M/s. Century Real Estate Holdings Private Limited, Bangalore V. The Assistant Commissioner Of Income Tax, Central Circle- 2(2), Bangalore

ITA 284/BANG/2020

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 0173 (ITAT-BANGALORE)
• Duration Of Justice: 3 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-06-2020
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 18-06-2020
• Assessment Year: 2014-2015
• Appeal Filed On: 02-03-2020
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: MUZAFFAR HUSSAIN
• Keywords: Earning of tax free income; Rule 8D
• Section: 14A

Judgement Text

ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU IN THE INCOME TAX APPELLATE TRIBUNAL BBENCH: BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENTAND SHRI B.R. BASKARAN, ACCOUTANT MEMBER ITA NOS.284/BANG/2020 ASSESSMENTYEAR: 2014-15 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD. NO.10/1, GROUND FLOOR LAKSHMINARAYANA COMPLEX PALACE ROAD BENGALURU-560 052. PAN NO :AADCC0651M VS. THE ASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2) BANGALORE APPELLANT RESPONDENT S.P. NO.113/BANG/2020 (ARISING OUT OF ITA NOS.284/BANG/2020) ASSESSMENT YEAR: 2014-15 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD. NO.10/1, GROUND FLOOR LAKSHMINARAYANA COMPLEX PALACE ROAD BENGALURU-560 052. VS. THEASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2) BANGALORE APPELLANT RESPONDENT APPELLANT BY : SMT. SHEETAL BORKAR, A.R. RESPONDENT BY : SHRI MUZAFFAR HUSSAIN, D.R. DATE OF HEARING : 18.06.2020 DATE OF PRONOUNCEMENT : 24.06.2020 ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 2 OF 11 O R D E R PER B.R. BASKARAN, ACCOUNTANT MEMBER: THIS APPEAL AND STAY PETITION HAVE BEEN FILED BY T HE ASSESSEE AND THEY RELATE TO ASSESSMENT YEAR 2014-15 . THE APPEAL IS DIRECTED AGAINST ORDER DATED 11.2.202 0 PASSED BY LD. CIT(A)-11, BENGALURU. THE GROUNDS OF APPEAL URGED BY THE ASSESSEE READ AS UNDER: 1. THE LEARNED CIT(A) HAS ERRED IN PASSING THE ORDER I N THE MANNER WHICH SHE DID. 2. THE LEARNED CIT(A) IS WRONG IN LAW BY CONFIRMING TH E ADDITIONS OF THE ASSESSING OFFICER AND PASSING THE ORDER WITHOUT CONSIDERING THE SUBMISSIONS OF THE APPELLANT. 3. THE LEARNED CIT(A) IS WRONG IN LAW IN CONFIRMING TH E ADDITION MADE BY THE ASSESSING OFFICER U/S 14A R.W. RULE 8D OF THE ACT. 4. THE LEARNED CIT(A) HAS ERRED IN NOT RECORDING THE SATISFACTION BEFORE PROCEEDING TO INVOKE THE PROVISIONS OF S.14A R.W. RULE 8D OF THE ACT. 5. THE LEARNED CIT(A) OUGHT TO HAVE APPRECIATED THAT N O EXPENDITURE IS INCURRED TO INVOKE S.14A SINCE MOST OF THE INVESTMENTS ARE CARRIED FORWARD FROM THE PREVIOUS YEAR. 6. THE LEARNED CIT(A) OUGHT TO HAVE APPRECIATED THAT THE APPELLANT HAD SUFFICIENT FUNDS OF ITS OWN, THER EBY MAKING THE DISALLOWANCE U/S 14A R.W. RULE 8D UNWARRANTED. 7. THE LEARNED CIT(A) FURTHER, FAILED TO APPRECIATE TH AT THE DISALLOWANCE MADE IN MUCH MORE THAN THE EXEMPT INCOME. 8. WITHOUT PREJUDICE, THE DISALLOWANCE IS EXCESSIVE, ARBITRARY, UNREASONABLE AND OUGHT TO BE DELETED. ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 3 OF 11 9. FOR THESE AND OTHER GROUNDS THAT MAY BE URGED AT THE TIME OF HARING OF THE APPEAL, THE APPELLANT PRA YS THAT THE APPEAL MAY BE ALLOWED. 2. ALL THE GROUNDS URGED BY THE ASSESSEE ARE DIREC TED AGAINST THE DISALLOWANCE MADE U/S 14A OF THE ACT. THE FACTS RELATING THERETO ARE DISCUSSED IN BRIEF. THE ASSESSEE IS A REAL ESTATE DEVELOPER. DURING THE YEAR UNDER CONSIDERATION, THE ASSESSEE HAS RECEIVED FOLLOWING INCOME, WHICH WERE CLAIMED AS EXEMPT: A) SHARE OF PROFIT FROM PARTNERSHIP FIRM RS.1,02,01,474/- B) DIVIDEND FROM MUTUAL FUNDS - RS.2,04,183/- TOTAL EXEMPT INCOME RS.1,04,05,657/- THE ASSESSEE DID NOT MAKE ANY DISALLOWANCE U/S 14A OF THE ACT. THE A.O. NOTICED THAT THE AMOUNT TO BE DISALLOWED U/S 14A OF THE ACT AS PER WORKINGS GIVEN RULE 8D OF INCOME TAX RULES IS RS.20,92,40,552/-. ACCORDINGLY, THE AO ISSUED A SHOW CAUSE NOTICE TO T HE ASSESSEE TO EXPLAIN AS TO WHY THE ABOVE SAID AMOUNT SHOULD NOT BE DISALLOWED U/S 14A OF THE ACT. IN RE PLY THERETO, THE ASSESSEE SUBMITTED THAT IT DID NOT INC UR ANY EXPENSE DURING THE YEAR FOR EARNING EXEMPT INCOME; THAT MOST OF THE INVESTMENTS HAVE BEEN BROUGHT FORWARD F ROM EARLIER YEAR; THAT THE INVESTMENTS IN EQUITY AND PR EFERENCE SHARES HAVE BEEN MADE OUT OF OWN FUNDS AND THAT THE INVESTMENTS MADE IN ASSOCIATE AND SUBSIDIARY COMPAN IES ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 4 OF 11 ARE STRATEGIC INVESTMENTS IN THE NATURE OF EQUITY A ND PREFERENCE SHARES. THE ASSESSEE ALSO CONTENDED THA T, ACCORDING ITS OWN WORKINGS, THE DISALLOWANCE U/S 14 A OF THE ACT WORKS OUT TO RS.7,54,468/- ONLY. 3. THE A.O. DID NOT ACCEPT THE CONTENTIONS OF TH E ASSESSEE HOWEVER, HE COMPUTED THE DISALLOWANCE AT RS.19.95 CRORES; WHICH CONSISTED OF INTEREST DISALL OWANCE OF RS.18.65 CRORES UNDER RULE 8D(2)(II) AND DISALLO WANCE OF RS.1.28 CRORES OUT OF ADMINISTRATIVE EXPENSES UNDER RULE 8D(2)(III). THE AO COMPLETED THE ASSESSMENT BY MAK ING DISALLOWANCE OF RS.19.95 CRORES U/S 14A OF THE ACT. 4. IN THE APPELLATE PROCEEDINGS BEFORE LD CIT(A), T HE ASSESSEE CONTENDED THAT THE AO HAS NOT RECORDED DISSATISFACTION BEFORE INVOKING PROVISIONS OF RULE 8D. IT WAS FURTHER SUBMITTED THAT MAJORITY OF THESE INVEST MENTS HAVE BEEN MADE IN THE PARTNERSHIP FIRMS AND THE ASS ESSEE HAS EARNED INTEREST INCOME AS WELL AS CROSS CHARGED EXPENDITURE ALSO TO THE PARTNERSHIP FIRMS. IT WAS ALSO SUBMITTED THAT THE A.O. SHOULD HAVE CONSIDERED ONLY THOSE INVESTMENTS, WHICH HAVE YIELDED EXEMPT INCOME . WITHOUT PREJUDICE TO THE ABOVE, IT WAS ALSO CONTEND ED THAT THE DISALLOWANCE U/S 14A OF THE ACT SHOULD BE RESTR ICTED TO THE AMOUNT OF EXEMPT INCOME. ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 5 OF 11 5. THE LD. CIT(A) REJECTED THE CONTENTIONS OF THE ASSESSEE THAT THE AO DID NOT RECORD DISSATISFACTION BY OBSER VING THAT THE AO HAS DULY LOOKED INTO THE ACCOUNTS OF TH E ASSESSEE. WITH REGARD TO OTHER ARGUMENTS OF THE ASS ESSEE, THE LD CIT(A) TOOK SUPPORT OF THE CBDT CIRCULAR NO.5/2014 DATED 11.2.2014, WHICH STATED THAT THE DISALLOWANCE U/S 14A OF THE ACT SHOULD BE MADE EVEN IF THE TAX PAYERS HAS NOT EARNED ANY EXEMPT INCOME, AN D REJECTED ALL OTHER ARGUMENTS. ACCORDINGLY, HE CONF IRMED DISALLOWANCE MADE BY THE A.O. AGGRIEVED, THE ASSESS EE HAS FILED THIS APPEAL BEFORE US. 6. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE RECORDS. THE GROUND NOS. 1, 2, 3, 5, 8 AND 9 ARE GE NERAL IN NATURE. GROUND NO.4 IS RELATED TO NON-RECORDING OF DISSATISFACTION. AS RIGHTLY POINTED OUT THAT THE L D CIT(A), WE NOTICE THAT THE AO HAS ISSUED SHOW CAUSE NOTICE TO THE ASSESSEE ON DUE EXAMINATION OF FINANCIAL STATEMENTS OF THE ASSESSEE, SINCE THE ASSESSEE DID NOT MAKE ANY DISALLOWANCE U/S 14A OF THE ACT, EVEN THOUGH IT HAD EARNED EXEMPT INCOME. HENCE THE DISSATISFACTION OF THE AO HAS BEEN DEMONSTRATED IN THE ASSESSMENT ORDER AN D IT IS NOT A CASE OF MECHANICAL INVOKING OF PROVISIONS OF RULE 8D. ACCORDINGLY WE REJECT GROUND NO.4 OF THE ASSES SEE. 7. IN GROUND NO.6, THE ASSESSEE IS CONTENDING T HAT THE ASSESSEE HAS GOT SUFFICIENT OWN FUNDS AND HENCE ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 6 OF 11 DISALLOWANCE U/S 14A IS NOT WARRANTED. BEFORE US, THE LD. A.R. SUBMITTED THAT THE OWN FUNDS AVAILABLE WIT H THE ASSESSEE IS IN EXCESS OF THE VALUE OF INVESTMENT MA DE IN SHARES AND HENCE THE A.O. SHOULD NOT HAVE DISALLOWE D ANY EXPENDITURE OUT OF INTEREST EXPENSES UNDER RULE 8D( 2)(II) OF I T RULES. IN THIS CONNECTION, LD. A.R. INVITED OUR ATTENTION TO THE COPIES OF BALANCE SHEET PLACED IN THE PAPER BOOK. ON A PERUSAL OF THE SAME, WE NOTICE TH AT THE LD. A.R. HAS CONSIDERED ONLY THE VALUE OF INVESTMEN TS MADE IN SHARES FOR ADVANCING THIS ARGUMENT AND DID NOT CONSIDER THE VALUE OF INVESTMENTS MADE IN PARTNERSH IP FIRM. WE HAVE NOTICED EARLIER THAT THE EXEMPT INCO ME EARNED BY THE ASSESSEE INCLUDED SHARE INCOME FROM PARTNERSHIP FIRM, WHICH IS EXEMPT U/S 10(2A) OF TH E ACT. HENCE, WE ARE OF THE VIEW THAT THE INVESTMENTS MADE IN PARTNERSHIP FIRM ARE ALSO REQUIRED TO BE CONSIDERED FOR COMPARING THE VALUE OF INVESTMENTS WITH THE AVAILAB LE OWN FUNDS. WE NOTICE THAT THE VALUE OF INVESTMENTS HELD BY THE ASSESSEE AS AT THE YEAR END IS RS.1,444.46 C RORES, WHEREAS THE OWN FUNDS AVAILABLE WITH THE ASSESSEE W AS RS.585.21 CRORES ONLY. HENCE, IT CANNOT BE SAID TH AT THE OWN FUNDS AVAILABLE WITH THE ASSESSEE WAS MORE THAN THE VALUE OF INVESTMENTS. HENCE, THIS ARGUMENT OF THE ASSESSEE ALSO FAILS ON THE ABOVE SAID FACTS. 8. BEFORE ADDRESSING GROUND NO.7, WE PREFER TO ADJ UDICATE TWO MORE CONTENTIONS URGED ORALLY BY LD A.R. THE F IRST ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 7 OF 11 CONTENTION OF LD A.R WAS THAT THE SHARE INCOME FROM PARTNERSHIP FIRM SHOULD NOT BE CONSIDERED AS EXEMPT INCOME, SINCE THE PROFITS OF PARTNERSHIP FIRM HAVE ALREADY SUFFERED TAX IN THE HANDS OF THE PARTNERSHIP FIRM. WE NOTICE THAT THE VERY SAME ISSUE WAS CONSIDERED BY AHMEDABAD SPECIAL BENCH OF ITAT IN THE CASE OF SHRI VISHNU ANAND MAHAJAN (ITA NO.3002/AHD/2009 DATED 25-05-2012) AND IDENTICAL CONTENTIONS MADE BY THE ASSESSEE WERE REJECTED BY HOLDING THAT, ONCE THE SH ARE INCOME IS EXCLUDED FROM THE TOTAL INCOME U/S 10(2A) OF THE ACT, THE PROVISIONS OF SECTION 14A OF THE ACT W OULD APPLY TO IT. HENCE, THIS CONTENTION OF THE ASSESSE E WOULD FAIL. 9. THE NEXT CONTENTION URGED BY THE ASSESSEE IS A PARTNER IN MANY FIRMS. SOME FIRMS HAVE EARNED PROF IT AND OTHER FIRMS HAVE INCURRED LOSS. SHE SUBMITTED THAT THE A.O. HAS CONSIDERED ONLY SHARE OF PROFIT RECEI VED FROM PARTNERSHIP FIRM FOR THE PURPOSES OF SEC.14A AND D ID NOT CONSIDER SHARE OF LOSS DIVIDED TO THE ASSESSEE. THE LD A.R SUBMITTED THAT THE SHARE OF PROFIT/LOSS FROM PARTNERSHIP FIRMS SHOULD BE CUMULATED AND IN THAT C ASE, NET RESULT WOULD BE ONLY LOSS FROM THE PARTNERSHIP FIRMS. HENCE THE AO SHOULD HAVE IGNORED THE SHARE OF PROFI T RECEIVED FROM SOME OF THE FIRMS FOR THE PURPOSES OF COMPUTING DISALLOWANCE UNDER SEC.14A OF THE ACT. W E DO NOT FIND ANY MERIT IN THIS CONTENTION OF THE ASSESS EE, SINCE ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 8 OF 11 WHAT IS EXEMPTED UNDER THE ACT IS SHARE INCOME RECE IVED FROM THE PARTNERSHIP FIRM U/S 10(2A) OF THE ACT, ME ANING THEREBY, THE PROFIT OR LOSS RECEIVED FROM THE PARTN ERSHIP FIRM DOES NOT ENTER INTO COMPUTATION OF INCOME AT A LL. HENCE THE QUESTION OF SETTING OFF INCOME FROM PARTN ERSHIP FIRM INTER SE DOES NOT ARISE. ACCORDINGLY, ONCE A P ARTICULAR INCOME DOES NOT ENTER INTO THE COMPUTATION ON THE G ROUND THE SAME IS EXEMPT, AS HELD BY SPECIAL BENCH IN THE CASE OF SRI VISHNU ANAND MAHAJAN (SUPRA), PROVISIONS OF SECTION 14A OF THE ACT WOULD APPLY. IN THIS CASE, THERE IS NO DISPUTE THAT THE SHARE INCOME FROM PARTNERSHIP F IRM TO THE TUNE OF RS.1,02,01,474/- HAS BEEN CLAIMED AS EX EMPT U/S 10(2A) OF THE ACT. HENCE THE PROVISIONS OF SEC .14A SHALL APPLY TO THE ABOVE SAID EXEMPT INCOME. 10. IN GROUND NO.7, THE ASSESSEE IS CONTENDING THA T THE DISALLOWANCE MADE BY THE TAX AUTHORITIES U/S 14A OF THE ACT IS MUCH MORE THAN EXEMPT INCOME. BEFORE US, TH E LD. A.R. SUBMITTED THAT THE QUANTUM OF DISALLOWANCE U/S 14A OF THE ACT SHOULD NOT EXCEED THE AMOUNT OF EXEMPT INCOME. IN SUPPORT OF THIS PROPOSITION, THE LD. A. R. PLACED RELIANCE ON THE DECISION RENDERED BY HONBLE HIGH COURT OF DELHI IN THE CASE OF JOINT INVESTMENT PRIV ATE LIMITED VS. CIT 372 ITR 694 AND ALSO THE DECISION RENDERED BY MUMBAI BENCH OF TRIBUNAL IN THE CASE OF FUTURE CORPORATE RESOURCES LIMITED VS. DCIT (ITA NO.4658/MUM/2015 DATED 26.7.2017). ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 9 OF 11 11. THE HONBLE DELHI HIGH COURT HAS CONSIDERED AN IDENTICAL ISSUE IN THE CASE OF PCIT VS. CARAF BUILD ERS & CONSTRUCTION (P) LTD (2019)(101 TAXMANN.COM 167) AN D HAS HELD AS UNDER:- 25. TOTAL EXEMPT INCOME EARNED BY THE RESPONDENT-ASSES SEE IN THIS YEAR WAS RS. 19 LAKHS. IN THESE CIRCUMSTANCES, WE ARE NOT REQUIRED TO CONSIDER THE CASE OF THE REVENUE THAT THE DISALLOWANCE SHOULD BE ENHANCED FROM RS. 75.89 CRORES TO RS. 144.52 CRORES. UPPER DISALLOWANCE AS HELD IN PR. CIT V. MCDONALDS INDIA (P.) LTD. ITA 725/2018 DECIDED ON 22ND OCTOBER, 2018 CANNOT EXCEED THE EXEMPT INCOME OF THAT YEAR. THE MUMBAI BENCH OF TRIBUNAL HAS ALSO TAKEN AN IDENTICAL VIEW IN THE CASE OF FUTURE CORPORATE RESO URCES LTD (SUPRA) AND THE RELEVANT OBSERVATIONS MADE BY T HE TRIBUNAL IN THE ABOVE SAID CASE ARE EXTRACTED BELOW :- 10. COMING TO THE SECOND ARGUMENT OF THE ASSESSEE, THE ASSESSEE ARGUED THAT IT HAD EARNED MEAGER DIVIDEND INCOME OF RS. 24,138 AS AGAINST WHICH, THE ASSESSIN G OFFICER DISALLOWED A SUM OF RS. 3,36,28,000 WHICH I S MORE THAN THE EXEMPT INCOME. THE ASSESSEE FURTHER ARGUED THAT DIS-ALLOWANCE UNDER SECTION 14A CANNOT EXCEED AMOUN T OF EXEMPT INCOME. THE ASSESSEE RELIED UPON CASE LAWS I N SUPPORT OF ITS ARGUMENTS. WE FIND THAT THE HONBLE DELHI HIGH COURT IN THE CASE OF JOINT INVESTMENTS (P.) ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 10 OF 11 LTD. (SUPRA) HELD THAT THE WINDOW FOR DIS ALLOWANCE IS INDICATED IN SECTION 14A AND IS ONLY TO THE EXTENT OF DISALLOWING EXPENDITURE INCURRED BY THE ASSESSEE IN RELATION TO TAX EXEMPT INCOME. THIS PROPORTION OR P ORTION OF THE TAX EXEMPT INCOME SURELY CANNOT SWALLOW THE ENT IRE AMOUNT AS HAS HAPPENED IN THIS CASE. WE FURTHER NOT ICE THAT THE HONBLE DELHI HIGH COURT IN THE CASE OF CIT V. HOLCIM INDIA (P.) LTD. (2014) 272 CTR 282 (DELHI) HAS HELD THAT THERE CAN BE NO DIS ALLOWANCE UNDER SECTION 14 A IN THE ABSENCE OF EXEMPT INCOME. THE RATIONALE BEHIND THESE JUDGMENTS IS THAT THE AMOUNT OF DIS ALLOWANCE CANNO T EXCEED EXEMPT INCOME. IN THIS CASE, ON PERUSAL OF T HE FACTS, WE FIND THAT THE ASSESSEE HAS EARNED EXEMPT INCOME OF RS. 24,138, WHEREAS THE ASSESSING OFFICER DISALLOWED AN AMOUNT OF RS. 3,36,28,000. THEREFORE, CONSIDERING THE FACTS AND CIRCUMSTANCES OF THE CASE AND ALSO FOLLOWING THE RATIOS OF THE CASE LAWS DISCUSSE D ABOVE, WE ARE OF THE VIEW THAT DIS ALLOWANCE UNDER SECTION 14A CANNOT EXCEED THE EXEMPT INCOME. HENCE, WE DIRECT T HE ASSESSING OFFICER TO RESTRICT DIS ALLOWANCE UNDER S ECTION 14A TO THE EXTENT OF EXEMPT INCOME EARNED BY THE ASSESSEE. THE ABOVE SAID DECISIONS WOULD SUPPORT THE CONTENTI ON OF THE ASSESSEE ON THIS POINT. ACCORDINGLY WE SET ASI DE THE ORDER PASSED BY LD CIT(A) ON THIS ISSUE AND DIRECT THE AO TO RESTRICT THE DISALLOWANCE U/A 14A TO THE AMOUNT OF EXEMPT INCOME . ITA NO.284/BANG/2020 & S.P. NO.113/BANG/2020 M/S. CENTURY REAL ESTATE HOLDINGS PVT. LTD., BENGAL URU PAGE 11 OF 11 12. SINCE APPEAL ITSELF IS DISPOSED OF, THE STAY PE TITION SHALL BECOME INFRUCTUOUS. 13. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PARTLY ALLOWED AND STAY PETITION IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 24.6.2020. SD/- (N.V. VASUDEVAN) VICE PRESIDENT SD/- (B.R. BASKARAN) ACCOUNTANT MEMBER BANGALORE, DATED 24 TH JUNE, 2020. VG/SPS COPY TO: 1. THE APPLICANT 2. THE RESPONDENT 3. THE CIT 4. THE CIT(A) 5. THE DR, ITAT, BANGALORE. 6. GUARD FILE BY ORDER ASST. REGISTRAR, ITAT, BANGALORE.