Nadeem Mahammed Abdul , Secunderabad V. Income Tax Officer, Ward-10(5) , Hyderabad

ITA 25/Hyd/2020

• Counselvise Citation: [2021] 109 COUNSELVISE.COM (IT) 7064 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 28-01-2021
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Next Hearing Date: 21-01-2021
• Assessment Year: 2015-2016
• Appeal Filed On: 07-01-2020
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Earning of tax free income; TDS; Set aside
• Section: 143(1); 143(2); 22; 20

Judgement Text

ITA NO 25 OF 2020 NADEEM MOHD ABDUL SECUNDERABAD PAGE 1 OF 8 IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD SMC BENCH, HYDERABAD (THROUGH VIDEO CONFERENCING) BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER ITA NO 25/HYD/2020 ASSESSMENT YEAR: 2015-16 SHRI NADEEM MOHD.ABDUL SECUNDERABAD PAN:ATAPA0329F VS. INCOME TAX OFFICER WARD 10(5) HYDERABAD (APPELLANT) (RESPONDENT) ASSESSEE BY: SRI K.A. SAI PRASAD REVENUE BY : SRI D.J.P. ANAND, DR DATE OF HEARING: 21/01/2021 DATE OF PRONOUNCEMENT: 28/01/2021 ORDER THIS IS ASSESSEES APPEAL FOR THE A.Y 2015-16 AGAIN ST THE ORDER OF THE CIT (A)-6, HYDERABAD, DATED 11.10. 2019. THE GROUNDS OF APPEAL RAISED BY THE ASSESSEE ARE AS UND ER: 1. THE ORDER OF THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) DISMISSING THE APPEAL, IN THE FACTS AND CIRCUMSTANCES OF THE CASE, IS NOT CORRECT BOTH ON F ACTS AND IN LAW. 2. IN THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) IS NOT JUSTIFI ED IN CONFIRMING THE ORDER OF THE ASSESSING OFFICER, WHO TREATED THE SUM OF RS.29,09,280 AS NON-AGRICULTURAL INCOME. 3. THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) FAILED TO APPRECIATE THE FACT THAT THE INCOME EARNED ON LE ASING OUT AGRICULTURAL LAND IS AGRICULTURAL INCOME. 4. THE VIEW/OBSERVATION OF THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) IN PARA 7.14 OF THE APPELLATE ORDER THAT THE APPELLANT IS NOT PRIMARILY AN AGRICULTURIS T ETC., IS NOT RELEVANT FOR DETERMINATION WHETHER THE APPELLANT'S ACTIVITY IS AGRICULTURAL OR NOT. 5. THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) FAILED TO APPRECIATE THE FACT THAT THE LESSEE-COMPANY DID AGRICULTURAL ACTIVITIES TO GROW AROMATIC, MEDICINAL PLANTS ITA NO 25 OF 2020 NADEEM MOHD ABDUL SECUNDERABAD PAGE 2 OF 8 ETC., AND THE LESSEE'S END USE OF THE PRODUCED PROD UCT DID NOT ALTER THE NATURE OF AGRICULTURAL ACTIVITY PARA 7.16 . 6 THE APPELLANT CRAVES LEAVE TO ADD, AMEND, DELETE OR SUBSTITUTE ANY ROUND OR ROUNDS DURING THE COURSE OF HEARING. 2. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE IN DIVIDUAL FILED HIS RETURN OF INCOME FOR THE A.Y 2015-16 ON 1 .1.2016 ADMITTING TOTAL INCOME OF RS.3,33,840/- AFTER CLAIM ING CHAPTER VIA DEDUCTION OF RS.1,10,000/-. THE ASSESSEE ALSO A DMITTED AGRICULTURAL INCOME OF RS.29,09,280/- AND OTHER INC OME OF RS.2,01,921/- UNDER EXEMPT INCOME CATEGORY. THE A SSESSEES RETURN OF INCOME WAS SELECTED FOR SCRUTINY UNDER CA SS TO EXAMINE THE ASSESSEES CLAIM OF AGRICULTURAL INCOME. ACCORD INGLY, NOTICES U/S 143(2) AND 143(1) WERE ISSUED TO THE ASSESSEE R EQUIRING THE ASSESSEE TO FURNISH CERTAIN INFORMATION. THE ASSESS EE FURNISHED SOME INFORMATION IN SUPPORT OF HIS CLAIM OF AGRICUL TURAL INCOME. AFTER PERUSAL OF THE SAME, THE AO OBSERVED THAT THE ASSESSEE IS HAVING AGRICULTURAL LAND OF 20 ACRES AND 10 GUNTAS IN SURVEY NO.426 AND 427 RESPECTIVELY AT KADAVERGU VILLAGE OF WARANGAL DISTRICT. APART FROM THIS, THE ASSESSEE HAS TAKEN O N LEASE 10 ACRES AND 21 GUNTAS OF DRY LAND SITUATED AT CHELLAMPALLY VILLAGE OF TALLAKONDAPALLY MANDAL, RANGA REDDY DISTT FROM ONE SHRI MOD.ABDUL AZEEM (LESSOR), VIDE LEASE DEED DATED 1.5 .2013 AND AGRICULTURAL LAND OF 10 ACRES AND 24 GUNTAS SITUATE D AT DEVETHPALLE VILLAGE, NAMPALLY MANDAL, RANGA REDDY D ISTT FROM ONE AVULA SREENU (LESSOR) VIDE LEASE DEED DATED 22 ND JULY, 2013. THUS, A TOTAL AGRICULTURAL LAND OF 41.15 ACRES SITU ATED AT DIFFERENT PLACES HAVE BEEN LEASED OUT BY THE ASSESSEE TO A CO MPANY BY NAME ADISA AGRO PVT. LTD, MUMBAI, VIDE LEASE DEED D ATED 30 TH SEPT.2013. HE OBSERVED FROM THE COPIES OF KHASRA PA HANI PRODUCED BY THE ASSESSEE, THAT THEY DID NOT SPECIFY ANY CROP ITA NO 25 OF 2020 NADEEM MOHD ABDUL SECUNDERABAD PAGE 3 OF 8 DETAILS. THE AO ALSO OBSERVED THAT THE ASSESSEE ALS O DID NOT PRODUCE ANY EVIDENCE REGARDING THE GROWING OF ANY C ROPS DURING THE PERIOD RELEVANT TO THE A.Y 2015-16 SUCH AS DETA ILS OF THE PARTIES FROM WHOM FERTILIZER, SEEDS ETC., WERE PROC URED AND ALSO THE DETAILS OF THE PARTIES TO WHOM AGRICULTURAL PRO DUCE WERE SOLD AND OTHER DETAILS RELATING TO THE EXPENDITURE WHICH IS LIKELY TO BE INCURRED FOR THE AGRICULTURE OPERATIONS BY THE ASSE SSEE. 3. THE AO ALSO OBSERVED THAT THE ASSESSEE IS NOT HA VING ANY AGRICULTURAL LAND TO CLAIM THAT HE HAS GOT AN A MOUNT OF RS.29,09,280/- FROM AGRICULTURAL ACTIVITIES AND AS THE LAND HE WAS HOLDING WAS EITHER ON LEASE OR LEASED TO ADISA AGRO PVT. LTD. HE ALSO OBSERVED FROM THE LEASE DEED ENTERED INTO WITH ADISA AGRO PVT LTD MUMBAI THAT THE LEASE RENT @ RS.40,000/- PER AC RE IS TO BE PAID TO THE ASSESSEE BUT THERE WAS NO TDS MADE BY A DISA AGRO P LTD. THEREFORE, HE REJECTED THE ASSESSEES CLAIM OF AGRICULTURAL INCOME AND TREATED THE INCOME AS INCOME FROM OTHER SOURCES AND BROUGHT IT TO TAX. AGGRIEVED, THE ASSESSEE PREF ERRED AN APPEAL BEFORE THE CIT (A) WHO CONFIRMED THE ORDER OF THE A O AND THE ASSESSEE IS IN SECOND APPEAL BEFORE THE TRIBUNAL. 4. THE LEARNED COUNSEL FOR THE ASSESSEE SUBMITTED T HAT THE ASSESSEE IS THE OWNER OF THE AGRICULTURAL LAND TO THE EXTENT OF 20 ACRES AND 10 GUNTAS IN WARANGAL DISTRICT AND HE HAS TAKEN CERTAIN OTHER LAND AT RANGA REDDY DISTRICT AND NALG ONDA DISTRICT ALSO ON LEASE FROM THE LANDOWNERS RESPECTIVELY AS R ECORDED BY THE AO IN HIS ASSESSMENT ORDER. HE SUBMITTED THAT THE A SSESSEE HAD BEEN CARRYING ON AGRICULTURAL ACTIVITY IN THESE LAN DS AND THE RECORDING OF THE AO THAT THE KHASRA PAHANI DID NOT MENTION ANY CROP DETAILS IS INCORRECT. HE HAS DRAWN MY ATTENTIO N TO THE ENTRIES ITA NO 25 OF 2020 NADEEM MOHD ABDUL SECUNDERABAD PAGE 4 OF 8 IN KHASRA PAHANI (REPRODUCED BY THE AO IN THE ASSES SMENT ORDER) WHEREIN THE NAME OF THE CROP IS MENTIONED AS MANGO. HE FURTHER SUBMITTED THAT THE LEASE DEED ENTERED INTO WITH ADI SA AGRO (P) LTD ALSO MENTIONS THE AGRICULTURAL OPERATIONS HAVING BE EN CARRIED ON BY THE ASSESSEE AND ALSO THE INFRASTRUCTURE CREATED BY HIM FOR CARRYING ON SUCH ACTIVITY AND THERE IS NO DISPUTE W ITH REGARD TO THE SAME. HE SUBMITTED THAT THE CIT (A) HAS DISALLO WED THE CLAIM OF AGRICULTURAL INCOME BY HOLDING THAT THE ASSESSEE HAS UTILIZED THE AGRICULTURAL LAND FOR GROWING COMMERCIAL CROPS SUCH AS AROMATIC AND MEDICINAL PLANTS AND THEREFORE, IT C ANNOT BE TREATED AS AGRICULTURAL OPERATIONS. HE SUBMITTED THAT THIS FINDING OF THE CIT (A) IS CONTRARY TO HIS FINDING SUBSEQUENTLY THA T THE ASSESSEE HIMSELF HAS NOT CARRIED ON ANY AGRICULTURAL ACTIVIT Y. HE FURTHER SUBMITTED THAT THE CASE LAWS RELIED UPON BY THE CIT (A) ARE ALL DISTINGUISHABLE ON FACTS AND HAVE NO RELEVANCE TO T HE CASE ON HAND. HE, THEREFORE, PRAYED THAT THE CLAIM OF AGRIC ULTURAL INCOME BY THE ASSESSEE BE ALLOWED. 5. THE LEARNED DR, ON THE OTHER HAND, SUPPORTED THE ORDERS OF THE AUTHORITIES BELOW AND SUBMITTED THAT THE ASSESSEE HIMSELF HAS NOT CARRIED ON ANY AGRICULTURAL OPERATI ONS BUT HAS LEASED OUT THE LAND TO A COMPANY AND THEREFORE, THE SAME CANNOT BE TREATED AS AGRICULTURAL INCOME. THUS, HE PRAYED FOR CONFIRMATION OF THE ASSESSMENT ORDER. 6. HAVING REGARD TO THE RIVAL CONTENTIONS AND THE M ATERIAL ON RECORD, I FIND THAT THE UNDISPUTED FACTS OF THE CASE ARE THAT THE ASSESSEE IS THE OWNER OF AGRICULTURAL LAND OF 20 AC RES AND 10 GUNTAS. THE KHASRA PAHANI ALSO SHOWS THAT THESE LAN DS ARE AGRICULTURAL LANDS AND THAT THE CROP GROWN THEREON IS MANGO. ITA NO 25 OF 2020 NADEEM MOHD ABDUL SECUNDERABAD PAGE 5 OF 8 THEREFORE, THESE LANDS BEING AGRICULTURAL LAND IS N OT IN DISPUTE. IN ADDITION TO THESE LANDS, THE ASSESSEE HAS TAKEN ON LEASE AGRICULTURAL LANDS IN RANGA REDDY AND NALGONDA DIST RICTS FROM TWO OTHER PERSONS. THESE LANDS ALSO BEING AGRICULTU RAL LANDS IS NOT IN DISPUTE. 7. THE NEXT ISSUE TO BE CONSIDERED IS WHETHER THE AGRICULTURAL OPERATIONS HAVE BEEN CARRIED ON BY THE ASSESSEE IN THESE LANDS. ACCORDING TO THE ASSESSEE, THE ASSESSE E HAS CREATED INFRASTRUCTURE TO FACILITATE IRRIGATION IN THE AGRI CULTURAL OPERATIONS. ACCORDING TO THE LEASE DEED BETWEEN THE ASSESSEE AN D THE COMPANY ADISA AGRO PVT. LTD ALSO, THE ASSESSEE HAD ALREADY PLANTED AROMATIC AND MEDICINAL PLANTS IN THESE LAND S AND THE LESSEE AGREED TO PAY THE LESSOR HIGHER PERCENTAGE I N VIEW OF THE CROPS ALREADY GROWN BY THE LESSOR. THEREFORE, THE A SSESSEE HAS ALSO CARRIED ON CERTAIN AGRICULTURAL OPERATIONS IN THE LANDS WHICH HAVE BEEN LEASED OUT BY THE ASSESSEE. 8. AS REGARDS THE AGRICULTURAL OPERATIONS CARRIED O N BY ADISA AGRO (P) LTD DURING THE RELEVANT PERIOD IS CO NCERNED, THERE IS NO INFORMATION AVAILABLE ON RECORD NOR IS THERE ANY DISPUTE RAISED BY THE AUTHORITIES BELOW, EXCEPT FOR A FINDI NG BY THE CIT (A) IN PARA 7.23, THAT THERE IS NO EVIDENCE ON RECORD T O STATE THAT THE COMPANY HAD ACTUALLY UTILIZED THE LAND WHOLLY AND E XCLUSIVELY FOR THE PURPOSE OF CULTIVATING ON ITS OWN RATHER THAN S UB-LEASING IT TO OUTSIDE PARTIES. THEREFORE, NO PRESUMPTION CAN BE D RAWN ABOUT THE AGRICULTURAL OPERATIONS BEING OR NOT BEING CARR IED OUT BY THE COMPANY. ITA NO 25 OF 2020 NADEEM MOHD ABDUL SECUNDERABAD PAGE 6 OF 8 9. HOWEVER, THE FACT REMAINS THAT ASSESSEE HAS EARN ED LEASE RENT INCOME BY LEASING OUT THE AGRICULTURAL L AND. WHETHER SUCH INCOME IS ELIGIBLE TO BE TAKEN AS AGRICULTURAL INCOME IS THE QUESTION BEFORE THE TRIBUNAL. THE TERM AGRICULTURAL INCOME HAS BEEN DEFINED U/S 2(1A) OF THE I.T ACT AND FOR THE P URPOSE OF READY REFERENCE, THE SAME IS REPRODUCED HEREUNDER: (1A) 4 ]' AGRICULTURAL INCOME' MEANS- (A) ANY RENT OR REVENUE DERIVED FROM LAND WHICH IS SIT UATED IN INDIA AND IS USED FOR AGRICULTURAL PURPOSES; (B) ANY INCOME DERIVED FROM SUCH LAND BY- (I) AGRICULTURE; OR (II) THE PERFORMANCE BY A CULTIVATOR OR RECEIVER OF REN T- IN- KIND OF ANY PROCESS ORDINARILY EMPLOYED BY A CULTIVATOR OR RECE IVER OF RENT- IN- KIND TO RENDER THE PRODUCE RAISED OR RECEIVED BY HIM FIT TO BE TAKEN TO MARKET; OR (III) THE SALE BY A CULTIVATOR OR RECEIVER OF RENT- IN- KIND OF THE PRODUCE RAISED OR RECEIVED BY HIM, IN RESPECT OF WHICH NO P ROCESS HAS BEEN PERFORMED OTHER THAN A PROCESS OF THE NATURE DESCRI BED IN PARAGRAPH (II) OF THIS SUB- CLAUSE; (C) ANY INCOME DERIVED FROM ANY BUILDING OWNED AND OCC UPIED BY THE RECEIVER OF THE RENT OR REVENUE OF ANY SUCH LAND, O R OCCUPIED BY THE CULTIVATOR OR THE RECEIVER OF RENT- IN- KIND, OF AN Y LAND WITH RESPECT TO WHICH, OR THE PRODUCE OF WHICH, ANY PROCESS MENTION ED IN PARAGRAPHS (II) AND (III) OF SUB- CLAUSE (B) IS CARRIED ON: 1 PROVIDED THAT- (I) THE BUILDING IS ON OR IN THE IMMEDIATE VICINITY OF THE LAND, AND IS A BUILDING WHICH THE RECEIVER OF THE RENT OR REVENUE OR THE CULTIVATOR, OR THE RECEIVER OF RENT- IN- KIND, BY REASON OF HIS CONNEC TION WITH THE LAND, REQUIRES AS A DWELLING HOUSE, OR AS A STORE- HOUSE, OR OTHER OUT- BUILDING, AND (II) THE LAND IS EITHER ASSESSED TO LAND REVENUE IN IND IA OR IS SUBJECT TO A LOCAL RATE ASSESSED AND COLLECTED BY OFFICERS OF TH E GOVERNMENT AS SUCH OR WHERE THE LAND IS NOT SO ASSESSED TO LAND REVENUE O R SUBJECT TO A LOCAL RATE, IT IS NOT SITUATED- (A) IN ANY AREA WHICH IS COMPRISED WITHIN THE JURISDIC TION OF A MUNICIPALITY (WHETHER KNOWN AS A MUNICIPALITY, MUNI CIPAL CORPORATION, NOTIFIED AREA COMMITTEE, TOWN AREA COMMITTEE, TOWN COMMITTEE OR BY ANY OTHER NAME) OR A CANTONMENT BOARD AND WHICH HAS A P OPULATION OF NOT LESS THAN TEN THOUSAND ACCORDING TO THE LAST PRECED ING CENSUS OF WHICH THE RELEVANT FIGURES HAVE BEEN PUBLISHED BEFORE THE FIR ST DAY OF THE PREVIOUS YEAR; OR (B) IN ANY AREA WITHIN SUCH DISTANCE, NOT BEING MORE T HAN EIGHT KILOMETERS, FROM THE LOCAL LIMITS OF ANY MUNICIPALI TY OR CANTONMENT BOARD REFERRED TO IN ITEM (A), AS THE CENTRAL GOVERNMENT MAY, HAVING REGARD TO THE EXTENT OF, AND SCOPE FOR, URBANISATION OF THAT AREA AND OTHER RELEVANT CONSIDERATIONS, SPECIFY IN THIS BEHALF BY NOTIFICAT ION 2 IN THE OFFICIAL GAZETTE.] 3 EXPLANATION.- FOR THE REMOVAL OF DOUBTS, IT IS HER EBY DECLARED THAT REVENUE DERIVED FROM LAND SHALL NOT INCLUDE AN D SHALL BE DEEMED NEVER TO HAVE INCLUDED ANY INCOME ARISING FROM THE TRANSFER OF ANY LAND REFERRED TO IN ITEM (A) OR ITEM (B) OF SUB- CLAUSE (III) OF CLAUSE (14) OF THIS SECTION;] ITA NO 25 OF 2020 NADEEM MOHD ABDUL SECUNDERABAD PAGE 7 OF 8 1. SUBSTITUTED BY THE TAXATION LAWS (AMENDMENT) ACT , 1970, W. R. E. F. 1- 4- 1962. 2. INSERTED BY THE FINANCE ACT, 1989 W. R. E. F. 1- 4- 1970. 10. ON A LITERAL READING OF CLAUSE (A) OF SUB-SECTI ON 1A TO SECTION 2 WE FIND THAT IT REFERS TO ANY RENT OR REV ENUE ( EMPHASIS SUPPLIED BY ME ) DERIVED FROM LAND WHICH IS SITUATED IN INDIA AND IS USED FOR AGRICULTURAL PURPOSES. THIS SECTION DOE S NOT SPECIFY THAT THE LAND WHICH IS USED FOR AGRICULTURAL PURPOS ES SHOULD BE OWNED BY THE ASSESSEE. THEREFORE, THE LAND OWNED BY THE ASSESSEE AS WELL AS THE LAND TAKEN ON LEASE BY THE ASSESSEE ARE TO BE TREATED AS AGRICULTURAL LAND PROVIDED OTHER CONDITI ONS ARE SATISFIED. FURTHER, NOT ONLY THE REVENUE, BUT EVEN THE RENT FOR THE LAND WHICH IS USED FOR AGRICULTURAL PURPOSES IS TO BE TREATED AS AGRICULTURAL INCOME. THE A.Y RELEVANT FOR THIS CA SE IS A.Y 2015- 16, WHEREAS THE LEASE DEED ENTERED BY THE ASSESSEE WITH ADISA AGRO (P) LTD IS SEPTEMBER, 2013 I.E. A.Y 2014-15. F ROM THE LEASE DEED, IT IS SEEN THAT THE ASSESSEE HAD CARRIED ON A GRICULTURAL OPERATIONS DURING THE PREVIOUS YEAR I.E. 2013-14 RE LEVANT TO THE A.Y 2014-15 AND THEREAFTER, THE ASSESSEE HAS LEASED OUT THIS LAND TO ADISA AGRO (P) LTD ON 30.09.2013 I.E. DURING THE PREVIOUS YEAR 2014-15 RELEVANT TO THE A.Y 2015-16. THEREFORE, THE ASSESSEE HAD CARRIED ON AGRICULTURAL OPERATIONS DURING THE PREVI OUS YEAR 2013- 14 AND SUBSEQUENTLY SUCH AGRICULTURAL LAND HAS BEEN GIVEN ON LEASE TO A COMPANY WHICH IS ALSO ENGAGED IN CARRYIN G ON AGRICULTURAL OPERATIONS. THE FINDING OF THE CIT (A) IS THAT THE CROPS GROWN ARE COMMERCIAL IN NATURE. THE DEFINITION OF AGRICULTURAL INCOME DOES NOT LIMIT ITS APPLICATION TO ANY PARTI CULAR CROPS/PRODUCE. THE ONLY REQUIREMENT IS THAT THE BAS IC AGRICULTURAL OPERATIONS ARE TO BE CARRIED OUT. THE NATURE OF THE CROP BEING COMMERCIAL IN NATURE WILL NOT THEREFORE, DISENTITLE THE ASSESSEE FROM CLAIMING THE INCOME AS AGRICULTURAL INCOME. THUS, THE FINDING OF THE CIT (A) THAT THE ASSESSEES INTE NTION OF TAKING ITA NO 25 OF 2020 NADEEM MOHD ABDUL SECUNDERABAD PAGE 8 OF 8 THE AGRICULTURAL LANDS ON LEASE IS TO EXPLOIT THEM COMMERCIALLY IS NOT SUSTAINABLE TO DISENTITLE THE ASSESSEE FROM MAK ING THE CLAIM OF AGRICULTURAL INCOME. HAVING GONE THROUGH THE DEC ISIONS RELIED BY THE LEARNED CIT (A), I AM OF THE OPINION THAT TH EY ARE ALL ARE DISTINGUISHABLE FROM THE FACTS OF THE CASE BEFORE T HE TRIBUNAL AND THEREFORE, ARE NOT APPLICABLE. IN VIEW OF THE SAME, I SET ASIDE THE ORDER OF THE AO AND DIRECT HIM TO TREAT THE LEASE R ENT RECEIVED BY THE ASSESSEE FROM ADISA AGRO (P) LTD FOR USE OF T HE AGRICULTURAL LAND AS AGRICULTURAL INCOME. 11. IN THE RESULT, ASSESSEES APPEAL IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 28 TH JANUARY, 2021. SD/- (P. MADHAVI DEVI) JUDICIAL MEMBER HYDERABAD, DATED 28 TH JANUARY, 2021. VINODAN/SPS COPY TO: 1 SHRI NADEEM MOHD ABDUL C/O KATRAPATI & ASSOCIATES , 1-1- 298/2/B/3, 1 ST FLOOR, ASHOKNAGAR, HYDERABAD 500020 2 ITO WARD 10(5) 5 TH FLOOR, IT TOWERS, AC GUARDS, HYDERABAD 3 CIT (A)-6 HYDERABAD 4 PR. CIT 6 HYDERABAD 5 THE DR, ITAT HYDERABAD 6 GUARD FILE BY ORDER