Appeal Details
Counselvise Citation
[2014] 140 COUNSELVISE.COM (IT) 75407 (ITAT-MUMBAI)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
9 month(s) 13 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
06-02-2014
Appeal Filed By
Assessee
Order Result
Allowed
Bench Allotted
K
Assessment Year
2008-2009
Appeal Filed On
23-04-2013
Judgement Text
, IN THE INCOME TAX APPELLATE TRIBUNAL K B ENCH, MUMBAI . . , , !'# , $ % BEFORE SHRI I.P. BANSAL, JM AND SHRI N.K. BILLAI YA, AM ./ I.T.A. NO.3104/MUM/2013 ( & & & & / ASSESSMENT YEAR : 2008-09 M/S. NOBEL BIOCARE INDIA PVT. LTD., FORTUNE 2000, 1 ST FLOOR, C-WING, BANDRA KURLA COMPLEX, BANDRA (E), MUMBAI-400 051 / VS. THE DCIT 9(2), AAYAKAR BHAVAN, MUMBAI-400 020 ' $ ./ () ./ PAN/GIR NO. : AACCN 0274A ( '* / APPELLANT ) .. ( +,'* / RESPONDENT ) '* - / APPELLANT BY: SHRI KANCHAN KAUSHAL SHRI ALISAGAR RAMPURAWALA SHRI ANUSHA SINHA +,'* . - / RESPONDENT BY: SHRI AJEET KUMAR JAIN . /0$ / DATE OF HEARING :06.02.2014 12& . /0$ / DATE OF PRONOUNCEMENT :06.02.2014 3 / O R D E R PER N.K. BILLAIYA, AM: THIS IS AN APPEAL BY THE ASSESSEE AGAINST THE ORDE R OF THE LD. CIT(A)-15, MUMBAI DT.25.02.2013 PERTAINING TO A.Y. 2008-09. ITA NO. 3104/M/2013 2 2. THE ASSESSEE HAS RAISED FOLLOWING GROUNDS OF APP EAL: 1.1. ON THE FACTS AND CIRCUMSTANCES OF THE CASE, A ND IN LAW, THE CIT(A) ERRED IN UPHOLDING/CONFIRMING THE ACTION OF THE LD. TRANSFER PRICING OFFICER (TPO)/AO IN HOLDING THAT THE APPELLANTS INTERNATIONAL TRANSACTION PERTAINING TO IMPORT OF DENTAL PRODUCTS IS NOT AT ARMS LENGTH AND THEREBY CONFIRMING THE ADDITION OF RS. 1,58,32,566/- 1.2. THE APPELLANT PRAYS THAT THE ADDITION MADE BY THE TPO/AO BE TREATED AS VOID-AB-INITIO AND SHOULD BE DELETED. 2.1. WITHOUT PREJUDICE TO GROUND NO. 1 ABOVE, ON TH E FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW, THE LD. CIT(A) HAS ERRED IN UPHOLDING THE ORDER OF THE TPO/AO IN INTRODUCING COMPANIES IN THE COMPARABILITY ANALYSIS WHICH ARE DIFFERENT FROM THE APPELLANTS FUNCTIONS, ASSET BASE AND RISK PROFILE. 2.2. THE APPELLANT PRAYS THAT THE COMPARABLE COMPAN IES INTRODUCED BY THE TPO BE DELETED AND THE APPELLANT S TP STUDY COMPARABLES TO BE RESTORES. 3.1. ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW, THE LD. CIT(A) HAS ERRED IN UPHOLDING THE ORDER OF THE LD. TPO/AO IN COMPUTING THE ADJUSTMENT ON THE TOTAL INCOME(INCLUDING ASSISTANCE RECEIVED FROM THE ASSOCIATED ENTERPRISE) OF THE APPELLANT INSTEAD OF APPLYING ARMS LENGTH MARGIN ONLY TO THE THIRD PART Y SALES OF THE APPELLANT. 3.2. THE APPELLANT PRAYS THAT THE TPO/AO BE DIRECTE D TO RESTRICT THE ADJUSTMENT TO THE THIRD PARTY SALES OF THE APPELLANT ONLY. 4.1. ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW, THE LD. CIT(A) HAS ERRED IN ENHANCING THE TOTAL INCOME BY DISALLOWING THE EXPENSES OF RS. 1,01,87,180/- U/S. 37(1) OF THE I.T. ACT, 1961 INCU RRED ITA NO. 3104/M/2013 3 IN RELATION TO TRAVELLING AND ACCOMMODATION FOR DOCTORS. 4.2. THE ASSESSEE PRAYS THAT THE LD. AO BE DIRECTED TO DELETE THE ADDITION OF RS. 1,01,87,180/-. 4.3. WITHOUT PREJUDICE TO THE ABOVE, THE ASSESSEE P RAYS THAT THE DISALLOWANCE OF THE AFORESAID EXPENSES OF RS. 1,01,87,180/- IN RELATION TO TRAVELLING AND ACCOMMODATION FOR DOCTORS, SHOULD NOT BE CONSIDERED WHILE DETERMINING THE TOTAL OPERATING COST OF THE ASSESSEE (WHILE APPLYING TRANSACTIONAL NET MARGIN METHOD) FOR TRANSFER PRICING PURPOSES AND THE ADJUSTMENT SHOULD BE CARRIED OUT AFTER REDUCING THE SAID EXPENSES FROM THE TOTAL OPERATING COST. 3. THE ASSESSEE IS A WHOLLY OWNED SUBSIDIARY OF NAB EL BIOCARE ASIA- AFRICA HOLDING AG (NBH) FOR UNDERTAKING WHOLESALE T RADING OF NBHS DENTAL PRODUCTS/SOLUTIONS IN INDIA AND FOR PROVIDIN G THE REQUISITE MARKETING, PRE-SALE/AFTER-SALE SUPPORT AND TRAINING TO CUSTOMERS IN INDIA. DURING THE YEAR, THE ASSESSEE HAS IMPORTED DENTAL P RODUCTS FROM ITS ASSOCIATED ENTERPRISES (AES). FOLLOWING INTERNATIO NAL TRANSACTIONS ARE REPORTED BY THE ASSESSEE FOR THE YEAR UNDER CONSIDE RATION. S. NO. NAME OF SERVICE F.Y 2007-08 METHOD ADOPTED F.Y.2006-07 1. IMPORT OF DENTAL PRODUCTS 157,661,188 TNMM 74,302,503 2. PURCHASE OF CAPITAL ASSET 15,870,254 CUP NIL 3. REIMBURSEMENT OF EXPENSES PAID 14,843,974 CUP 8,208,842 4. REIMBURSEMENT OF EXPENSES RECEIVED 4,528,767 CUP NIL TOTAL 192,904,183 82,511,345 ITA NO. 3104/M/2013 4 4. THE ASSESSEE ADOPTED TRANSACTIONS NET MARGIN MET HOD (TNMM) AT THE MOST APPROPRIATED METHOD TP. PROFIT LEVEL IND ICATOR (PLI) WAS TAKEN AT OPERATING PROFIT/SALES. THE ASSESSEE ADOPTED 5 C OMPARABLES. ARITHMETIC MEAN OF THE 5 COMPARABLES IS SHOWN AT 4.03% IN THE TP REPORT AGAINST ASSESSEES PLI IS AT 4.35% AS COMPUTED HEREIN BELO W: TOTAL SALE RS. 182,649,829/- OPERATING ASSISTANCE RECD FROM AE RS. 94,849,856/ - OTHER INCOME RS. 11,92,329/- TOTAL INCOME RS. 278,692,014/- TOTAL EXPENSES RS. 270,752,151/- OPERATING PROFIT RS. 7,939,863/- OPERATING PROFIT/TOTAL SALE 4.35% 5. THE ASSESSEE WAS ASKED TO SUBMIT THE UPDATED PL I FOR THE SAME SET OF COMPARABLE COMPANIES USING DATA FOR F.Y. 2007-0 8 ONLY. THE SAME WAS SUBMITTED AS UNDER: S.NO. NAME OF COMPARABLE COMPANIES PLI AS PER TP REPORT (%) UPDATED PLI FOR F.Y. 2007- 08(%) 1. ASHCO NIULAB INDS. LTD 7.10% REFER NOTE 2. HICKS THERMOMETERS (INDIA)LTD 4.47% 4.93% 3. SHREE CORATOMIC LTD. -0.26% REFER NOTE 2 4. 3M INDIA LTD.-HEALTH CARE MARKETS SEGMENT 6.05% 3.67% 5. SIEMENS LTD-HEALTH CARE AND OTHER SERVICES SEGMENT 2.80% 2.15% ARITHMETIC MEAN 4.03% 3.59% 6. AFTER CONSIDERING THE TP STUDY REPORT OF THE ASS ESSEE, THE TPO CONSIDERED THE FOLLOWING SET OF COMPARABLES FOR THE DETERMINATION OF ALP ITA NO. 3104/M/2013 5 S. NO. NAME OF COMPARABLE COMPANIES PLI AS PER TP REPORT(%) 1. ASHCO NIULAB INDUS. LTD. 8.59% 2. ADVANCE MICRONIC DEVICES LTD. 12.06% 3. HICKS THERMOMETERS (INDIA)LTD 4.93% ARITHMETIC MEAN 8.53% 7. THE ARMS LENGTH PRICE OF PURCHASE OF GOODS WA S DETERMINED AT RS. 14,18,28,622/-. SINCE THE ASSESSEE HAD PAID RS . 15,76,61,188/- WHICH WAS HIGHER BY RS. 1,58,32,566/-. THE TPO MADE AN A DJUSTMENT OF RS. 1,58,32,566/-. 8. AGGRIEVED BY THE MYTHOLOGY OF DETERMINING THE AL P, THE ASSESSEE CARRIED THE MATTER TO THE LD. CIT(A). IT WAS STRON GLY CONTENDED BEFORE THE LD. CIT(A) THAT AS PER THE DISTRIBUTION AGREEME NT ENTERED WITH AE, THE ARMS LENGTH OPERATING MARGIN (OP/SALES) FOR F. Y. 2007-08 WAS DETERMINED IN THE RANGE OF 2% TO 4%. IT WAS FURTHE R CONTENDED THAT THE ASSESSEE HAS SHOWN OP/SALES MARGIN AT 4.35% WHICH W AS HIGHER THAN THE AVERAGE OP/SALES MARGIN OF COMPARABLE COMPANIES OF 4.03%. IT WAS ARGUED THAT THE INTERNATIONAL TRANSACTIONS OF THE A SSESSEE WERE DETERMINED TO BE AT ARMS LENGTH. BEFORE THE LD. CIT(A), IT W AS THE ASSESSEES CONTENTION THAT THE TPO ERRED IN CONSIDERING COMPAN IES WITH SERVICE AND MANUFACTURING INCOME AS COMPARABLE VIS--VIS THE DI STRIBUTION FUNCTION PERFORMED BY THE ASSESSEE. IT WAS THEREFORE REQUEST ED TO TAKE INTO CONSIDERATION THE FUNCTIONAL PROFILE AND INDUSTRY I N WHICH THE ASSESSEE OPERATES AND TO CONSIDER THE COMPARABLES SELECTED BY THE ASSESSEE. IT WAS ITA NO. 3104/M/2013 6 ALSO STRONGLY AGITATED BEFORE THE LD. CIT(A) THAT T HE TPO DETERMINED THE ARMS LENGTH PROFIT USING TOTAL INCOME OF THE ASSES SEE WHEREIN IT OUGHT TO HAVE BEEN COMPUTED ONLY ON THE SALES OF THIRD P ARTIES. AFTER CONSIDERING THE FACTS AND THE SUBMISSIONS, THE LD. CIT(A) WAS CONVINCED THAT THE 3 COMPARABLES REJECTED BY THE TPO WERE BAS ED ON SOUND REASONS AND IN SO FAR AS THE DETERMINATION OF ALP USING TOT AL INCOME OF THE ASSESSEE, THE LD. CIT(A) THUS HELD AS UNDER : THE APPELLANT HAS IN ITS SUBMISSION CONTENDED THAT THE TPO HAS DETERMINED THE ARMS LENGTH PROFIT USING TOTAL INCOME OF THE ASSESSEE WHERE AS IT OUGHT TO HAVE BEEN COMPUTED ON LY ON THE SALES TO THE THIRD PARTIES AND THAT THE APPELLANT HAS FIL ED A RECTIFICATION APPLICATION TO THE TPO IN THIS REGARD. IN RESPECT OF SUCH CONTENTION OF THE APPELLANT HAS BEEN COMPUTED AFTE R CONSIDERING AND TAKING INTO ACCOUNT THE ASSISTANCE RECEIVED FRO M THE AE. IT IS ONLY ON ACCOUNT OF THE ASSISTANCE RECEIVED FROM THE AE OF RS. 9,48,49,856/- THAT THE APPELLANT HAS EARNED AN OPER ATING PROFIT OF 4.35% OR ELSE IT WOULD HAVE BEEN INTO SUBSTANTIAL L OSSES. FURTHER THERE IS NO INFIRMITY FOUND IN THE COMPUTATION OF T HE ADJUSTMENT BY THE TPO WHO HAS COMPUTED THE ARMS LENGTH PROFIT ON THE TOTAL REVENUE/SALES INCLUDING THE ASSISTANCE RECEIVED FRO M THE AE. IT HAS TO BE UNDERSTOOD THAT THE INTERNATIONAL TRANSACTION IN THE WHOLE CASE IS NOT THE ONE RELATING TO SALES TO THE THIRD PARTIES BUT IS PURCHASE FROM THE AE AND FURTHER INADEQUATE ASSISTA NCE RECEIVED FROM THE AE AND THEREFORE WHILE COMPUTING THE ARMS LENGTH PROFIT BOTH THE TRANSACTIONS VIZ. PURCHASE FROM THE AE AND INADEQUATE ASSISTANCE RECEIVED FROM THE AE HAS TO BE TAKEN INT O ACCOUNT. ACCORDINGLY SUCH CONTENTION OF THE APPELLANT IS NOT FOUND TO BE ACCEPTABLE. 9. AGGRIEVED, THE ASSESSEE IS BEFORE US. THE LD. C OUNSEL FOR THE ASSESSEE STRONGLY SUBMITTED THAT AS PER THE DISTRIB UTION AGREEMENT WITH THE AE, THE ASSESSEE WAS ASSURED OF A MINIMUM OPERATING PROFIT MARGIN AT 4% AND IF THE SAME WAS NOT ACHIEVED, THE AES WERE TO RECOUP THE DIFFERENCE TO MAKE UP THE OPM OF THE ASSESSEE AT 4% . THE LD. COUNSEL FURTHER SUBMITTED THAT SUCH OPERATING ASSISTANCE R ECEIVED FROM AE DURING ITA NO. 3104/M/2013 7 THE YEAR WERE AT RS. 9,48,49,856/-. IT IS THE SAY OF THE LD. COUNSEL THAT THE TPO WHILE DETERMINING THE ALP HAS ADDED THIS AM OUNT TO THE TOTAL SALES OF THE ASSESSEE. AT THIS POINT, WE ASKED THE LD. COUNSEL WHETHER THIS TRANSACTION OF RECOUPMENT WAS REPORTED IN THE TP STUDY TO WHICH THE LD. COUNSEL DREW OUR ATTENTION TO THE NOTE NO. 2 OF APPENDIX B (CLAUSE 8B) OF THE REPORT. THE SAID NOTE READS AS UNDER: AS PER THE DISTRIBUTION AGREEMENT THE ASSESSEE HAS BEEN COMPENSATED RS. 94,849,856 BY ITS ASSOCIATED ENTERP RISE TO RETAIN AN ARMS LENGTH OPERATING MARGIN. FURTHER, BASED O N THE TRANSFER PRICING STUDY CARRIED OUT BY THE ASSESSEE, THE ARIT HMETICAL MEAN OF THE MARGIN OF COMPARABLE COMPANIES (CALCULATED USIN G OPERATING PROFIT/SALES AS THE PROFIT LEVEL INDICATOR) WAS COM PARED BY THE ASSESSEE WITH ITS OPERATING PROFIT/SALES FOR THE FI NANCIAL YEAR ENDED MARCH 31,2008. ON THE BASIS OF THE ABOVE, IT WAS C ONCLUDED BY THE ASSESSEE THAT THE PRICES OF INTERNATIONAL TRANSACT IONS OF THE ASSESSEE WERE AT ARMS LENGTH AS PROVIDED UNDER SEC TION READ WITH PROVISO TO SEC. 92C(2) OF THE INCOME TAX ACT, 1961. 10. IN OUR UNDERSTANDING OF LAW, THIS IS NOT A PROP ER WAY OF REPORTING AN INTERNATIONAL TRANSACTION. IT APPEARS THAT THE ASSESSEE HAS NOT REPORTED/CONSIDERED THIS RECOUPMENT OF RS. 9,48,49, 856/- AS INTERNATIONAL TRANSACTION, THEREFORE, THE TPO HAS ALSO NOT CONSID ERED THIS IN HIS DETERMINATION OF ARMS LENGTH PRICE. IN OUR CONSID ERED VIEW, THIS IS A LAPSE ON THE PART OF THE ASSESSEE WHICH HAS MADE TH E ORDER OF THE LOWER AUTHORITIES ERRONEOUS. HOWEVER, IN THE INTEREST OF JUSTICE AND FAIR PLAY, WE RESTORE THIS ISSUE BACK TO THE FILES OF THE TPO. THE TPO IS DIRECTED TO CONSIDER THIS RECOUPMENT OF RS. 9,48,49,856/- FOR T HE DETERMINATION OF ALP AS THIS IS ALSO AN INTERNATIONAL TRANSACTION AF TER GIVING A REASONABLE AND SUFFICIENT OPPORTUNITY OF BEING HEARD TO THE AS SESSEE. GROUND NO. 1,2 AND 3 ARE ACCORDINGLY ALLOWED FOR STATISTICAL PURPO SE. ITA NO. 3104/M/2013 8 11. THE OTHER GRIEVANCE OF THE ASSESSEE IS THAT THE LD. CIT(A) ERRED IN ENHANCING THE TOTAL INCOME BY DISALLOWING THE EXPEN SES OF RS. 1,01,87,180/- U/S. 37(1) OF THE ACT. 12. DURING THE YEAR UNDER CONSIDERATION, THE ASSESS EE HAS REIMBURSED TO ITS AES THE COST OF ACTUAL EXPENDITURE INCURRED BY THE AE ON BEHALF OF THE ASSESSEE. THE EXPENSES REIMBURSED ARE IN THE N ATURE OF FREIGHT CHARGES, TRAVEL, HOTEL EXPENSES ETC. THE FREIGHT C HARGES REIMBURSED ARE FOR THE FREIGHT EXPENSES INCURRED BY THE AE FOR THE DENTAL PRODUCTS IMPORTED BY THE ASSESSEE. THE HOTEL AND TRAVEL EX PENSES REIMBURSED ARE TOWARDS THE EXPENSES INCURRED BY THE AE FOR THE HOT EL AND TRAVEL EXPENSES OF THE EMPLOYEES OF THE ASSESSEE/CUSTOMERS OF THE ASSESSEE. THE ASSESSEE WAS ASKED TO SUBMIT THE DETAILS OF REIMBUR SEMENT OF EXPENSES WITH SUPPORTING DOCUMENTS THEREOF. THE ASSESSEE CO ULD SUBMIT DETAILS FOR MAJORITY OF THE REIMBURSEMENT. ACCORDING TO TH E TPO, THE ASSESSEE FAILED TO PROVIDE SUPPORTING DOCUMENTS IN RESPECT O F THE AMOUNT OF RS. 1,01,87,180/-. THE TPO FURTHER OBSERVED THAT THE A SSESSEE COULD NOT SUBSTANTIATE THE NAMES OF THE PERSONS ATTENDING THE CONFERENCE, THE NAME OF THE PERSONS STAYED IN THE HOTEL, NAME OF THE PER SONS WHO TRAVELLED ETC. THE TPO WAS CONVINCED THAT AN ADJUSTMENT TO THE EXT ENT OF RS. 1,01,87,180/- WAS REQUIRED. HOWEVER, SINCE THE ADJ USTMENT UNDER TNMM WORKING AT NDT LEVEL WAS MADE. THE TPO DID NO T MAKE ANY SEPARATE ADJUSTMENT FOR THIS REIMBURSEMENT OF EXPEN SES. 13. DURING THE COURSE OF THE APPELLATE PROCEEDINGS, BEFORE THE LD. CIT(A), THE CIT(A) NOTICED THAT THIS REIMBURSEMENT OF EXPENSES WAS TOWARDS THE TRAVELLING AND ACCOMMODATION OF DOCTORS /MEDICAL PROFESSIONALS, THE SAME DESERVES TO BE DISALLOWED U /S. 37(1) OF THE ACT ITA NO. 3104/M/2013 9 AND ACCORDINGLY HE PROPOSES TO DISALLOW THE SAME. EXPLANATION WAS CALLED FROM THE ASSESSEE. THE ASSESSEE WAS ASKED T O JUSTIFY THE EXPENSES IN THE LIGHT OF THE CIRCULAR OF THE CBDT NO. 5/2012 DT. 1.8.2012 BEARING NO. F. NO. 225/142/2012-ITA-II. THE ASSESSEE FILED A DETAILED REPLY STRONGLY CONTENDING THAT THE AMENDMENT IN THE INDIA N MEDICAL COUNCIL (PROFESSIONAL CONDUCT ETIQUETTES AND ETHICS) REGULA TION S, 2002 BY THE MEDICAL COUNCIL OF INDIA (MCI) WAS MADE IN DECEMBER , 2009 AND THE AFORESTATED CIRCULAR WAS ISSUED BY THE CBDT ON AUGU ST 1 ST 2012. IT WAS ARGUED THAT THE YEAR UNDER CONSIDERATION IS F.Y. 20 07-08 HENCE THE AMENDMENT IN THE REGULATIONS OF MCI AND THE CIRCULA R OF THE CBDT HAS NO APPLICABILITY FOR THE YEAR UNDER APPEAL. THE LD . CIT(A) DISMISSED THIS SUBMISSION OF THE ASSESSEE AND DIRECTED THE AO TO E NHANCE THE TOTAL INCOME BY RS. 1,01,87,180/-. 14. AGGRIEVED BY THIS, THE ASSESSEE IS BEFORE US. WITHOUT GOING INTO THE MERITS OF THIS ISSUE, SINCE WE HAVE RESTORED TH E ISSUE OF THE DETERMINATION OF ALP VIDE GROUND NO. 1,2 & 3 BACK T O THE FILES OF THE TPO AND SINCE THE TPO HAD NOT MADE ANY ADJUSTMENT I N RESPECT OF THIS REIMBURSEMENT, IN OUR VIEW, THE ASSESSEE MUST GET O NE MORE OPPORTUNITY TO SUBSTANTIATE ITS CLAIM BEFORE THE TPO. THEREFOR E, IN THE INTEREST OF JUSTICE AND FAIR PLAY, THIS ISSUE IS ALSO RESTORED BACK TO THE FILES OF THE TPO. THE TPO IS DIRECTED TO DECIDE THIS ISSUE AFRE SH IN THE LIGHT OF THE FINDINGS OF THE LD. CIT(A) CONSIDERING THE AMENDMEN T BROUGHT IN BY THE MCI READ WITH CIRCULAR OF THE CBDT MENTIONED AS WEL L AFTER GIVING A REASONABLE AND SUFFICIENT OPPORTUNITY OF BEING HEAR D TO THE ASSESSEE. GROUND NO.4 WITH ALL ITS SUB-GROUNDS ARE ALLOWED FO R STATISTICAL PURPOSE. ITA NO. 3104/M/2013 10 15. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS ALLOWED FOR STATISTICAL PURPOSE. ORDER PRONOUNCED IN THE OPEN COURT ON 6 TH FEBRUARY, 2014 . 3 . 2& $ 4 56 06.02.2014 2 . 7 SD/- SD/- (I.P. BANSAL ) (N.K. BILLAIYA) /JUDICIAL MEMBER $ / ACCOUNTANT MEMBER MUMBAI; 5 DATED 06.02.2014 . . ./ RJ , SR. PS 3 3 3 3 . .. . +/ +/ +/ +/ 8 &/ 8 &/ 8 &/ 8 &/ / COPY OF THE ORDER FORWARDED TO : 1. '* / THE APPELLANT 2. +,'* / THE RESPONDENT. 3. 9 ( ) / THE CIT(A)- 4. 9 / CIT 5. :7 +/ , , / DR, ITAT, MUMBAI 6. 7; < / GUARD FILE. 3 3 3 3 / BY ORDER, , / +/ //TRUE COPY// = == = / > > > > ( ( ( ( (DY./ASSTT. REGISTRAR) , / ITAT, MUMBAI
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