Asst.DIT, (Exemptions)-III, Hyderabad V. Sri Venkateswara Educational Society, R.R.Dist

ITA 269/HYD/2013

• Counselvise Citation: 26922514 RSA 2013
• Duration Of Justice: 1 year(s) 11 month(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 20-02-2015
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Next Hearing Date: 08-01-2015
• Assessment Year: 2009-2010
• Appeal Filed On: 01-03-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: D SUDHAKAR RAO
• Assessee Lawyers: S VENKATESAN
• Keywords: Capital asset
• Section: 143(3); 2(14); 147; 12; 11

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SHRI P.M. JAGTAP, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER ITA NO. 269/HYD/2013 ASSESSMENT YEAR: 2009-10 ASST. DIRECTOR OF INCOME-TAX, (EXEMPTIONS) III, HYDERABAD SRI VENKATESWARA EDUCATIONAL SOCIETY, R.R. DISTRICT. PAN AAETS 5284J (APPELLANT) (RESPONDENT) C.O. NO. 23/HYD/2013 (IN ITA NO. 269/HYD/2013 ASSESSMENT YEAR: 2009-10) SRI VENKATESWARA EDUCATIONAL SOCIETY, R.R. DISTRICT. PAN AAETS 5284J. ASST. DIRECTOR OF INCOME-TAX, (EXEMPTIONS) III, HYDERABAD. (CROSS OBJECTOR) (RESPONDENT) REVENUE BY : SHRI D. SUDHAKAR RAO ASSESSEE BY : SHRI S. VENKATESAN DATE OF HEARING 18-02-2015 DATE OF PRONOUNCEMENT 20-02-2015 O R D E R PER SAKTIJIT DEY, J.M.: THIS APPEAL OF THE DEPARTMENT AND C.O. OF THE ASSE SSEE ARE DIRECTED AGAINST ORDER DATED 26/12/2012 PASSED BY L D. CIT(A)-IV, HYDERABAD FOR A.Y. 2009-10. 2 ITA NO. 269 /HYD/2013 & C.O. NO. 23/H/13 SRI VENKATESWARA EDUCATIONAL SOCIETY ITA NO. 269/HYD/2013 2. THE ONLY EFFECTIVE GROUND RAISED BY DEPARTMENT I S AS UNDER: 2. ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND WHEN THE ASSESSEE ITSELF HAS SHOWN THE AMOUNT OF RS. 24,96,44,000 RECEIVED FROM RAMKY ESTATES AND FIRMS, DURING THE PREVIOUS YEAR, RELEVANT TO THE AY 2009-10, ADMI TTING AS RECEIPT IN THE RECEIPTS AND PAYMENTS ACCOUNT AND HA S SHOWN THE SAID ENTIRE AMOUNT ADMITTING AS INCOME, IN THE COMPUTATION STATEMENT FILED WITH THE RETURN OF INCO ME, LD. CIT(A) OUGHT TO HAVE CONFIRMED THE ADDITION OF THE SAID AMOUNT OF RS. 24,96,44,000 MADE BY AO TOWARDS INCOM E FROM SALE OF LAND, IN THE ASST ORDER PASSED IN THIS CASE, FOR THE AY 2009-10. FILED WITH THE RETURN 3. BRIEFLY, THE FACTS RELATING TO THE AFORESAID ISS UE IN DISPUTE ARE, ASSESSEE, A SOCIETY, IS REGISTERED UNDER SECTION 1 2A OF THE ACT. FOR THE AY UNDER CONSIDERATION, ASSESSEE FILED ITS RETURN OF INCOME ON 14/12/09 DECLARING NIL INCOME AFTER CLAIMING E XEMPTION U/S 11 OF THE ACT. IN COURSE OF ASSESSMENT PROCEEDING, IT WAS NOTICED BY AO THAT DURING THE RELEVANT PY, ASSESSEE HAD RECEIV ED AN AMOUNT OF RS. 24,96,44,000 AS CONSIDERATION TOWARDS SALE O F A PLOT OF LAND. TO A QUERY RAISED BY AO, IT WAS STATED BY ASSESSEE THAT THE SOCIETY RECEIVED 64 ACRES OF AGRICULTURAL LAND AT S RINIGAR VILLAGE IN THE YEAR 2002-03 AS DONATION FROM MEMBERS AND THEIR FAMILY MEMBERS. HOWEVER, SUBSEQUENTLY ON SURVEY, IT WAS FO UND THAT ACTUALLY LAND PHYSICALLY AVAILABLE WAS 44.32 ACRES ONLY. ASSESSEE ENTERED INTO AN AGREEMENT OF SALE ON 08/02/06 WITH M/S RAMKY ESTATES AND FARMS PVT. LTD. ( IN SHORT M/S RAMKY) FOR SALE OF LAND TO THE EXTENT OF 24.32 ACRES @ 44.80 LAKH PER ACRE, WITH TOTAL CONSIDERATION AMOUNTING TO RS. 11,11,04,000. IT WAS STATED, ASSESSEE RECEIVED AN AMOUNT OF RS. 2,10,000 AS ADVA NCE DURING THE PY 2005-06. FURTHER, ASSESSEE SUBMITTED, GOVT. IN APRIL, 2006 ISSUED A NOTIFICATION TO ACQUIRE LAND IN SRINIGAR V ILLAGE WHICH ALSO INCLUDED ASSESSEES LAND. M/S RAMKY ENTERED INTO JO INT AGREEMENT 3 ITA NO. 269 /HYD/2013 & C.O. NO. 23/H/13 SRI VENKATESWARA EDUCATIONAL SOCIETY WITH GOVT. OF AP AND HYDERABAD URBAN DEVELOPMENT AU THORITY FOR DEVELOPMENT OF AN INTEGRATED TOWNSHIP. IN THIS PROC ESS, M/S RAMKY PROPOSED TO PURCHASE THE ENTIRE AREA UNDER ACQUISIT ION @ RS. 70 LAKH PER ACRE. AS PER THE SURVEY CONDUCTED BY M/S R AMKY AND ASSESSEE, LAND BELONGING TO ASSESSEE WAS FOUND TO B E 44.32 ACRES ONLY. ACCORDINGLY, ASSESSEE ENTERED INTO AN AGREEME NT OF SALE ON 21/08/07 WITH M/S RAMKY FOR PURCHASE OF BALANCE 20 ACRES @ RS. 70 LAKH PER ACRE FOR A TOTAL CONSIDERATION OF RS. 1 4 CRORES. HE ALSO NOTICED, A GENERAL POWER OF ATTORNEY (GPA) HAD ALSO BEEN REGISTERED TO THAT EFFECT ON 05/05/07. AO NOTICED T HAT OUT OF THE TOTAL CONSIDERATION OF RS. 25,11,04,000, ASSESSEE R ECEIVED A PART AS ADVANCE IN THE EARLIER YEAR. HOWEVER, DURING THE RELEVANT PY ASSESSEE RECEIVED BALANCE AMOUNT OF RS. 24,96,44,00 0. HE FURTHER OBSERVED THAT ASSESSEE HAS MADE PAYMENT OF RS. 25,1 0,00,000 TO M/S MVR SECURITIES PVT. LTD. TOWARDS PURCHASE OF A PLOT OF LAND THROUGH AN UNREGISTERED AGREEMENT. ASSESSEE, HOWEVE R, DID NOT OFFER ANY INCOME BY CLAIMING THE PAYMENT OF THE AM OUNT AS APPLICATION OF INCOME. AO, HOWEVER, OBSERVED THAT M /S MVR SECURITIES PVT. LTD. IS A COMPANY WHEREIN SMT. M. R ADHIKA, WIFE OF THE PRESIDENT OF ASSESSEE SOCIETY IS ONE OF THE DIR ECTOR, THEREBY PAYMENTS MADE ATTRACTS THE PROVISIONS OF SECTION 13 (2)(A) AND 13(1)(C)(II). ASSESSEE ALSO CLAIMED THAT THE LAND S OLD BY IT BEING IN THE NATURE OF AGRICULTURAL LAND DID NOT CONSTITUTE CAPITAL ASSET U/S 2(14) OF THE ACT, HENCE, ANY GAIN RESULTING ON TRAN SFER OF LAND WAS EXEMPT. AO, HOWEVER, DID NOT AGREE WITH THE SUBMISS IONS OF ASSESSEE. HE OBSERVED, THOUGH INITIALLY ASSESSEE ST ATED THAT THE DELAY IN REGISTRATION OF LAND CLAIMED TO HAVE BEEN PURCHASED FROM M/S MVR SECURITIES PVT. LTD. WAS DUE TO LACK OF FUN DS BUT SUBSEQUENTLY IT WAS STATED BY ASSESSEE THAT DELAY I N REGISTRATION WAS DUE TO PENDING PROCEEDING OVER CHANGE OF LAND U SED. HE OBSERVED THAT ASSESSEE HAD PURCHASED THE PROPERTY W ITH FULL 4 ITA NO. 269 /HYD/2013 & C.O. NO. 23/H/13 SRI VENKATESWARA EDUCATIONAL SOCIETY KNOWLEDGE THAT NEITHER THE TITLE NOR POSSESSION WAS AVAILABLE WITH THE SELLER AND THE CLAIM THAT TOTAL LAND HAS NOT BE EN TRANSFERRED DUE TO INABILITY OF ASSESSEE TO PAY BALANCE CONSIDERATI ON IS NOT CORRECT. THE AO ALSO HELD THAT THE NATURE OF LAND IS NOT AGR ICULTURAL AS CLAIMED BY ASSESSEE AND ACCORDINGLY, CONCLUDED THAT THE AMOUNT RECEIVED BY ASSESSEE FROM M/S RAMKY TOWARDS SALE OF LAND IS TO BE TREATED AS INCOME OF ASSESSEE FOR THE IMPUGNED AY. ACCORDINGLY, HE COMPLETED THE ASSESSMENT BY DETERMINING THE TOTA L INCOME AT RS. 24,96,44,000. BEING AGGRIEVED, ASSESSEE PREFERR ED AN APPEAL BEFORE LD. CIT(A). 4. BEFORE LD. CIT(A), ASSESSEE REITERATED THE SUBMI SSIONS MADE BEFORE AO. IN ADDITION, IT WAS SUBMITTED BY ASSESSE E THAT PROVISIONS U/S 11 & 12 RELATING TO APPLICATION, ACC UMULATION AND INVESTMENT ARE NOT APPLICABLE TO AN INCOME, WHICH I S OTHERWISE EXEMPT. IT WAS ALSO SUBMITTED BY ASSESSEE THAT AS POSSESSION OVER THE LAND WAS HANDED OVER TO M/S RAMKY UNDER GP A DURING FY 2007-08, CAPITAL GAIN, IF ANY, IS NOT TAXABLE IN T HE IMPUGNED AY, BUT IN THE AY 2008-09. 5. LD. CIT(A) AFTER CONSIDERING THE SUBMISSIONS OF ASSESSEE, THOUGH DID NOT ACCEPT ASSESSEES CLAIM WITH REGARD TO THE NATURE OF LAND AS AGRICULTURAL AND ALSO APPLICATION OF SALE P ROCEEDS, HOWEVER, SHE ACCEPTED ASSESSEES CLAIM THAT POSSESSION OVER THE LAND HAVING BEEN HANDED OVER TO THE PURCHASER DURING AY 2008-09 IN TERMS OF SECTION 2(47)(V), CAPITAL GAIN, IF ANY, HA S TO BE ASSESSED IN THE AY 2008-09. ACCORDINGLY, LD. CIT(A) DIRECTED AO TO BRING THE CAPITAL GAIN TO TAX FOR AY 2008-09 BY TAKING REMEDI AL MEASURES AS PER THE PROVISIONS OF THE ACT. BEING AGGRIEVED OF T HE AFORESAID DECISION OF LD. CIT(A), DEPARTMENT IS IN APPEAL BEF ORE US. 6. LD. DR SUBMITTED THAT AS ASSESSEE ITSELF HAS SHO WN THE RECEIPT AS APPLICATION OF INCOME FOR THE IMPUGNED A Y, LD. CIT(A) 5 ITA NO. 269 /HYD/2013 & C.O. NO. 23/H/13 SRI VENKATESWARA EDUCATIONAL SOCIETY WAS NOT CORRECT IN HOLDING THAT CAPITAL GAIN ARISIN G FROM SALE OF LAND IS TO BE TAXED IN THE AY 2008-09 AND NOT IN THE IMP UGNED AY. 7. LD. AR, HOWEVER, SUPPORTING THE ORDER OF LD. CIT (A) ON THIS ASPECT, SUBMITTED THAT WHEN THE POSSESSION OVER THE LAND WAS HANDED OVER TO THE DEVELOPER IN TERMS WITH THE GPA IN FY 2007-08, THERE WAS A TRANSFER IN TERMS WITH SECTION 2(47)(V) OF THE ACT. LD. AR SUBMITTED THAT ONLY BECAUSE ASSESSEE UNDER A MIS TAKEN IMPRESSION, HAS SHOWN THE AMOUNT AS APPLICATION OF INCOME IN THE IMPUGNED AY, DEPARTMENT CANNOT BE ALLOWED TO TAKE A DVANTAGE OF SUCH MISTAKE COMMITTED BY ASSESSEE. LD. AR SUBMITTE D THAT IN PURSUANCE TO DIRECTION OF LD. CIT(A), AO IN THE MEA NTIME, HAS REOPENED ASSESSMENT U/S 147 OF THE ACT FOR AY 2008- 09 AND HAS ALSO PASSED ASSESSMENT ORDER ON 31/03/14 BY BRINGIN G TO TAX ON SUBSTANTIVE BASIS THE AMOUNT OF RS. 25,11,27,000 RE CEIVED TOWARDS SALE CONSIDERATION FROM M/S RAMKY. LD. AR, THUS, SU BMITTED THAT WHEN THE AMOUNT RECEIVED BY ASSESSEE ON SALE OF LAN D HAS BEEN BROUGHT TO TAX IN AY 2008-09, THE SAME AMOUNT CANNO T BE TAXED AGAIN IN THE IMPUGNED AY. THEREFORE, THE DEPARTMENT SHOULD NOT HAVE ANY GRIEVANCE AGAINST THE IMPUGNED ORDER OF LD . CIT(A) ON THIS ISSUE. 8. WE HAVE CONSIDERED THE SUBMISSIONS OF THE PARTIE S AND PERUSED THE MATERIALS ON RECORD AS WELL AS ORDERS O F REVENUE AUTHORITIES ON THIS ISSUE. THERE IS NO DISPUTE TO T HE FACT THAT ASSESSEE ON 05/05/07 HAS ENTERED INTO GPA WITH M/S RAMKY FOR DEVELOPMENT OF LAND AND IN PURSUANCE TO THE TERMS O F THE SAID GPA HAS HANDED OVER POSSESSION OF THE PROPERTY TO M/S R AMKY. THIS FACT IS ALSO EVIDENT FROM THE ENTRIES MADE IN THE B OOKS OF ACCOUNT FOR AY 2008-09. AS OBSERVED BY LD. CIT(A) IN PARA 8 .3 OF HER ORDER, AO ALSO IN HIS REMAND REPORT DATED 28/08/12 HAS ADM ITTED THAT SALE HAS TAKEN PLACED IN AY 2008-09. THEREFORE, SINCE AS SESSEE HAS 6 ITA NO. 269 /HYD/2013 & C.O. NO. 23/H/13 SRI VENKATESWARA EDUCATIONAL SOCIETY HANDED OVER POSSESSION OVER THE PROPERTY TO THE DEV ELOPER ON EXECUTION OF GPA ON 05/05/07, THERE IS A TRANSFER O F THE ASSET IN TERMS WITH SECTION 2(47)(V) DURING THE FY 2007-08 R ELEVANT TO AY 2008-09. THIS VIEW IS ALSO SUPPORTED BY THE DECISIO N OF THE HONBLE JURISIDICTIONAL HIGH COURT IN CASE OF POTLA NAGRESW ARA RAO VS. DCIT, [2014] 365 ITR 249. MOREOVER, IT IS A FACT ON RECORD THAT ON THE BASIS OF THE IMPUGNED ORDER OF LD. CIT(A), AO N OT ONLY REOPENED THE ASSESSMENT FOR AY 2008-09 BY TAKING RE COURSE TO SECTION 147 OF THE ACT, BUT HAS ALSO COMPLETED THE ASSESSMENT FOR AY 2008-09 BY BRINGING TO TAX THE AMOUNT OF RS. 25, 11,44,000 RECEIVED FROM M/S RAMKY TOWARDS DEVELOPMENT OF LAND . THIS FACT IS VERY MUCH EVIDENT FROM THE ASSESSMENT ORDER PASSED FOR AY 2008- 09 U/S 143(3) READ WITH SECTION 147 OF THE ACT FOR AY 2008-09. TO A QUERY RAISED BY THE BENCH, LD. AR OF ASSESSEE ASS ERTED THAT ASSESSEE HAS NOT CHALLENGED THE YEAR OF TAXABILITY IN THE APPEAL PREFERRED BEFORE LD. CIT(A) AGAINST THE ASSESSMENT ORDER PASSED U/S 143(3) READ WITH SECTION 147 FOR AY 2008-09. LD . AR ASSURED THAT ASSESSEE ACCEPTS THE FACT THAT, IF AT ALL, CAP ITAL GAIN HAS TO BE ASSESSED, THEN, IT IS TO BE IN THE AY 2008-09. ON P ERUSAL OF THE GROUNDS RAISED BY ASSESSEE BEFORE LD. CIT(A) IN APP EAL PREFERRED FOR AY 2008-09, A COPY OF WHICH IS PLACED BEFORE US , ALSO REVEALS THAT ASSESSEE HAS NOT CHALLENGED THE YEAR OF TAXABI LITY. THEREFORE, ONCE IT IS ACCEPTED THAT ASSESSEE HAS HANDED OVER P OSSESSION OF THE LAND TO THE DEVELOPER IN FY 2007-08, IN TERMS W ITH AN AGREEMENT TRANSFER TAKES PLACE DURING THAT FY, NOT ONLY AS PER THE PROVISIONS OF SECTION 2(47)(V) BUT ALSO AS PER THE RATIO LAID DOWN BY HONBLE JURISDICTIONAL HIGH COURT IN CASE OF POTLA NAGESWARA RAO (SUPRA). IN THE AFORESAID VIEW OF THE MATTER, WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF LD. CIT(A) IN HOLDING THA T CAPITAL GAIN, IF ANY, FROM THE SALE OF LAND HAS TO BE ASSESSED IN AY 2008-09 AND NOT IN THE IMPUGNED AY. ACCORDINGLY, WE UPHOLD THE ORDER OF LD. 7 ITA NO. 269 /HYD/2013 & C.O. NO. 23/H/13 SRI VENKATESWARA EDUCATIONAL SOCIETY CIT(A) BY DISMISSING THE GROUND RAISED BY DEPARTMEN T ON THIS ISSUE. 9. IN THE RESULT, DEPARTMENTS APPEAL IS DISMISSED. C.O. NO. 23/HYD/2013 BY ASSESSEE 10. THE FIRST ISSUE AS RAISED IN C.O. IS WITH REGAR D TO FINDING OF LD. CIT(A) THAT THE LAND SOLD BY ASSESSEE IS NOT AN AGR ICULTURAL LAND, BUT, A CAPITAL ASSET WITHIN THE MEANING OF SECTION 2(14) OF THE ACT. AS CAN BE SEEN, DURING THE ASSESSMENT PROCEEDING AS WELL AS BEFORE THE LD. CIT(A), IT WAS SUBMITTED BY ASSESSEE THAT THE LAND SOLD BY ASSESSEE TO THE DEVELOPER BEING RECORDED AS AGRICULTURAL LAND AND SITUATED BEYOND EIGHT KILOMETERS FROM THE LIMIT OF A NOTIFIED MUNICIPALITY, IS NOT A CAPITAL ASSET U/S 2(14) OF THE ACT. HOWEVER, NEITHER THE AO NOR LD. CIT(A) ACCEPTED SUC H CLAIM OF ASSESSEE AND HELD THAT THE LAND SOLD BY ASSESSEE IS A CAPITAL ASSET. 11. LD. AR SUBMITTED BEFORE US, CIT(A) HAVING HELD THAT CONSIDERATION RECEIVED BY ASSESSEE FROM SALE OF LAN D IS NOT TAXABLE IN THE IMPUGNED AY WAS NOT JUSTIFIED OR LEGALLY COR RECT IN GIVING HER FINDING WITH REGARD TO NATURE OF LAND. LD. AR SUBMI TTED THAT ONCE LD. CIT(A) HOLDS A PARTICULAR INCOME NOT TO BE TAXABLE IN THE PARTICULAR ASSESSMENT YEAR, SHE HAS NO JURISDICTION TO DECIDE ANY OTHER ISSUE RELATED TO SUCH INCOME. THEREFORE, FINDING OF CIT(A ) WITH REGARD TO NATURE OF LAND NEEDS TO BE EXPUNGED. 12. LD. DR, ON THE OTHER HAND, SUPPORTED THE ORDER OF LD. CIT(A). 13. WE HAVE CONSIDERED THE SUBMISSIONS OF THE PARTI ES AND PERUSED THE MATERIALS ON RECORD. IN PRINCIPLE, WE A GREE WITH THE LD. AR THAT LD. CIT(A) SHOULD NOT HAVE COMMENTED UPON T HE NATURE OF LAND, ONCE, SHE HELD THAT THE INCOME ARISING OUT OF SALE OF LAND NOT TO BE TAXABLE IN THE IMPUGNED AY BUT, A.Y. 2008-09 . THEREFORE, 8 ITA NO. 269 /HYD/2013 & C.O. NO. 23/H/13 SRI VENKATESWARA EDUCATIONAL SOCIETY ONCE LD. CIT(A) WAS OF THE VIEW THAT INCOME IS NOT TAXABLE IN THE IMPUGNED AY IT WOULD HAVE BEEN BETTER IF SHE HAD NO T COMMENTED UPON THE NATURE OF LAND AND LEFT IT TO BE DECIDED B Y AUTHORITIES CONCERNED WHILE DECIDING THE ISSUE RELATING TO TAXA BILITY OF THE SAID INCOME IN THE A.Y. 2008-09. THE FINDING OF LD. CIT( A), IN OUR VIEW, HAS CAUSED SERIOUS PREJUDICE TO ASSESSEE AS HE HAS BEEN PRECLUDED FROM RAISING THE ISSUE OF NATURE OF LAND IN THE APPROPRIATE ASSESSMENT YEAR. ACCORDINGLY, WE EXPUNGE THE OBSERV ATIONS OF LD. CIT(A) WITH REGARD TO NATURE OF LAND AND OBSERVE TH AT THE AUTHORITIES CONCERNED WHILE DECIDING THE ISSUE RELA TING TO NATURE OF LAND IN A.Y. 2008-09 SHOULD NOT GET INFLUENCED WITH THE OBSERVATIONS MADE BY LD. CIT(A) IN THE IMPUGNED A.Y . AND DECIDE THE ISSUE INDEPENDENTLY ON THE BASIS OF EVIDENCES O N RECORD AND IN ACCORDANCE WITH LAW. 14. THE NEXT ISSUE AS RAISED IN C.O. IS WITH REGARD TO THE OBSERVATIONS MADE BY AO AS WELL AS LD. CIT(A) IN SO FAR AS INVESTMENTS MADE TOWARDS PURCHASE OF LAND OF M/S MV R SECURITIES PVT. LTD. 15. HAVING HEARD THE PARTIES, WE ARE OF THE VIEW TH AT THIS ISSUE IS OF MERE ACADEMIC INTEREST. THE LD. COUNSELS FOR BOT H THE PARTIES ALSO AGREED TO THIS POSITION. ACCORDINGLY, THE GROU NDS RAISED ARE DISMISSED AS INFRUCTUOUS. 16. IN THE RESULT, C.O. FILED BY ASSESSEE IS PARTLY ALLOWED. 9 ITA NO. 269 /HYD/2013 & C.O. NO. 23/H/13 SRI VENKATESWARA EDUCATIONAL SOCIETY 17. TO SUM UP, DEPARTMENTS APPEAL IS DISMISSED AND C.O. OF ASSESSEE IS PARTLY ALLOWED. PRONOUNCED IN THE OPEN COURT ON 20/02/2015. SD/- SD/- (P.M. JAGTAP) (SAKTIJIT DEY) ACCOUNTANT MEMBER JUDICIAL MEMBER HYDERABAD, DATED: 20 TH FEBRUARY, 2015 KV COPY TO:- 1) ASST. DIRECTOR OF INCOME-TAX (EXEMPTIONS)-III, 3 RD FLOOR, AAYAKAR BHAVAN, BASHEERBAGH, HYD 04. 2) SRI VENKATESWARA EDUCATIONAL SOCIETY, 7-128, TUKKUGUDA VILLAGE, MAHESWARAM MANDAL, RR DIST. 3) CIT(A)-IV, HYDERABAD 4) DIT(EXEMPTIONS), HYDERABAD 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDE RABAD.