ILLUMINATOR, LED LIGHTING AND BUILT IN SPECTRAL IMAGING SENSITIVITY CONTROL TO CAPTURE LIGHT IN THE RANGE OF 700 TO 900 NINO METERS. CIS 202 IMAGE OUTPUT MEET INDUSTRY INTERCHANGE FORMAT SPECIFICATION BY SUPPORTING ANSI N I ST TYPE 47 RECORDS, WITH RAW IMAGES CON F ORMAN T TO I SO 979 4 - 6 RECTILINEAR IMAGE STANDARDS. 2 . 3M RM CS500E LIVE SCAN SYSTEM : THIS IS A CO PRINT LIVE SCAN DEVICE IS A LIGHT WEIGHT SCANNER CA PA BLE O F PERF O RMING R OLD AND FLAT FINGERPRINT IMAGES. 3. BIOMETRIC I NPUT DEVICES : A BIOMETRIC INPUT DEVICE MEASURES A UNIQUE PHYSICAL CHARACTERISTIC OF A PERSON. THE MOS T COMMON BIOMETRIC DEVICES ARE USED TO INPUT A PERSON S FINGERPRINT INTO A COMPUTER. MORE SOPHISTICATED DEVICES USE A CAMERA TO INPUT A DESCRIPTION OF A PERSON S IRIS (T HE COLORED PART OF THE EYE). BIOMETRIC DEVICES ARE USUALLY USED FOR SECURITY PURPOSES. A RECORD OF A PERSON S FINGERPRINT OR IRIS PATTERN IS STORED IN A DATABA S E. LATER ON THE IDENTITY OF A PERSON CA N BE DETERMINED BY RE - SCANNING THE FINGER OR EYE AND LOOK ING UP THE RESULTS OF THE SCAN IN THE DATABASE. BIOMETRIC DEVICES PROVIDE A VERY RELIABLE WAY OF IDENTI FY ING PEOPLE. THERE ARE MANY KINDS OF BIOMETRIC INPUT DEVICES THAT YOU CAN USE WITH YOUR COMPUTER, AND THESE BIOMETRIC SECURITIES INPU T DEVICES ARE ALL DESIGNED WITH A SINGLE PURPOSE IN MIND SECURITY. THE WAY A BIOMETRIC MOUSE, FIN G ERPRINT INPUT KEYBOARD, BIOMETRICS, SCANNER, BIOMETRIC SOFTWARE, AND BIOMETRICS INPUT READER WORKS TO ENHANCE YOUR COMPUTER SECURITY IS BY LOCKING EVERYTHING ON THE C O MP UT ER D OWN TIGHTLY. THE WORLD OF C OM PUTERS, THE INTEREST, AND DIGITAL INFORMATION IS MUCH LE S S SECURE THAN IT ONCE WAS, AS MORE AND MORE COMPUTER HACKERS AND DATA THIEVES ARE FINDING THE DIGITAL WORLD IS MUCH EASIER TO STEAL FROM THAN THE REAL WORLD. MORE AND MOR E PEOPLE ARE BEING FORCED TO UPGRADE THEIR COMPUTER INPUT SECURITY DEVICES, AND BIOMETRICS IS, ONE OF THE BEST WAYS TO DO IT EASILY. 6 S.A. NO. 49 /VIZ/2020 AND I.T.A. 2 28 /VIZ/2020,A.Y. 20 13 - 14 INSTRUMENT TECHNOLOGIES , VISAKHAPATNAM BIOMETRIC INPUT DEVICES: THE REASON THAT BIOMETRICS INPUT SYSTEMS ARE SUCH A GOOD CHOKE FOR UPGRADING YOUR SECURITY IS THA T THEY ARE MUCH MORE DIFFICULT TO CRACK THAN A PASSWORD OR ALPHANUMERICAL KEY. SEEING AS EACH PERSON AROUND THE WORLD HAS A UNIQUE BIOMETRIC SIG NATURE THAT NO ONE IN THE WORLD CAN MATCH , THERE I S LITTLE RISK THAT ANYONE ELSE WILL BE ABLE TO DUPE THE SYSTE M. IN ORDER TO CRACK A N INPUT BIOMETRIC SECURITY SYSTEM, THE ACTUAL BIOMETRICS INPUT SIGNATURE OF THE PARSON WILL USED TO BE COPIED AND DUPLICATED IN ORDER TO GAIN ACCESS. UNLESS YOU ARE A MILLIONAIRE OR SOMEONE WHO KEEPS INCREDIBLY SENSITIVE PERSONAL INFORMATION ON YOUR COMPUTER, I T IS HIGHLY UNLIKELY THAT A THIEF WILL' BE INTERESTED ENOUGH IN STEALING YOUR DATA IF YOU USE A BIOMETRICS COMPUTER SECURITY SYSTEM OF SOME SOR T. BIOMETRIC INPUT SECURITY DEVICES ARE AN EXCELLENT BACKUP TO HAVE FOR YOUR COMPUTER, AS THEY HELP TO PROTECT YOUR COMPUTER AGAINST INTRUSION AND DATA THEFT FROM THE OUTSIDE. WHILE THERE IS LITTLE THAT BIOMETRICS SECURITY CAN DO TO PREVENT VIRUSES OR SPENT W ARE FROM TAKING OVER YOUR COMPUTER, YOU WILL FIND THAT THE SYSTEM WILL BE MORE THAN ENOUGH TO KEEP THIEVES FROM PHYSICALLY GETTING ON YOUR COMPUTER AND STEALING PERSONAL INFORMATION AND SENSITIVE DATA. BIOMETRIC INPUT SECURITY DEVICES SUCH AS THE BIOMETRIC S KEYBOARD OR BIOMETRICS MOUSE ARE DESIGNED TO ENHANCE YOUR COMPUTER'S SECURITY BY PROVIDING EXTRA LAYER OF PROTECTION. WHILE YOU MAY HAVE A COMPLEX PASSWORD THAT NO ONE WILL EVER THINK TO CRACK, HAVING AN EXTRA LAYER OF BIOMETRIC INPUT SECURITY ON TOP OF YOU R SAFETY PRECAUTIONS CANT HURT. ONCE YOU HAVE PLUGGED IN YOUR U S B FINGERPRINT KEYBOARD OR MOUSE, THE COMPUTER IS LOCKED UNTIL YOUR FINGERPRINT IS SCANNED ONCE MORE AND YOU ARE AUTHORIZED BY THE BIOMETRIC SOFTWARE RUNNING THE SECURITY PROGRAM. IT WON T MATTER IF YOUR BIOMETRIC DEVICES ARE UNPLUGGED: THE BIOMETRIC SOFTWARE IN THE COMPUTER WILL KEEP THE COMPUTER LOCKED UNTIL YOU HAVE SCANNED YOUR FINGERS AND GAINED ACCESS TO THE SOF TW ARE. IN THE END, THE BIOMETRIC INPUT - DEVICES ARE SOME OF THE MOST PRACTI CAL INPUT SYSTEMS THAT YOU CAN USE TO KEEP YOUR COMPUTER S AF E. THE F A CT OF THE MATTER IS THAT A FINGERPRINT INPUT KEYBOARD OR BIOMETRICS MOUSE CONNECTED TO YOUR COMPUTER CAN DO FAR MORE THAN ANTI 34 CHARACTER PASS WORD, AS THERE IS ONLY ONE PERSON THAT WIL L EVER B E ABLE TO GAIN ACCESS TO YOUR CO M PUTER WHEN YOU ARE USING THESE INPUT DEVICES WITH BIOMETRICS INTEGRATED FOR SECURITY.' 6.3. WE FIND FROM ABOVE THAT THE BIOMETRIC SYSTEM FUNCTIONS INDEPENDENTLY AND CAPTURES THE INFORMATION, HOWEVER, IT NEEDS TO B E ATTACHED TO THE COMPUTER WITH SOFTWARE TO TAKE THE OUTPUT. A A DHAAR ENROLMENT PROJECT IS TO PROVIDE UNIQUE IDENTIFICATION TO EVERY CITIZEN OF INDIA AND TO ISSUE 7 S.A. NO. 49 /VIZ/2020 AND I.T.A. 2 28 /VIZ/2020,A.Y. 20 13 - 14 INSTRUMENT TECHNOLOGIES , VISAKHAPATNAM IDENTIFICATION CARDS TO ALL THE CITIZENS. WITHOUT THE OUT PUT THE PROJECT DOES NOT SERVE THE PURPOSE FOR WHICH IT IS INTENDED. THUS, WITHOUT COMPUTER SYSTEM, AADHAR ENROLMENT KIT IS NOT USEFUL. 6.4. HONBLE MADRAS HIGH COURT IN THE CASE OF CIT VS. CACTUS IMAGING INDIA (P) LTD. [2018) 406 ITR 406 (MADRAS)] HELD THAT THE COMPUTER PRINTERS BEING PAR T OF COMPUTER IS ELIGIBLE FOR HIGHER RATE OF DEPRECIATION @60%. WHILE DEALING WITH THE ISSUE, THE HONBLE MADRAS HIGH COURT APPLYING THE RULE OF INTERPRETATION OBSERVED THAT ENTRY IN APPENDIX I CLAUSE III(5) STATES COMPUTERS INCLUDING COMPUTER SOFTWARE AND THE NOTES UNDER THE APPENDIX DEFINES THE COMPUTER SOFTWARE IN CLAUSE7 TO MEAN ANY COMPUTER PROGRAM RECORDED ON DISC, TAPE, PERFORATED MEDIA OR OTHER INFORMATION STORAGE DEVICE. THE COMPUTER WAS NOT DEFINED IN THE ACT. THEREFORE, H ON BLE H IGH C OURT VIEWED THAT IF A PARTICUL AR ARTICLE FALL S WITHIN THE DESCRIPTION BY THE FORCE OF WORDS USED, IT IS IMPERMISSIBLE TO IGNORE THE WORD DESCRIPTION. THUS, THE HONBLE HIGH COURT HELD THAT THE PRINTER IS INTEGRAL PART OF THE COMPUTER AND ACCORDINGLY HELD THAT IT IS ELIGIBLE FOR DEPREC IATION @60%. FOLLOWING THE DECISION OF HONBLE MADRAS HIGH COURT, IN THE INSTANT CASE, THOUGHT THE BIOMETRIC KIT IS CAPABLE OF CAPTURING THE DATA, IT NEEDS THE COMPUTER FOR TAKING OUTPUT. 8 S.A. NO. 49 /VIZ/2020 AND I.T.A. 2 28 /VIZ/2020,A.Y. 20 13 - 14 INSTRUMENT TECHNOLOGIES , VISAKHAPATNAM 6.5. HONBLE MUMBAI SPECIAL BENCH IN THE CASE OF DATA CRAFT INDIA LTD. (2010) 40 SOT 295 CONSIDERED THE ISSUE S OF COMPUTER AND THE COMPUTER SYSTEMS AND HELD THAT ROUTER IS A NETWORKING DEVI C E, WHOSE SOFTWARE AND HARDWARE ARE CUSTOMIZED TO THE TASK OF ROUTING AND FORWARDING INFORMATION AND HELD THAT THE SWITCHES CAN BE C LASSIFIED AS COMPUTER HARDWARE WHEN THEY ARE USED ALONG WITH THE COMPUTER AND WHEN THEIR FUNCTIONS ARE INTEGRATED WITH THE COMPUTER. IN SIMPLE WORDS, WHEN DEVICE USED AS THE PART OF COMPUTER IN ITS FUNCTIONS, THEN IT WOULD BE TERMED AS COMPUTER. IF WE APP LY THE REASONING GIVEN BY THE HONBLE MADRAS HIGH COURT AND THE DECISION OF HONBLE SPECIAL BENCH OF MUMBAI TRIBUNAL, BIOMETRIC DEVICE I S USED ALONG WITH THE COMPUTER AND FITS ALSO IN TO THE DEFINITION OF COMPUTER. 6.6. IF THE BIOMETRIC SYSTEM IS DETACHE D FROM THE COMPUTER, THE SAME DOES NOT SERVE THE PURPOSE FOR WHICH IT IS INTENDED. EVEN IN THE BIOMETRIC SYSTEM ALSO, WEAR AND TEAR IS VERY HIGH LIKE COMPUTER. AS PER THE INTERPRETATION OF HONBLE MADRAS HIGH COURT IN THE CASE SUPRA THE FUNCTIONING OF BIO METRIC D EVICE FITS INTO THE COMPUTER AND ELIGIBLE FOR HIGHER RATE OF DEPRECIATION . THEREFORE, WE HOLD THAT BIO METRIC SYSTEM IS A COMPUTER AND THE DEPRECIATION REQUIRED TO BE ALLOWED AT HIGHER RATE. ACCORDINGLY, WE SET ASIDE THE ORDERS OF THE LD.CIT(A) AND ALLOW T HE APPEAL OF THE ASSESSEE. 9 S.A. NO. 49 /VIZ/2020 AND I.T.A. 2 28 /VIZ/2020,A.Y. 20 13 - 14 INSTRUMENT TECHNOLOGIES , VISAKHAPATNAM 7. IN THE RESULT, STAY APPLICATION OF THE ASSESSEE IS DISMISSED AND THE APPEAL OF THE ASSESSEE IS ALLOWED . ORDER PRONOUNCED IN THE OPEN COURT ON 6 TH J ANUARY, 2021 . S D/ - S D/ - ( . ) ( . . ) (V. DURGA RAO) ( D.S. SUNDER SINGH ) /JUDICIAL MEMBER /ACCOUNTANT MEMBER /DATED : 06.01.2021 L.RAMA, SPS / COPY OF THE ORDER FORWARDED TO : - 1 . / THE ASSESSEE INSTRUMENT TECHNOLOGIES , D.NO.50 - 63 - 03, GAYATRI NILAYAM, RAJENDRA NAGAR, SEETHAMMAPETA, VISAKHAPATNAM 2 . / THE REVENUE ASST.COMMISSIONER OF INCOME TAX, CIRCLE - 3(1) VISAKHAPATNAM 3. THE PR.COMMISSIONER OF INCOME TAX - 1 , VISAKHAPATNAM 4. THE COMMISSIONER OF INCOME TAX (APPEALS) - 1 , VISAKHAPATNAM 5 . , , / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // SR. PRIVATE SECRETARY ITAT, VISAKHAPATNAM