ANAND I POWER LTD. (FORMERLY KNOWN AS PERFECT CIRCLE INDIA LTD.), MUMBAI V. DCIT RANGE 5(2), MUMBAI

ITA 2281/MUM/2016

• Counselvise Citation: [2018] 125 COUNSELVISE.COM (IT) 9921 (ITAT-MUMBAI)
• Duration Of Justice: 1 year(s) 10 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-03-2018
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Not Allotted
• Assessment Year: 2011-2012
• Appeal Filed On: 28-04-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: POOJA SWAROP
• Assessee Lawyers: PRASAD BAPAT
• Keywords: Gift
• Section: 143(3)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH F, MU MBAI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER ITA NO.2281/MUM/2016 (ASSESSMENT YEAR- 2011-12) ANAND I POWER LTD. (FORMERLY KNOWN AS PERFECT CIRCLE INDIA LTD.), 10, PRASAD CHAMBERS, OPERA HOUSE, MUMBAI-400004 PAN:AAACP0482E VS. DCIT RANGE -5(2) AAYAKAR BHAVAN, M.K. ROAD, MUMBAI-20. (APPELLANT) (RESPONDENT) ASSESSEE BY : SHRI PRASAD BAPAT (AR) REVENUE BY : MS. POOJA SWAROP (DR) DATE OF HEARING : 13.03.2018 DATE OF PRONOUNCEMENT : 13.03.2018 ORDER UNDER SECTION 254(1) OF INCOME TAX ACT PER PAWAN SINGH, JUDICIAL MEMBER: 1. THIS APPEAL BY ASSESSEE UNDER SECTION 253 OF INCOME TAX ACT (THE ACT) IS DIRECTED AGAINST THE ORDER OF LD. COMMISSIONER OF I NCOME-TAX (APPEALS)- 10, MUMBAI, [FOR SHORT THE LD. CIT(A)] DATED 18.01. 2016 FOR ASSESSMENT YEARS 2011-2012. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS OF AP PEAL: BEING AGGRIEVED BY THE ORDER PASSED BY THE COMMISSI ONER OF INCOME TAX (APPEALS) -10 (CIT(A), FOR SHORT),), MUMBAI, YOUR A PPELLANT SUBMITS THE FOLLOWING GROUNDS OF APPEAL FOR YOUR SYMPATHETIC CO NSIDERATION: 1) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E AND IN LAW, THE LEARNED CIT(A) ERRED IN CONFIRMING DISALLOWANCE OF INR 39,8 8,000 BEING 20% OF THE PROFESSIONAL FEES PAID TO ANAND AUTOMOTIVE SYST EMS LTD OF INR 1,99,40,000 BY TREATING IT AS NOT INCURRED WHOLLY A ND EXCLUSIVELY FOR BUSINESS PURPOSE. 2) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E AND IN LAW, THE LEARNED CIT(A) ERRED IN CONFIRMING DISALLOWANCE OF INR 95,6 7,000 BEING 20% OF THE ADVERTISEMENT AND PUBLICITY EXPENSES OF INR 4,7 8,35,000 BY TREATING AS NOT INCURRED WHOLLY AND EXCLUSIVELY FOR THE PURP OSE OF BUSINESS. 3) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E AND IN LAW, THE LEARNED CIT(A) ERRED IN CONFIRMING DISALLOWANCE OF INR 35,8 6,000 BEING 20% OF ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 2 THE SHARE OF COMMON MARKETING EXPENSES OF INR 1,79, 30,000 BY TREATING IT AS NOT INCURRED WHOLLY AND EXCLUSIVELY FOR THE P URPOSE OF BUSINESS. 4) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E AND IN LAW, THE LEARNED CIT(A) ERRED IN CONFIRMING THE DISALLOWANCE OF INR 13,47,200 BEING 20% OF THE COMMISSION AND DISCOUNT OF INR 57,74,000 AND INR 9,62,000 RESPECTIVELY BY TREATING IT AS NOT INCURRED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS. 2. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE-COMPA NY IS ENGAGED IN THE BUSINESS OF MANUFACTURING PISTON RINGS AND SEMI-FIN ISHED CASTINGS, FILED ITS RETURN OF INCOME FOR ASSESSMENT YEAR 2011-12 ON 28.09.2011 DECLARING TOTAL INCOME OF RS. 4,21,15,198/-. THE ASSESSMENT W AS COMPLETED ON 27.02.2014 UNDER SECTION 143(3) OF THE ACT. THE ASS ESSING OFFICER WHILE PASSING THE ASSESSMENT ORDER MADE THE DISALLOWANCE OF 20% OF PROFESSIONAL FEES, ADVERTISEMENT AND PUBLISHING EXPENSES, COMMON MARKETING EXPENSES AND COMMISSION AND DISCOUNT. ON APPEAL BEFORE THE L D. CIT(A), ALL THE DISALLOWANCES @ 20% MADE BY ASSESSING OFFICER WAS C ONFIRMED. THUS, FURTHER AGGRIEVED BY THE ORDER OF LD. CIT(A), THE A SSESSEE HAS FILED THE PRESENT APPEAL BEFORE US. 3. WE HAVE HEARD THE LD. AUTHORIZED REPRESENTATIVE (AR ) OF THE ASSESSEE AND LD. DEPARTMENTAL REPRESENTATIVE (DR) FOR THE REVENU E AND PERUSED THE MATERIAL AVAILABLE ON RECORD. THE LD. AR OF THE ASS ESSEE SUBMITS THAT THE ASSESSING OFFICER DISALLOWED THE PROFESSIONAL FEES, ADVERTISEMENT EXPENSES, SHARE OF COMMON MARKETING EXPENSES AND CO MMISSION & DISCOUNT @ 20%. ALL DISALLOWANCE WAS MADE ON ADHOC BASIS AND WITHOUT ANY SPECIFIC REASONS. THE ASSESSEE HAS EXPLAINED TH E NATURE OF EXPENSES AND THEIR JUSTIFICATION. ON THE OTHER HAND, THE LD. DR FOR THE REVENUE SUPPORTED ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 3 THE ORDER OF AUTHORITIES BELOW. THE LD. DR FOR THE REVENUE FURTHER SUBMITS THAT THE ASSESSEE FAILED TO PROVIDE THE NATURE OF S ERVICES RELATED WITH ALL THE EXPENSES. THE LOWER AUTHORITY HAS REASONABLY DISALL OWED THE EXPENSES WHICH CONSIST OF PROFESSIONAL FEES, ADVERTISEMENT E XPENSES, MARKETING EXPENSES AND COMMISSION AND BROKERAGE. 4. WE HAVE CONSIDERED THE SUBMISSION OF THE PARTIES AN D HAVE PERUSED THE MATERIAL AVAILABLE ON RECORD. GROUND NO.1 RELATES T O DISALLOWANCE OF 20% OF LEGAL & PROFESSIONAL FEES PAID TO ANAND AUTOMOTI VE SYSTEMS LTD. DURING THE ASSESSMENT, THE ASSESSING OFFICER NOTED THAT THE ASSESSEE HAS DEBITED AN AMOUNT OF RS. 1,99,40,000/- UNDER THE HE AD LEGAL & PROFESSIONAL FEE PAID TO ANAND AUTOMOTIVE SYSTEMS L TD. THE ASSESSEE WAS ASKED TO JUSTIFY IF THE EXPENSES WERE INCURRED WHO LLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS. THE ASSESSEE FILED ITS REP LY DATED 19.02.2014. IN THE REPLY THE ASSESSEE CONTENDED THAT THE ASSESSEE AVAILED SERVICES FROM ANAND AUTOMOTIVE SYSTEMS LTD. IN RELATION TO AREA M AINLY HUMAN RESOURCES DEVELOPMENT AS WELL AS MARKETING MATTERS, TRAINING PROGRAMME AND DEALERS MEET FOR PROVIDING ASSISTANCE TO ARRANG E LONG TERM SALES, CAPITAL NEED FROM FINANCIAL INSTITUTION LIKE BANKS, ADVERTI SING MATERS OF STRATEGIC ISSUE, KEY BUSINESS DECISION AND CORPORATE RELATION AND COMMUNICATION. THE ASSESSEE ALSO FURNISHED THE AGREEMENT WITH THE ANAND AUTOMOTIVE SYSTEMS LTD., THE ASSESSEE FURTHER CONTENDED THAT D UE TO SPECIAL KNOWLEDGE AND GUIDANCE OF ANAND AUTOMOTIVE SYSTEMS LTD., THE SALE OF ASSESSEE WAS ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 4 INCREASED FROM RS. 78.22 CRORE TO 104.17 CRORE WHIC H RESULTED IN INCREASED IN PROFIT FROM RS. 7.36 CRORE TO 8.56 CRORE. THE CO NTENTION OF THE ASSESSEE WAS NOT ACCEPTED BY THE ASSESSING OFFICER. THE ASSE SSING OFFICER CONCLUDED THAT ASSESSEE FAILED TO GIVE EXACT NATURE AND QUANTUM OF SERVICES RENDERED BY ANAND AUTOMOTIVE SYSTEMS LTD. AND DISAL LOWED 20% OF THE EXPENDITURE OUT OF TOTAL PAID AMOUNT DEBITED UNDER THE HEAD LEGAL & PROFESSIONAL FEE OF RS. 1,99,40,000/-. THE ASSESSIN G OFFICER WORKED OUT THE DISALLOWANCE TO RS. 39,88,000/-. DURING THE COU RSE OF FIRST APPELLATE STAGE, THE LD. CIT(A) OBSERVED THAT ANAND AUTOMOTIV E SYSTEMS LTD. IS SISTER CONCERN OF THE ASSESSEE. THE ASSESSEE HAS NO T JUSTIFIED THE EXPENSES INCURRED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS. THE ASSESSEE FAILED TO GIVE EXACT NATURE AND TYPE OF SERVICES RE NDERED BY ITS GROUP CONCERN AND CONCUR THAT THE DISCRETION APPLIED BY A SSESSING OFFICER IN MAKING DISALLOWANCE AT 20% OF EXPENDITURE. WE HAVE NOTED THAT ASSESSEE HAS PLACED ON RECORD THE CORPORATE SERVICES AGREEME NT ENTERED BY ASSESSEE- COMPANY WITH ANAND AUTOMOTIVE SYSTEMS LTD., COPIES OF WHICH AVAILABLE AT PAGE NO. 56 TO 63 OF PAPER BOOK. DETAILS OF PROF ESSIONAL FEES ARE PROVIDED AT PAGE NO. 64 TO 71 OF PAPER BOOK. THE PE RUSAL OF CORPORATE SERVICES AGREEMENT REVEALS THAT THE ASSESSEE AND IT S SISTER CONCERN I.E. ANAND AUTOMOTIVE SYSTEMS LTD. ENTERED FOR PROVIDING HUMAN RESOURCES DEVELOPMENT SERVICES, MARKETING, FINANCE, LEGAL AND TAXATION, OPERATION REVIEW, CORPORATE OFFICE FACILITIES, GOVERNMENT LIC ENSE, CORPORATE RELATION ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 5 AND COMMUNICATION SUPPORT AND ASSISTANCE IN CORPORA TE AREAS ETC. THE LOWER AUTHORITY HAS NOT DISPUTED THE EXECUTION CORP ORATE SERVICES AGREEMENT. THE LD. CIT(A) IN ITS ORDER HAS REFERRED THAT THERE IS NO SPECIFIC ACTIVITIES, WHICH THE ASSESSEE-COMPANY ITSELF CANNO T TAKE CARE OF AND THE NEED OF ASSISTANCE OF SISTER CONCERN AND THAT THE C ORPORATE SERVICE AGREEMENT IS VAGUE. WE HAVE NOTED THAT NEITHER THE ASSESSING OFFICER NOR THE LD. CIT(A) HAS BRING ANY COGENT MATERIAL ON REC ORD WHILE MAKING ADHOC DISALLOWANCE @ 20% OF EXPENDITURE. THE ASSESS ING OFFICER OR THE LD. CIT(A) HAS NOT REFERRED ANYWHERE THAT NO SUCH S ERVICES AS REFERRED IN THE CORPORATE SERVICE AGREEMENT, IS UNDERTAKEN BY T HE ANAND AUTOMOTIVE SYSTEMS LTD. NO SPECIFIC REASON IS IDENTIFIED FOR M AKING ADHOC DISALLOWANCE ONLY. FURTHER, NO SPECIFIC REASON IS M ENTIONED AS TO WHY THE DISALLOWANCES MADE @ 20% ONLY. AVAILING OF SUCH SER VICES FROM THE GROUP CONCERN IS NOT UN-COMMON. THE LOWER AUTHORITIES HAV E NOT IDENTIFIED, IF THE PAYMENTS MADE TO RELATED PARTY IS UNREASONABLE. NO COMPARABLE ON REASON CUM INDUSTRY IS REFERRED BY LOWER AUTHORITIES. MOR EOVER, WE HAVE SEEN THAT LEGAL & PROFESSIONAL FEES IS ONLY 2.02% OF THE SALE S. THUS, WE DO NOT FIND ANY JUSTIFICATION IN PARTIAL DISALLOWANCE OF LEGAL AND PROFESSIONAL EXPENSES, WHICH WE DELETE. IN THE RESULT THE GROUND NO.1 OF THE APPEAL IS ALLOWED. 5. GROUND NO.2 RELATES TO 20% OF DISALLOWANCE OF ADVER TISEMENT AND PUBLICITY EXPENSES. THE ASSESSING OFFICER DURING THE ASSESSME NT PROCEEDING ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 6 DISALLOWED THE 20% OF ADVERTISEMENT EXPENSES OUT OF RS. 4,78,35,000/- DEBIT IN THE PROFIT & LOSS ACCOUNT. THE ASSESSING O FFICER DISALLOWED HOLDING THAT NO PROPER JUSTIFICATION AND SUPPORTING DOCUMENTARY EVIDENCE IS PRODUCED BY THE ASSESSEE. THEREFORE, AN AMOUNT O F 20% OF RS. 4,78,35,000/- I.E. RS. 95,67,000/- WAS DISALLOWED. THE LD. CIT(A) CONFIRMED THE ACTION OF ASSESSING OFFICER BY OBSERV ING THAT THE ASSESSEE FAILED TO FURNISH REQUIRE DETAILS THAT IN SUBSTANTI ATING THAT EXPENDITURE WAS WHOLLY AND EXCLUSIVELY INCURRED OF THE PURPOSE OF R UNNING THE BUSINESS. BEFORE THE TRIBUNAL, THE ASSESSEE HAS PLACED ON REC ORD THE LEDGER ACCOUNT ON ACCOUNT OF ADVERTISEMENT AND PUBLICITY EXPENSES (PAGE NO. 72 TO 83 OF PAPER BOOK). THE ASSESSEE HAS CERTIFIED/VERIFIED TH AT THESE DOCUMENTS WERE FURNISHED TO THE LOWER AUTHORITY. WE HAVE NOTED THA T THE LOWER AUTHORITY HAS NOT GIVEN ANY FINDING ON THE DOCUMENTARY EVIDENCES FURNISHED BEFORE THEM. WE HAVE SEEN THAT THE ASSESSEE HAS SHOWN TO HAVE IN CURRED EXPENSES ON ADVERTISEMENT, GIFT, COUPONS, SIMPLE EXPENSES AND E XPORT EXPENSES. THE ASSESSING OFFICER DISALLOWED THE 20% ON THE BASIS O F HIS DISCRETION. THE LD. CIT(A) CONFIRMED THE DISALLOWANCE WITHOUT SPECI FYING ANY REASON. MOREOVER, THE LOWER AUTHORITIES HAVE NOT IDENTIFIED , IF THE PAYMENTS MADE TO RELATED PARTY IS UNREASONABLE, WE HAVE SEEN THAT ADVERTISEMENT AND PUBLICITY IS ONLY 4.30% OF THE SALES. IN ABSENCE O F ANY SPECIFIC REASON FOR DISALLOWANCE @ 20% OF THE EXPENSES, THE ADHOC DISAL LOWANCE IS NOT ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 7 SUSTAINABLE. HENCE, THE ADHOC DISALLOWANCE MADE BY ASSESSING OFFICER AND CONFIRMED BY LD. CIT(A) IS DELETED. 6. GROUND NO.3 RELATES TO DISALLOWANCE OF 20% OF SHARE OF COMMON MARKETING EXPENSES. THE ASSESSING OFFICER DISALLOWE D 20% OF MARKETING EXPENSES OUT OF RS. 1,79,30,000/- HOLDING THAT NO P ROPER JUSTIFICATION AND SUPPORTING DOCUMENTARY EVIDENCE WAS PRODUCED. THE S ECOND REASON FOR DISALLOWANCE BY ASSESSING OFFICER WAS THAT EARLIER YEARS ADDITION WAS PENDING BEFORE THE LD. CIT(A). BEFORE THE LD. CIT(A ), THE ASSESSEE- COMPANY URGED THAT THE ASSESSEE ENTERED IN AGREEMEN T WITH VICTOR GASKET INDIA LTD TO SHARE CERTAIN COMMON RESOURCES FOR MA RKETING AND THAT AMOUNT WERE PAID AS PER AGREEMENT. THE LD. CIT(A) C ONCURRED WITH THE DECISION OF ASSESSING OFFICER HOLDING THAT THE PERU SAL OF AGREEMENT WITH VICTOR GASKET INDIA LTD DATED 23.06.2009 RELATES T O ASSESSMENT YEAR 2010-11 AND THAT THERE IS NO SUCH AGREEMENT FOR ASS ESSMENT YEAR 2011-12, NOR THERE IS REFERENCE IN THE AGREEMENT REGARDING V ALIDITY OF AGREEMENT FOR THE ASSESSMENT YEAR UNDER CONSIDERATION. BEFORE US, THE ASSESSEE HAS PLACED ON RECORD THE COPIES OF FOUR AGREEMENTS W ITH VICTOR GASKET INDIA LTD. WITH REGARD TO SHARE OF COMMON MARKETING EXPEN SES, COPY OF WHICH ARE AVAILABLE AT PAGE NO. 84 TO 94 OF PAPER BOOK (F OUR AGREEMENTS). THE PERUSAL OF THE AGREEMENTS REVEALS THAT INITIAL AGRE EMENT WAS MADE BETWEEN THE ASSESSEE AND VICTOR GASKET INDIA LTD. ON 06.02. 2002 FOR PROVIDING MARKETING SERVICES TO ASSESSEE ALL OVER INDIA TO HA NDLE MECHANICAL SERVICE, ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 8 SALES PROMOTION, VAN CAMPAIGN AND TO SHARE THE EXPE NSES IN 60:40 RATIO. NO PERIOD OF VALIDITY OF AGREEMENT IS MENTIONED. FU RTHER, THE AGREEMENT WAS REVISED BY AGREEMENT DATED 05.08.2004, WHICH WA S FURTHER REVISED VIDE AGREEMENT DATED 27.05.2007. THE AGREEMENT DATED 27 .05.2007 WAS AGAIN REVISED VIDE AGREEMENT DATED 05.06.2009. IN AGREEME NT DATED 05.06.2009, THE ASSESSEE AND VICTOR GASKET INDIA LTD. AGREED TO SHARE 67% AND 33% OF THE MARKETING EXPENSES. INTERESTINGLY, NO PERIOD OF VALIDITY OF AGREEMENT IS MENTIONED IN THIS AGREEMENT AS WELL. WE HAVE NOTED THAT THE LOWER AUTHORITY HAS NOT DISPUTED THE EXPENSES INCURRED IN RELATION TO THE AGREEMENT, ONLY THE VALIDITY OF AGREEMENT WAS DISPU TED. THE LOWER AUTHORITY HAS NOT BROUGHT ANY MATERIAL ON RECORD TH AT PAYMENT INCURRED ON COMMON MARKETING EXPENSES IS IN-GENUINE OR UNREASON ABLE. CONSIDERING THE FACT THAT NEITHER ANY ADVERSE MATERIAL WAS BROU GHT ON RECORD NOR ANY SPECIFIC REASON WAS MENTIONED BEFORE DISALLOWING 20 % ONLY OF THE COMMON MARKETING EXPENSES. WE HAVE SEEN THAT SHARE OF COMMON MARKETING EXPENSES IS ONLY 1.61% OF THE SALES. HE NCE, WE DO NOT FIND ANY JUSTIFICATION IN MAKING ADHOC DISALLOWANCE @ 20% OF THE COMMON MARKETING EXPENSES. IN THE RESULT THIS GROUND OF AP PEAL IS ALLOWED. 7. GROUND NO.4 RELATES TO DISALLOWANCE OF 20% OF COMMI SSION DISCOUNT. THE ASSESSING OFFICER DISALLOWED THE 20% OF AMOUNT OF C OMMISSION AND DISCOUNT HOLDING THAT NO PROPER JUSTIFICATION AND S UPPORTING DOCUMENTARY EVIDENCE WAS FILED. THE LD. CIT(A) CONFIRMED THE DI SALLOWANCE WITH ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 9 SIMILAR OBSERVATION. BEFORE US, THE ASSESSEE HAS PL ACED ON RECORD THE LEDGER ACCOUNT OF COMMISSION, TURNOVER DISCOUNT, DETAILS O F CASH DISCOUNT TO VARIOUS PARTIES. COPY OF WHICH IS AVAILABLE AT PAGE NO. 95 TO 115 OF PAPER BOOK. THE ASSESSEE HAS FURTHER CERTIFIED/VERIFIED T HAT ALL THESE DOCUMENTS WERE PLACED BEFORE THE ASSESSING OFFICER/LD.CIT(A). WE HAVE NOTED THAT THE LOWER AUTHORITY HAS NOT GIVEN ANY FINDING ON TH ESE DOCUMENTARY EVIDENCES. THE LOWER AUTHORITY HAS NOT DISCARDED TH ESE DOCUMENTARY EVIDENCES BEFORE MAKING DISALLOWANCE/CONFIRMING THE SAME. WE HAVE FURTHER NOTED THAT THE LOWER AUTHORITY HAS NOT DISP UTED THE GENUINENITY OF THE PAYMENT. CONSIDERING THE FACT THAT NEITHER ANY ADVERSE MATERIAL WAS BROUGHT ON RECORD OR ANY SPECIFIC REASON WAS MENTIO NED BEFORE DISALLOWING 20% OF COMMISSION AND DISCOUNT PAYMENTS. THE LOWER AUTHORITIES HAVE NO IDENTIFIED THAT THE PAYMENT MADE ON ACCOUNT OF COMM ISSION AND DISCOUNT IS UNREASONABLE. IN OUR VIEW WHEN THE LOWER AUTHORITY HAS NEITHER DISPUTED THE GENUINENITY NOR GIVEN ANY SPECIFIC REASON FOR A DHOC DISALLOWANCE, THE DISALLOWANCE IS NOT JUSTIFIABLE. MOREOVER, WE HAVE SEEN THAT COMMISSION AND DISCOUNT IS ONLY 2.07% OF THE SALES. 8. IN THE RESULT, APPEAL FILED BY ASSESSEE IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 13 TH DAY OF MARCH 2018. SD/- SD/- ( SHAMIM YAHYA ) (PAWAN SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER MUMBAI; DATED 13/03/2018 S.K.PS ITA NO. 2281/MUM/20 16 - ANAND I POWER LTD. 10 COPY OF THE ORDER FORWARDED TO : BY ORDER (ASSTT.REGISTRAR) ITAT, MUMBAI 1. THE APPELLANT 2. THE RESPONDENT. 3. THE CIT(A), MUMBAI. 4. CIT 5. DR, ITAT, MUMBAI 6. GUARD FILE. //TRUE C