Viceroy Hotels Ltd., Hyd, Hyderabad V. DCIT, Circle-3(3), Hyderabad, Hyderabad

ITA 292/HYD/2016

• Counselvise Citation: [2017] 128 COUNSELVISE.COM (IT) 2447 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 2 month(s) 25 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-06-2017
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Next Hearing Date: 03-05-2017
• Assessment Year: 2006-2007
• Appeal Filed On: 14-03-2016
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: U MINICHANDRAN
• Assessee Lawyers: P MURALI MOHAN RAO
• Keywords: Opportunity of being heard; Proportionate interest; Question of law; Right to appeal
• Section: 43B; 143(3); 14A

Judgement Text

ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 1 OF 10 IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD B BENCH, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER ITA NO.292/HYD/2016 (ASSESSMENT YEAR: 2006-07) M/S. VICEROY HOTELS LTD HYDERABAD PAN: AABCP 2279 G VS DCIT, CIRCLE 3 (3) HYDERABAD FOR ASSESSEE : SHRI P. MURALI MOHAN RAO FOR REVENUE : SMT. U. MINI CHANDRAN, DR O R D E R PER SMT. P. MADHAVI DEVI, J.M. THIS IS ASSESSEES APPEAL FOR THE A.Y 2006-07. IN TH IS APPEAL, THE ASSESSEE HAS RAISED THE FOLLOWING GROUN DS OF APPEAL: 1. THE LD. COMMISSIONER OF INCOME TAX(APPEALS)-5, HYDERABAD ERRED BOTH IN LAW AND ON FACTS IN PASSING THE ORDER TO THE EXTENT IT IS PREJUDICIAL TO THE INTEREST OF THE ASSESSEE. 2. THE LD. COMMISSIONER OF INCOME TAX(APPEALS) ERRED IN CONFIRMING THE DISALLOWANCE OF INTEREST TO THE EXTENT OF RS.17 ,52,000/- 3. THE LD. COMMISSIONER OF INCOME TAX(APPEALS), WHILE CONFIRMING THE DISALLOWANCE OF RS.17,52,000/-, OUGHT TO HAVE APPRECIATED THAT THE IMPUGNED DATE OF HEARING : 04.05.2017 DATE OF PRONOUNCEMENT : 09.06.2017 ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 2 OF 10 INVESTMENT HAD BEEN MADE OUT OF THE APPELLANT'S OWN FUNDS. 4. THE LD. COMMISSIONER OF INCOME TAX(APPEALS) ERRED IN CONFIRMING THE DISALLOWANCE OF RS. 1,62,300/- 5. THE LD. COMMISSIONER OF INCOME TAX(APPEALS), WHILE CONFIRMING THE DISALLOWANCE OF RS.1,62,300/- OUGHT TO HAVE APPRECIATED THAT OUT OF THE TOTAL PAYMENT OF INSURANCE OF RS.30,76,827/-, RS.28,88,890/- PERTAINS TO THE YEAR OF ACCOUNT AND THE BALANCE AMOUNT RELATES TO EARLIER YEARS. 6. THE LD. COMMISSIONER OF INCOME TAX(APPEALS) ERRED IN NOT ADJUDICATING ON THE DISALLOWANCE MADE U/S 43B OF THE ACT FOR RS.21,75,031/- 7. AS PER THE RATIO LAID DOWN BY THE HON'BLE SUPREME COURT IN THE CASE OF NATIONAL THERMAL POWER CO. LTD V. CIT (1998) 229 ITR 383 (SC), THE HON'BLE ITAT HAS JURISDICTION TO EXAMINE THE QUESTION OF LAW WITH REGARD TO THE ADDITION OF RS.21,75,031/-, WHICH IS NOW RAISED BEFORE THE ITAT FOR THE FIRST TIME, -THOUGH IT HAS NOT BEEN RAISED BEFORE THE FIRST APPELLATE AUTHORITY. 8. THE ASSESSEE MAY ADD, ALTER OR MODIFY OR SUBSTITUTE ANY OTHER POINTS TO THE GROUNDS OF APPEAL AT ANY TIME BEFORE OR AT THE TIME OF HEARING OF THE APPEAL. 2. AT THE TIME OF HEARING, THE LEARNED COUNSEL FOR THE ASSESSEE SUBMITTED THAT GROUNDS OF APPEAL NO.6 & 7 ARE ADDITIONAL GROUNDS OF APPEAL RAISED BEFORE THE INCO ME TAX APPELLATE TRIBUNAL FOR THE FIRST TIME AND AN APPLIC ATION FOR ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 3 OF 10 ADMISSION OF THESE ADDITIONAL GROUNDS OF APPEAL HAS BEEN FILED. IT WAS THEREFORE, PRAYED THAT THE SAME MAY BE ADMITTED . HOWEVER, ON POINTING OUT THAT THE ACTUAL GRIEVANCE OF THE AS SESSEE IS NOT REFLECTED IN THE GROUNDS OF APPEAL AS RAISED ABOVE, THE ASSESSEE, VIDE LETTER DATED 4.5.2017, HAS FILED ANOTHER APPLI CATION RAISING THE FOLLOWING ADDITIONAL GROUND OF APPEAL: ADDITIONAL GROUNDS OF APPEAL 9. THE AO ERRED IN DISALLOWING THE GRATUITY OF RS.21,75,031/- U/S 43B WITHOUT APPRECIATING THE FACT THAT THIS IS AN OPENING BALANCE. 10. THE AO OUGHT TO HAVE APPRECIATED THE FACT THAT THE PROVISIONS OF SECTION 43B CANNOT BE INVOKED FOR DISALLOWANCE OF GRATUITY AND WHICH IS AN OPENING BALANCE. 11. THE AO OUGHT TO HAVE APPRECIATED THE FACT THAT THE ASSESSEE HAS MAINTAINED ITS BOOKS OF ACCOUNT AS PER ACCOUNTING STANDARDS ISSUED BY ICAI AND METHOD OF ACCOUNTING FOLLOWED BY ASSESSEE COULD NOT BE DISCARDED AND EXPENDITURE ENTITLED CANNOT BE DENIED. 12. THE AO OUGHT TO HAVE APPRECIATED THE FACT THAT GRATUITY IS SCIENTIFICALLY DERIVED AND IS ALLOWABLE IRRESPECTIVE OF PAID OR PAYABLE. 3. BRIEF FACTS OF THE CASE LEADING TO THE ABOVE APP EAL ARE THAT THE ASSESSEE COMPANY, WHICH IS ENGAGED IN THE BUSINESS OF RUNNING OF HOTELS, FILED ITS RETURN OF INCOME FOR T HE A.Y 2006-07 ON 30.11.2006 DECLARING A LOSS OF RS.(-)2,63,20,925/-. DURING THE ASSESSMENT PROCEEDINGS U/S 143(3) OF THE ACT, AO PE RUSED THE AUDIT REPORT FILED BY THE ASSESSEE WHEREIN IT WAS M ENTIONED THAT THE GRATUITY IS SHOWN AS PAYABLE AT RS.21,75,031. O BSERVING THAT ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 4 OF 10 ONLY THE SUMS WHICH ARE PAID BY THE ASSESSEE ARE AL LOWABLE U/S 43B(B) OF THE ACT, THE AO DISALLOWED THE SAME AND B ROUGHT IT TO TAX. FURTHER, THE AO ALSO OBSERVED THAT THE ASSESSE E HAS MADE INVESTMENT TO THE TUNE OF RS.1.46 CRORES IN M/S. MA YURI INDIA CUISINE INC AND THAT THIS INVESTMENT IS MADE IN ORD ER TO EARN THE DIVIDEND INCOME WHICH IS EXEMPT FROM TAX. THE AO HE LD THAT THE PROPORTIONATE INTEREST IS NOT ALLOWABLE. FURTHER, TH E AO ALSO OBSERVED THAT THE ASSESSEE IS PAYING INTEREST ON BO RROWED FUND BUT IS NOT GETTING ANY TAXABLE INCOME ON THE INVEST MENTS MADE. THEREFORE, HE CALCULATED THE PROPORTIONATE INTEREST AT 12% ON THE INVESTMENT OF RS.1.46 CRORES AND DISALLOWED THE INT EREST OF RS.17,52,000. 4. FURTHER, AS PER THE P&L A/C, THE AO OBSERVED THAT THE ASSESSEES INSURANCE CLAIM IS RS.28,88,890, BUT AS PER THE ACCOUNT COPY FURNISHED BY THE ASSESSEE, THE ASSESSE E HAS PAID ONLY A SUM OF RS.27,26,590. THEREFORE, HE BROUGHT T HE DIFFERENCE OF RS.1,62,300 TO TAX. AGGRIEVED, THE ASSESSEE PREF ERRED AN APPEAL BEFORE THE CIT (A) ONLY AGAINST THE DISALLOWANCE OF INTEREST ON INVESTMENTS AND ALSO AGAINST THE DISALLOWANCE OF TH E INSURANCE CLAIM OF RS.1,62,300. THE CIT (A) CONFIRMED THE DIS ALLOWANCES AND THE ASSESSEE IS IN SECOND APPEAL BEFORE US RAISING GROUNDS OF APPEAL 1 TO 5 AGAINST THE ADDITIONS CONFIRMED BY TH E CIT (A) AND ALSO GROUNDS 6 & 7 AGAINST THE DISALLOWANCE MADE U/ S 43B(B) OF THE ACT. 5. AS REGARDS THE DISALLOWANCE U/S 43B(B) OF THE AC T, THE ASSESSEE HAS RAISED THE ADDITIONAL GROUNDS OF APPEA L. IT IS ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 5 OF 10 SUBMITTED THAT THE AMOUNT DISALLOWED BY THE AO IS T HE OPENING BALANCE OF PROVISION FOR GRATUITY AND HAS NOT ACCRU ED DURING THE RELEVANT PREVIOUS YEAR AND THEREFORE, NO DISALLOWAN CE CAN BE MADE IN THIS A.Y. HE FILED BEFORE US A COPY OF THE LEDGER ACCOUNT TO DEMONSTRATE THAT THE OPENING BALANCE OF THE GRAT UITY PAYMENT WAS RS.23,29,548 AND THE CLOSING BALANCE WAS RS.21, 75,031.73 AND THUS, THERE IS NO CLAIM OF DEDUCTION FOR GRATUI TY AS PAID BY THE ASSESSEE. 6. THE LEARNED DR, ON THE OTHER HAND, OBJECTED TO T HE ADMISSION OF THE ADDITIONAL GROUNDS OF APPEAL STATI NG THAT IT IS NOT A LEGAL GROUND OF APPEAL AND ALSO NEEDS FACTUAL VER IFICATION. SHE ALSO PLACED RELIANCE UPON THE JUDGMENT OF THE HON'B LE SUPREME COURT IN THE CASE OF HON'BLE SUPREME COURT IN THE C ASE OF NTPC LTD. 229 ITR 283 (SC) IN SUPPORT OF HER CONTENTION. 7. HAVING REGARD TO THE RIVAL CONTENTIONS AND THE M ATERIAL ON RECORD, WE FIND THAT, NO DOUBT, THE GROUNDS 6 AN D 7 WHICH ARE RAISED AS ADDITIONAL GROUNDS OF APPEAL ARE NOT ON L EGAL PRINCIPLES, BUT THAT THERE IS NO CLAIM DURING THE RELEVANT F.Y. T HE HON'BLE SUPREME COURT IN THE CASE OF NTPC (SUPRA) HAS HELD THAT: 4. THE TRIBUNAL HAS FRAMED AS MANY AS FIVE QUESTIONS WHILE MAKING A REFERENCE TO US. SINCE THE TRIBUNAL HAS NOT EXAMINED THE ADDITIONAL GROUNDS RAISED BY THE ASSESSEE ON THE MERITS, WE DO NOT PROPOSE TO ANSWER THE QUESTIONS RELATING TO THE MERITS OF THOSE CONTENTIONS. WE REFRAME THE QUESTION WHICH ARISES FOR OUR CONSIDERATION IN ORDER TO BRING OUT THE POINT WHICH REQUIRES DETERMINATION MORE CLEARLY. IT IS AS FOLLOWS: ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 6 OF 10 WHERE ON THE FACTS FOUND BY THE AUTHORITIES BELOW A QUESTION OF LAW ARISES (THOUGH NOT RAISED BEFORE THE AUTHORITIES) WHICH BEARS ON THE TAX LIABILITY O F THE ASSESSEE, WHETHER THE TRIBUNAL HAS JURISDICTION TO EXAMINE THE SAME ? 5. UNDER SECTION 254 OF THE INCOME-TAX ACT, THE APPELLATE TRIBUNAL MAY, AFTER GIVING BOTH THE PARTIES TO THE APPEAL AN OPPORTUNITY OF BEING HEARD, PASS SUCH ORDERS THEREON AS IT THINKS FIT. THE POWER OF THE TRIBUNAL IN DEALING WITH APPEALS IS THUS EXPRESSED IN THE WIDEST POSSIBLE TERMS. THE PURPOSE OF THE ASSESSMENT PROCEEDINGS BEFORE THE TAXING AUTHORITIES IS TO ASSESS CORRECTLY THE TAX LIABILITY OF AN ASSESSEE IN ACCORDANCE WITH LAW. IF , FOR EXAMPLE, AS A RESULT OF A JUDICIAL DECISION GIV EN WHILE THE APPEAL IS PENDING BEFORE THE TRIBUNAL, IT IS FOUND THAT A NON-TAXABLE ITEM IS TAXED OR A PERMISSIBLE DEDUCTION IS DENIED, WE DO NOT SEE ANY REASON WHY THE ASSESSEE SHOULD BE PREVENTED FROM RAISING THAT QUESTION BEFORE THE TRIBUNAL FOR THE FIRST TIME, SO LONG AS THE RELEVANT FACTS ARE ON RECORD IN RESPECT OF THAT ITEM. WE DO NOT SEE ANY REASON TO RESTRICT THE POWER OF THE TRIBUNAL UNDER SECTION 254 ONLY TO DECIDE THE GROUNDS WHICH ARISE FROM THE ORDER OF THE COMMISSIONER OF INCOME-TAX (APPEALS). BOTH THE ASSESSEE AS WELL AS THE DEPARTMENT HAVE A RIGHT TO FILE AN APPEAL/CROSS-OBJECTIONS BEFORE THE TRIBUNAL. WE FAIL TO SEE WHY THE TRIBUNAL SHOULD BE PREVENTED FROM CONSIDERING QUESTIONS OF LAW ARISING IN ASSESSMENT PROCEEDINGS ALTHOUGH NOT RAISED EARLIER. 6. IN THE CASE OF JUTE CORPORATION OF INDIA LTD. V. C.I.T . . THIS COURT, WHILE DEALING WITH THE POWERS OF THE APPELLATE ASSISTANT COMMISSIONER OBSERVED THAT AN APPELLATE AUTHORITY HAS ALL THE POWERS WHICH THE ORIGINAL AUTHORITY MAY HAVE IN DECIDING THE QUESTION BEFORE IT SUBJECT TO THE RESTRICTIONS OR LIMITATIONS, IF ANY, PRESCRIBED BY THE STATUTORY PROVISIONS. IN THE ABSENCE OF ANY STATUTORY PROVISION, THE APPELLATE AUTHORITY IS VESTED WITH ALL THE PLENARY POWERS WHICH THE SUBORDINATE AUTHORITY MAY HAVE IN THE MATTER. THERE IS NO GOOD REASON TO JUSTIFY CURTAILMENT OF THE POWER OF ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 7 OF 10 THE APPELLATE ASSISTANT COMMISSIONER IN ENTERTAINING AN ADDITIONAL GROUND RAISED BY THE ASSESSEE IN SEEKING MODIFICATION OF THE ORDER OF ASSESSMENT PASSED BY THE INCOME-TAX OFFICER. THIS COURT FURTHER OBSERVED THAT THERE MAY BE SEVERAL FACTORS JUSTIFYING THE RAISING OF A NEW PLEA IN AN APPEAL AND EACH CASE HAS TO BE CONSIDERED ON ITS OWN FACTS. THE APPELLATE ASSISTANT COMMISSIONER MUST BE SATISFIED THAT THE GROUND RAISED WAS BONA FIDE AND THAT THE SAME COULD NOT HAVE BEEN RAISED EARLIER FOR GOOD REASONS. THE APPELLATE ASSISTANT COMMISSIONER SHOULD EXERCISE HIS DISCRETION IN PERMITTING OR NOT PERMITTING THE ASSESSEE TO RAISE AN ADDITIONAL GROUND IN ACCORDANCE WITH LAW AND REASON. THE SAME OBSERVATIONS WOULD APPLY TO APPEALS BEFORE THE TRIBUNAL ALSO. 7. THE VIEW THAT THE TRIBUNAL IS CONFINED ONLY TO ISSUES ARISING OUT OF THE APPEAL BEFORE THE COMMISSIONER OF INCOME-TAX (APPEALS) TAKES TOO NARROW A VIEW OF THE POWERS OF THE APPELLATE TRIBUNAL [VIDE, E.G., C.I.T, V. ANAND PRASAD (DELHI), C.I.T . V. KARAMCHANDPREMCHAND P. LTD. AND C.I.T. V. CELLULOSE PRODUCTS OF INDIA LTD . . UNDOUBTEDLY, THE TRIBUNAL WILL HAVE THE DISCRETION TO ALLOW OR NOT ALLOW A NEW GROUND TO BE RAISED. BUT WHERE THE TRIBUNAL IS ONLY REQUIRED TO CONSIDER A QUESTION OF LAW ARISING FROM THE FACTS WHICH ARE ON RECORD IN THE ASSESSMENT PROCEEDINGS WE FAIL TO SEE WHY SUCH A QUESTION SHOULD NOT BE ALLOWED TO BE RAISED WHEN IT IS NECESSARY TO CONSIDER THAT QUESTION IN ORDER TO CORRECTLY ASSESS THE TAX LIABILITY OF AN ASSESSEE. 8. THE REFRAMED QUESTION, THEREFORE, IS ANSWERED IN THE AFFIRMATIVE, I.E., THE TRIBUNAL HAS JURISDICTION TO EXAMINE A QUESTION OF LAW WHICH ARISES FROM THE FACTS AS FOUND BY THE AUTHORITIES BELOW AND HAVING A BEARING ON THE TAX LIABILITY OF THE ASSESSEE. WE REMAND THE PROCEEDINGS TO THE TRIBUNAL FOR CONSIDERATION OF THE NEW GROUNDS RAISED BY THE ASSESSEE ON THE MERITS. ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 8 OF 10 THUS, THE HON'BLE SUPREME COURT HAS CLEARLY LAID DO WN THAT THIS TRIBUNAL HAS THE POWER TO CONSIDER ANY ISSUE TO COR RECTLY ASSESS THE TAX LIABILITY OF AN ASSESSEE. AS PER THE ARTICL E 265 OF THE CONSTITUTION OF INDIA, THE GOVT. HAS TO COLLECT THE TAX ONLY IN ACCORDANCE WITH LAW AND THEREFORE, THE AO IS REQUIR ED TO COMPUTE THE INCOME IN ACCORDANCE WITH LAW. THE QUESTION BEF ORE US IS NOT QUANTIFICATION OF THE DISALLOWANCE U/S 43B(B) BUT I T IS WHETHER THE GRATUITY DISALLOWED HAD ACCRUED TO THE ASSESSEE AT ALL DURING THE RELEVANT PREVIOUS YEAR AND WHETHER THE ASSESSEE HAS MADE ANY CLAIM OF THE GRATUITY PAYMENT. IF THERE IS NO CLAIM OF GRATUITY FOR THE RELEVANT A.Y, THEN THE QUESTION OF DISALLOWANCE ALSO WOULD NOT ARISE. FOR DETERMINATION OF THIS ASPECT, WE ARE OF T HE OPINION THAT VERIFICATION OF FRESH FACTS IS NOT NEEDED AS THE AS SESSEES BOOKS OF ACCOUNT WOULD CLEARLY REFLECT WHETHER THERE IS ANY CLAIM OF DEDUCTION FOR THE RELEVANT PREVIOUS YEAR. IN VIEW O F THE SAME, WE ARE INCLINED TO ADMIT THE ADDITIONAL GROUNDS OF APP EAL FILED BY THE ASSESSEE AND REMIT THE ISSUE TO THE FILE OF THE AO WITH A DIRECTION TO VERIFY THE CLAIM OF THE ASSESSEE AND TO ADJUDICA TE THE SAME IN ACCORDANCE WITH LAW. 8. AS REGARDS GROUNDS 2 AND 3 ARE CONCERNED, IT IS SEEN THAT M/S. MAYURI INDIA CUSINE INC. IS A FOREIGN COM PANY AND THE DIVIDEND INCOME EARNED FROM SUCH A NONRESIDENT COMP ANY IS NOT EXEMPT FROM TAX BUT IS TAXABLE UNDER THE CATEGORY INCOME FROM OTHER SOURCES. THEREFORE, THE PROVISIONS OF SECTIO N 14A WOULD NOT COME INTO PLAY. THE AO HAS CLEARLY ERRED IN OBSERVI NG THAT THE INTENTION OF THE ASSESSEE IS TO MAKE THE INVESTMENT TO EARN THE DIVIDEND INCOME WHICH IS EXEMPT FROM TAX. IN VIEW O F THE SAME, WE DIRECT THE AO TO DELETE THE DISALLOWANCE OF RS.1 7,52,000 MADE ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 9 OF 10 BY THE AO TOWARDS THE PROPORTIONATE INTEREST DEBITE D TO THE P&L A/C. THUS, GROUNDS 2 & 3 ARE ALLOWED. 9. AS REGARDS GROUNDS 4 & 5, AFTER HEARING BOTH THE PARTIES, WE FIND THAT IT IS NOT CLEAR AS TO HOW THE AO HAS ARRIVED AT THE FIGURE OF RS.1,62,300 AS BEING THE DIFFERENCE B ETWEEN THE AMOUNT CLAIMED AND THE AMOUNT PAID BY THE ASSESSEE. AS SEEN FROM PAGE NO.9 OF THE PAPER BOOK FILED BEFORE US, T HE TOTAL OF THE INSURANCE PAID BY THE ASSESSEE IS RS.28,88,890 WHER EAS THE AO MENTIONED THAT THE CLAIM OF THE ASSESSEE IS RS.30,7 6,827. WE FIND THAT EVEN THE CIT (A) HAS NOT VERIFIED THE ASSESSEE S CLAIM AND HAS MENTIONED PAYMENT AS RS.27,26,590 WITHOUT ANY BASIS . IN VIEW OF THE SAME, WE SET ASIDE THE ISSUE TO THE FILE OF THE AO TO VERIFY THE CLAIM OF THE ASSESSEE AND IF THERE IS NO DIFFERENCE IN THE PAYMENT OF INSURANCE AND THE CLAIM, THEN NO ADDITION SHALL BE MADE. 10. IN THE RESULT, ASSESSEES APPEAL IS PARTLY ALLO WED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 9 TH JUNE, 2017. SD/- SD/- (B. RAMAKOTAIAH ACCOUNTANT MEMBER (P. MADHAVI DEVI) JUDICIAL MEMBER HYDERABAD, DATED 9 TH JUNE, 2017. VINODAN/SPS ITA NO 292 OF 2016VICE ROY HOTELS LTD HYDERABAD PAGE 10 OF 10 COPY TO: 1 P. MURALI & CO. CAS, 6-3-655/2/3, 1 ST FLOOR, SOMAJIGUDA, HYDERABAD 500082 2 DCIT CIRCLE 3(3) HYDERABAD 3 CIT (A)-5 HYDERABAD 4 PR. CIT 5 HYDERABAD 5 THE DR, ITAT HYDERABAD 6 GUARD FILE BY ORDER