The DCIT, Circle-1(1), Baroda V. Gulbrandsen Technologies (India) Pvt. Ltd., Vadodara

ITA 263/AHD/2016

• Counselvise Citation: [2018] 126 COUNSELVISE.COM (IT) 5967 (ITAT-AHMEDABAD)
• Duration Of Justice: 2 year(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-02-2018
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: I
• Next Hearing Date: 22-05-2017
• Assessment Year: 2008-2009
• Appeal Filed On: 03-02-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Transfer pricing
• Section: 143(3)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD D BENCH AHMEDABAD BEFORE, SHRI PRAMOD KUMAR , ACCOUNTANT MEMBER AND SHRI S. S. GODARA, JUDICIAL MEMBER ITA NO. 263/AHD/2016 ( ASSESSMENT YEAR: 2008-09) THE DY.CIT, CIRCLE-1(1)(1), VADODARA APPELLANT VS. GULBRANDSEN TECHNOLOGIES (INDIA) PVT. LTD., 405, SYNERGY SQUARE, KRISHNA INDUSTRIAL ESTATE, GORVA, VADODARA 390016 RESPONDENT PAN: AABCG9006E /BY REVENUE : SHRI SUBHASH BAINS, CIT. D.R. /BY ASSESSEE : SHRI MAHAVIR JAIN & SHRI MAN ISH AGARWAL, A.R. /DATE OF HEARING : 06.02.2018 /DATE OF PRONOUNCEMENT : 27.02.2018 ORDER PER S. S. GODARA, JUDICIAL MEMBER THIS REVENUES APPEAL FOR ASSESSMENT YEAR 2008-09 A RISES AGAINST THE CIT(A)-1, VADODARAS ORDER DATED 10.11.2015, IN CAS E NO. CAB-1/22/2014-15, REVERSING ASSESSING OFFICERS ACTION MAKING TRANSFE R PRICING ADJUSTMENT OF RS.57,27,988/- PERTAINING TO INFORMATION TECHNOLOGY ENABLED SERVICES (ITES) AS PROPOSED IN THE TRANSFER PRICING OFFICERS ORDER DA TED 28.10.2011, IN PROCEEDINGS U/S. 143(3) R.W.S. 144C(1) OF THE INCOME TAX ACT, 1 961; IN SHORT THE ACT. HEARD BOTH THE PARTIES. CASE FILE PERUSED. ITA NO. 263/AHD/16 [DCIT VS. GULBRANDSEN TECHNOLOGI ES (INDIA) PVT. LTD. ] A.Y. 2008-09 - 2 - 2. IT EMERGES AT THE OUTSET THAT THE SOLE DISPUTE B ETWEEN THE PARTIES IS QUA INCLUSION OF TWO ENTITIES NAMELY M/S. MOLD-TEK TECH NOLOGIES LTD. AND M/S. ACROPETAL TECHNOLOGIES LTD. IN THE ARRAY OF COMPARA BLES. THE ASSESSEE HAD SELECTED NINE COMPARABLE ENTITIES IN ITS TRANSFER PRICING RE PORT FORM 3CEB REGARDING ITS INFORMATION TECHNOLOGY ENABLED SERVICES PROVIDED TO OVERSEAS ASSOCIATE ENTERPRISES. IT JUSTIFIED ITS PRICE CHARGED HAVING PLI OF 10.11% TO BE AT ARMS LENGTH BEING MUCH MORE AVERAGE OF 7.46% IN CASE OF SAID NINE COMPARABLE ENTITIES. THE TPOS ORDER REJECTED THE ASSESSEES TRANSFER PR ICING REPORT. HE PROCEEDED TO SELECT SIX COMPARABLE ENTITIES THEREAFTER NAMELY M/ S. ACROPETAL TECHNOLOGIES LTD., CROSSDOMAIN SOLUTIONS PVT. LTD., JINDAL INTELLICOM LTD., ICRA TECHNO ANALYTICS LTD., MOLD-TEK TECHNOLOGIES LTD. & SPANCO LTD. (SEG MENTAL DATA IN CASE OF FIRST AND LAST ENTITY) HAVING PLIS OF 35.3%, 26.96%, -8.6 6%, 8.03%, 96.66% AND 11.04%; RESPECTIVELY; AVERAGING TO 28.2%. THE TRAN SFER PRICING OFFICER THUS PROPOSED THE IMPUGNED ADJUSTMENT OF RS.57,27,988/- IN HIS REFERENCE ORDER AS CULMINATING IN THE TRANSFER PRICING ADJUSTMENT MADE IN ASSESSEES HANDS IN ASSESSMENT ORDER DATED 21.12.2011. 3. THE CIT(A)S ORDERS EXCLUSION OF THE ABOVE TWO E NTITIES M/S. MOLD-TEK TECHNOLOGIES LTD. AND M/S. ACROPETAL TECHNOLOGIES L TD. ON THE FOLLOWING GROUNDS: 4.2. I HAVE CONSIDERED THE APPELLANT'S SUBMISSION AND THE AO'S OBSERVATIONS. SO FAR AS THE SELECTION OF MOLD-TEK TECHNOLOGIES LTD. AS A COMPARABLE IS CONCERNED, THE PLI OF THIS COMPANY AS ADOPTED BY THE TPO HIMSE LF AT 96.66%. IN THE EARLIER ASSESSMENT YEAR I.E. AY 2007-08, THIS PLI WAS 101.7 7%. ON ACCOUNT OF SUCH SUPER ABNORMAL PROFITS, THIS COMPANY HAS BEEN DIRECTED TO BE NOT INCLUDED AS A COMPARABLE IN SEVERAL JUDICIAL PRONOUNCEMENTS OF TR IBUNALS AS HAS BEEN RELIED UPON BY THE APPELLANT IN ITS SUBMISSIONS. SINCE, IN THE CURRENT YEAR ALSO, THIS COMPARABLE IS HAVING VERY HIGH MARGIN BY ANY STANDA RD, HENCE, THE APPELLANT'S CONTENTIONS IN THIS REGARD ARE ACCEPTABLE. ACCORDIN GLY, THE AO IS DIRECTED TO EXCLUDE THIS COMPANY AS COMPARABLE IN THE CASE OF T HE APPELLANT ALSO. 4.2.1. SO FAR AS THE OTHER COMPARABLE I.E. M/S. ACR OPETAL TECHNOLOGIES LTD. IS CONCERNED, THE APPELLANT'S SUBMISSIONS ARE BASED UP ON THE DIFFERENCE IN FUNCTIONALITY WITH THE APPELLANT'S FUNCTION AND LES SER EMPLOYEE COST RATIO OF 8.29% WHICH DOES HOT FULFILL THE FILTER OF 20% ADOPTED BY THE TPO HIMSELF. IT IS SEEN THAT THE DRP IN APPELLANT'S OWN CASE FOR AY 2010-11 HAS HELD THAT ENGINEERING AND DESIGNING SERVICES IS NOT THE ACTIVITY COMPARABLE T O THE ASSESSES IS BUSINESS. ACCORDINGLY, IT DIRECTED THE TPO TO EXCLUDE M/S. AC ROPETAL TECHNOLOGIES LTD. FROM ITA NO. 263/AHD/16 [DCIT VS. GULBRANDSEN TECHNOLOGI ES (INDIA) PVT. LTD. ] A.Y. 2008-09 - 3 - THE SET OF COMPARABLES. MOREOVER, THE TPO HAS RELIE D UPON THE SEGMENTAL RESULTS OF THIS COMPARABLES FOR DETERMINING ITS PLI, BUT, AT T HE SAME TIME HAS ADOPTED THE EMPLOYEE COST RATIO AT THE ENTITY LEVEL TO SHOW THA T SUCH RATIO EXCEEDS FILTER OF 20%. THIS METHOD IS ALSO NOT CORRECT. THE EMPLOYEE COST RATIO SHOULD ALSO BE DETERMINED AT THE SEGMENTAL LEVEL IF SUCH RESULTS ARE AVAILABL E. HENCE, ON THE BASIS OF SUCH DISCUSSIONS, THE TPO IS DIRECTED TO EXCLUDE THIS CO MPANY FROM THE SET OF COMPARABLES. 4. LEARNED DEPARTMENTAL REPRESENTATIVE STRONGLY SUP PORTS REVENUES CASE THAT THE CIT(A) HAS ERRED IN LAW AS WELL AS ON FACTS IN ORDERING EXCLUSION OF THE ABOVE TWO ENTITIES. HE FILES REVENUES WRITTEN SUBMISSIO NS AS WELL READING AS FOLLOWS: 1. CONTENTION IN RESPECT OF FUNCTIONAL DIFFERENC ES. THE ASSESSEE SUBMITTED THAT ACROPETAL TECHNOLOGIES LTD. AND MOLD-TEK TECHNOLOGIES LTD. ARE NOT COMPARABLE TO THE ASSESSE E AS THESE COMPANIES ARE ENGAGED IN PROVIDING ENGINEERING DESIGN SERVICES WH ICH ARE NOT COMPARABLE TO THE FUNCTIONS PROVIDED BY THE ASSESSEE. IT WAS FURTHER SUBMITTED THAT THESE COMPANIES HAVE HIGH MARGIN AND THEREFORE THEY SHOULD BE REJEC TED. 1.1 BEFORE DISCUSSING SPECIFIC CONTENTIONS RAISED B Y THE ASSESSEE IN RESPECT OF VARIOUS FILTERS ADOPTED IN THE TP STUDY REPORT, FIL TERS ADOPTED BY TPO AND THE COMPARABLES SELECTED BY THE TPO, IT IS IMPORTANT TO UNDERSTAND THE NATURE OF WORK BEING CARRIED OUT BY THE ASSESSEE, WHICH IS BEING B ENCH MARKED. IN THIS REGARD, IT IS ALSO IMPORTANT TO NOTE THAT THE ASSESSEE HAS CAT EGORIZED ITSELF UNDER THE CATEGORY OF BPO/1TES (INFORMATION TECHNOLOGY ENABLED SERVICE S) AND CONSEQUENTLY DISCUSSED THIS INDUSTRY SEGMENT IN THE INDUSTRY PRO FILE IN THE TP REPORT. AS A RESULT OF PIS CLASSIFICATION, THE COMPARABLE SET IS NECESS ARILY REQUIRED'TO CONTAIN COMPANIES ENGAGED IN PROVIDING THE BPO/ITES SERVICE S. HOWEVER, THE COMPANIES ENGAGED IN PROVIDING SUCH SERVICES IN INDIA OFFER S ERVICES RELATED TO LOW END BACK OFFICE SUPPORT SERVICES TO HIGH END SPECIALIZED SER VICES, ACROSS MANY VERTICALS SUCH AS BANKING, FINANCE, INSURANCE, HEALTH CARE, RETAIL , INSURANCE ETC. THE FUNCTIONAL OR SERVICE LINES FOR THESE VERTICALS MAY INCLUDE BU T IS NOT LIMITED TO BACK OFFICE OPERATIONS, CALL CENTERS, CONTENT DEVELOPMENT OR AN IMATION; DATA PROCESSING; ENGINEERING AND DESIGN; GEOGRAPHIC INFORMATION SYST EM SERVICES, HUMAN RESOURCES SERVICES; INSURANCE CLAIM PROCESSING; LEG AL DATABASES; MEDICAL TRANSCRIPTION; PAYROLL; LEMOTE MAINTENANCE; REVENUE ACCOUNTING; SUPPORT CENTERS, AND WEB SITE SERVICES. 1.2 FROM THE PERUSAL OF THE DETAILS PROVIDED IN TH E TP REPORT, IT IS SEEN THAT THE ASSESSEE IS IN PROVIDING ACTIVITIES RELATED TO PROC ESSING OF ACCOUNT PAYABLE AND RECEIVABLE, INVOICING, JOURNAL VOUCHERS, GENERAL LE DGERS. IT IS ALSO ENGAGED IN PROVIDING SERVICES RELATED TO BUSINESS RESEARCH AND DEVELOPMENT INCLUDING THE DEVELOPMENT OF BUSINESS IN NEW MARKETS. IT IS ALSO ENGAGED IN DOCUMENTATION OF VARIOUS PROCESSES OF THE AE, IMPROVEMENT AND FURTHE R DEVELOPMENT OF SUCH PROCESS WHICH IS UPLOADED ON THE WEB SITE, DEVELOPMENT OF T HE INTERNET, MARKETING COLLATERALS AND OTHER SUCH ACTIVITIES. FROM THE PER USAL OF THE ABOVE, IT BECOMES ITA NO. 263/AHD/16 [DCIT VS. GULBRANDSEN TECHNOLOGI ES (INDIA) PVT. LTD. ] A.Y. 2008-09 - 4 - CLEAR THAT THE ASSESSEE IS ENGAGED IN PROVIDING SER VICES WHICH CANNOT BE CONSIDERED AS LOW END ACTIVITIES. ACTIVITIES RELATED TO BUSINE SS RESEARCH AND DEVELOPMENT, PROCESS ENGINEERING, PREPARING ACCOUNTS OF THE GROU P, GENERATION OF MIS REPORT, PURCHASES OF RAW MATERIAL CARRYING OUT COST BENEFIT ANALYSIS FOR THE SAME AND BUSINESS PROCESS RE-ENGINEERING SERVICES ARE THE SE RVICES WHICH ARE KNOWLEDGE BASED SERVICES AND REQUIRE EMPLOYEES HAVING HIGH SK ILL SET. CONSIDERING THE ABOVE DISCUSSION, THE ASSESSEE CANNOT BE CONSIDERED AS LO W END BPO SERVICES PROVIDER AND IN VIEW OF THE ENGINEERING SERVICES PROVIDED BY IT, AS DISCUSSED ABOVE, AND AS MENTIONED IN TRANSFER PRICING REPORT SUBMITTED TO T HIS OFFICE, THE ASSESSEE CAN BE PLACED TOWARDS THE HIGHER END OF THE BPO SPECTRUM N EARING THE KPO ACTIVITIES. KEEPING THE ABOVE IN MIND, THE DISCUSSION ON OBJECT IONS RAISED BY THE ASSESSEE IS AS FOLLOWS: THE ASSESSEE HAS OBJECTED TO THE INCLUSION OF ACROP ETAL TECHNOLOGIES LTD. AND MOLD-TEK TECHNOLOGIES LTD AS COMPARABLE ON THE BASI S THAT THESE COMPANIES ARE ENGAGED IN PROVIDING ENGINEERING DESIGN SERVICES AN D THE SAME ARE NOT COMPARABLE WITH THE ASSESSEE COMPANY. IN THIS RESPECT, IT CAN BE SEEN THAT THESE COMPARABLES ARE ENGAGED IN PROVIDING KNOWLEDGE BASED SERVICES A ND AS PER THE DISCUSSION MADE ABOVE, THE ASSESSEE IS ALSO ENGAGED KNOWLEDGE BASED SERVICES. CONSIDERING THE ABOVE, THERE IS NO DIFFERENCE IN TH ASSETS AND RISK S OF THIS COMPARABLES WITH THE ASSESSEE AND THEREFORE THERE IS NO REJECTION OF THE SE COMPANIES. 1.3 THE ASSESSEE FURTHER SUBMITTED THAT THIS COMPAR ABLE SHOULD NOT BE TAKEN INTO ACCOUNT CONSIDERING HIGH MARGIN EARNED BY IT. MERELY BECAUSE THE COMPARABLE HAS EARNED HIGHER MARGINS OR IT COULD EARN LOSSES I N THE YEAR UNDER REFERENCE CANNOT BE THE SOLE CRITERIA FOR REJECTING THE SAME IN THE COMPARABILITY ANALYSIS. THE CONTENTIONS RAISED BY THE REGARD TO THE DIFFERENCE IN RESPECT OF FUNCTIONS UNDERTAKEN, ASSETS UTILIZED AND RISK ASSUMED BY THE COMPARABLE VIS-A-VIS ITS OWN OPERATIONS IS ALREADY DISCUSSED ABOVE. IN QUARK SYSTEMS PVT. LTD. AND SAPIENT CORPORATION PVT. LTD. AND SAPIENT CORPORATION PVT. LTD., THE HON'BLE TRIBUNALS HELD THAT, HIGH PROFIT MAKING COMPANIES SHOULD NOT BE TAKEN INTO ACCOUNT; IN CASE OF LOSS MAKING COMPANIES ARE EXCLUDED FROM THE LIST OF COMPARABLE. IN THE INSTANT CASE, TPO HAS NOT REJECTED ANY COMPANY SOLELY ON TH E BASIS THAT IT IS LOSS MAKING AND INSTEAD A BROAD FILTER IN WHICH THE COMPANIES H AVING CONSISTENT OPERATING LOSSES FOR THE LAST THREE YEARS INCLUDING FY 2007-0 8 WAS CONSIDERED. THE GUIDING FACTOR IN RESPECT OF THE SELECTION OF COMPARABLE WA S THE COMPARISON OF FAR ANALYSIS OF THE COMPARABLES WITH THE ASSESSEE COMPA NY. IN CASE SUCH ANALYSIS COMPARES WITH THAT OF THE ASSESSEE COMPANY, THE ENT ITY WAS TAKEN AS COMPARABLE. IN THE CASE OF MENTOR GRAPHICS (NOIDA) PVT. LTD ., THE HON'BLE TRIBUNAL HAS ALSO LAID EMPHASIS ON THE FAR ANALYSIS. ON THE FACTS OF THE C ASE, THE HON'BLE TRIBUNAL CONTENDED THAT WIDE DIFFERENCE IN THE OPERATING MAR GIN COULD HAVE BEEN AS A RESULT OF VARIATION ON ACCOUNT OF FAR ANALYSIS. THE HON'BL E TRIBUNAL EVEN THOUGH DID NOT TAKE INTO ACCOUNT HIGH PROFIT OR LOSS MAKING COMPAN IES ON THE FACTS OF THE CASE, NO REASON FOR SUCH ACTION WAS GIVEN. IN THE CASE OF PHILLIP SOFTWARE CENTRE PVT. LTD., THE HON'BLE TRIBUNAL EXCLUDED THE HIGH PROFIT MAKIN G COMPANIES BASED ON ENTIRELY DIFFERENT REASON ON THE BASIS OF FACTS OF THE CASE. THE HON'BLE TRIBUNAL HOWEVER, ALSO LAID CONSIDERABLE EMPHASIS ON THE IMPORTANCE O N FAR ANALYSIS. THEREFORE, IT CAN BE SEEN THAT MERE OCCURRENCE OF LOSS OR ABNORMA L PROFIT PER SE CORRECT CRITERION TO SELECT/REJECT A COMPARABLE. THE FAR ANALYSIS SHO ULD BE THE KEY ON THE BASIS OF ITA NO. 263/AHD/16 [DCIT VS. GULBRANDSEN TECHNOLOGI ES (INDIA) PVT. LTD. ] A.Y. 2008-09 - 5 - ABOVE DISCUSSION, IT IS SEEN THAT THE FAR ANALYSIS OF THE COMPARABLE TO THE ASSESSEE AND THEREFORE THERE IS NO REASON TO REJECT THE SAME AS COMPARABLE. 1.4 THIS PROPOSITION IS ALSO PROPOUNDED IN TH E CASE OF EXXON MOBIL COMPANY LTD(20N-TII-68-ITAT-MUM-TP) WHEREIN THE FOLLOWING WAS HELD: NOW, COMING TO THE ALTERNATIVE ARGUMENTS OF THE AS SESSEE THAT ABNORMAL PROFIT MAKING UNIT IS ALSO TO BE ELIMINATED ON THE SAME AN ALOGY ON WHICH LOSS MAKING UNITS ARE EXCLUDED, WE, IN PRINCIPLE, DO NOT DISPUT E THIS PROPOSITION. THE VARIOUS CASE LAWS RELIED UPON BY THE ASSESSEE LAY DOWN THAT A COMPARABLE CANNOT BE ELIMINATED JUST BECAUSE IT IS A LOSS MAKING UNIT. S IMILARLY, A HIGHER PROFIT MAKING UNIT CANNOT ALSO BE AUTOMATICALLY ELIMINATED JUST B ECAUSE THE COMPARABLE COMPANY EARNED HIGHER PROFITS THAN THE AVERAGE. THE REASON FOR REJECTING THE TWO LOSS MAKING UNITS IS NOT JUST BECAUSE THEY WERE LOSS MAK ING UNITS BUT FOR THE REASONS WHICH ARE ALREADY STATED IN THE PRECEDING PARAGRAPH S. IF SIMILAR REASONS EXISTED IN THE HIGHER PROFIT MAKING UNIT, THEN, IT IS FOR THE ASSESSEE TO BRING OUT THOSE REASONS AND SEEK EXCLUSION OF THE SAME. A GENERAL ARGUMENT THAT, YOU HAVE TO EXCLUDE UNITS WHICH HAVE HIGH PROFIT RANGE, IN CASE YOU EXCLUDE U NITS WHICH HAVE MADE LOSS IS A GENERAL, SUBMISSION WHICH CANNOT BE ACCEPTED. IN OT HER WORDS, AS A GENERAL PRINCIPLE, BOTH LOSS MAKING UNIT AND HIGH PROFIT MA KING UNIT CANNOT BE ELIMINATED FROM THE COMPARABLE; UNLESS, THERE ARE SPECIFIC REA SONS FOR ELIMINATING THE SAME WHICH IS OTHER THAN THE GENERAL REASON THAT A COMPA RABLE HAS INCURRED LOSS OR HAS MADE ABNORMAL PROFITS. THUS, THIS GROUND IS DISMISS ED.' THEREFORE, IT IS PRAYED TO THE HON'BLE ITAT TO UPHO LD THE ORDER OF THE AO/TPO. SUBMITTED WITH THE PAPER BOOK OF THE ASSESSEE. 5. THE ASSESSEES AUTHORIZED REPRESENTATIVE ON THE OTHER HAND SUPPORTS THE LEARNED CIT(A)S ABOVE FINDINGS. HE SUBMITS THAT T HE SAID TWO COMPARABLES HAVE BEEN RIGHTLY REJECTED ON FAR ANALYSIS IN LOWER APPE LLATE PROCEEDINGS. 6. WE HAVE GIVEN OUR THOUGHTFUL CONSIDERATION TO RI VAL SUBMISSIONS. WE REITERATE THAT THE ONLY DISPUTE BETWEEN THE PARTIES IS QUA EXCLUSION OF THE ABOVE TWO ENTITIES M/S. MOLD-TEK TECHNOLOGIES LTD. AND M/S. A CROPETAL TECHNOLOGIES LTD. IN THE FIELD OF INFORMATION TECHNOLOGY ENABLED SERVICE S. WE FIND IN THIS BACKDROP THAT A CO-ORDINATE BENCHS DECISION IN M/S. SYMPHONY MAR KETING SOLUTIONS INDIA PVT. LTD. VS. ITO IT(TP)A NO. 1316/BANG/2012 DECIDED ON 14.08.2013 IN THE IMPUGNED ASSESSMENT YEAR ITSELF HAS REJECTED THESE TWO ENTIT IES AS COMPARABLES IN INFORMATION TECHNOLOGY ENABLES SERVICES SEGMENT. LEARNED CO-OR DINATE BENCH HOLDS THAT M/S. MOLD-TEK TECHNOLOGIES LTD. IS A KPO CLASSIFIED SERV ICE PROVIDER NOT ENGAGED IN ITES. IT THEREAFTER CONCLUDES THAT THE OTHER ENTIT Y M/S. ACROPETAL TECHNOLOGIES LTD. ITA NO. 263/AHD/16 [DCIT VS. GULBRANDSEN TECHNOLOGI ES (INDIA) PVT. LTD. ] A.Y. 2008-09 - 6 - IS AN ENGINEERING DESIGN SERVICES PROVIDER ON HIGH END BASIS THAN AN ENTITY IN ITES SEGMENT. LEARNED DEPARTMENTAL REPRESENTATIVES WRI TTEN SUBMISSION FAIL TO REBUT THE SAID ELABORATE FAR ANALYSIS ADOPTED IN LEARNED CO-ORDINATE BENCH DECISION. WE THUS SEE NO REASON TO DISAGREE WITH LEARNED CIT(A) S ABOVE EXTRACTED FINDINGS ACCEPTING ASSESSEES ARGUMENTS SEEKING REJECTION OF THE TWO COMPARABLE ENTITIES HEREINABOVE. THE REVENUES SOLE SUBSTANTIVE GROUND IS THEREFORE DECLINED. 7. THIS REVENUES APPEAL IS ACCORDINGLY DISMISSED. [PRONOUNCED IN THE OPEN COURT ON THIS T HE 27 TH DAY OF FEBRUARY, 2018.] SD/- SD/- ( PRAMOD KUMAR ) (S. S. GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER AHMEDABAD: DATED 27/02/2018 TRUE COPY S.K.SINHA / COPY OF ORDER FORWARDED TO:- / REVENUE 2 / ASSESSEE ! / CONCERNED CIT 4 !- / CIT (A) ( )*+ ,--. . /0 / DR, ITAT, AHMEDABAD 1 +23 / GUARD FILE. BY ORDER / . // . /0