Knoah Solutions Pvt.Ltd., Hyd, Hyderabad V. ITO, Ward - 2(1), Hyderabad, Hyderabad

ITA 326/HYD/2015

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 6263 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 4 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-08-2016
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 10-08-2016
• Assessment Year: 2010-2011
• Appeal Filed On: 01-04-2015
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: T VENKAT REDDY
• Assessee Lawyers: A V RAGHURAM
• Keywords: Transfer pricing; International transaction
• Section: 143(3)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A, HYDERABAD BEFORE SMT P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA NO. 180/HYD/2015 ASSESSMENT YEAR: 2010-11 INCOME TAX OFFICER, WARD 2(1), HYDERABAD. VS. KNOAH SOLUTIONS PVT. LTD., HYDERABAD. PAN AABCK 6861 B (ASSESSEE) (RESPONDENT) ITA NO. 326/HYD/2015 ASSESSMENT YEAR: 2010-11 KNOAH SOLUTIONS PVT. LTD., HYDERABAD. PAN AABCK 6861 B VS. INCOME TAX OFFICER, WARD 2(1), HYDERABAD. (ASSESSEE) (RESPONDENT) REVENUE BY : SHRI T. VENKAT REDDY ASSESSEE BY : SHRI A.V. RAGHURAM DATE OF HEARING 10-08-2016 DATE OF PRONOUNCEMENT 24-08-2016 O R D E R PER S. RIFAUR RAHMAN, A.M.: BOTH THESE APPEALS FILED BY THE ASSESSEE AND REVEN UE ARE CROSS APPEALS DIRECTED AGAINST THE ORDER PASSED U/S 143(3 ) R.W.S. 92CA(3) R.W.S.144C(13) OF THE INCOME TAX ACT, 1961 (IN SHOR T ACT) DATED 30/01/2015 RELATING TO AY 2010-11. 2 ITA NOS. 180 & 326 /HYD/2015 KNOAH SOLUTIONS PVT. LTD. ITA NO. 180/HYD/2015 BY THE REVENUE 2. BRIEF FACTS OF THE CASE ARE, THE ASSESSEE COMPA NY, WHICH IS ENGAGED IN THE BUSINESS PROCESS OUTSOURCING, FILED ITS RETURN OF INCOME ELECTRONICALLY ON 23/09/2010 DECLARING INCOM E OF RS. 9,84,900/- AFTER CLAIMING DEDUCTION U/S 10A OF RS. 1,82,16,263/-. THE AO HAS REFERRED THE CASE UNDER SECTION 92CA(1) OF T HE IT ACT FOR DETERMINATION OF ARMS LENGTH PRICE IN RESPECT OF T HE INTERNATIONAL TRANSACTIONS REPORTED BY THE TAXPAYER COMPANY FOR T HE FY RELEVANT TO THE AY 2010-11. THE AO PASSED A DRAFT ORDER DATED 10/03/2014 U/S 143(3) READ WITH SECTION 92CA(3) OF THE IT ACT FOR ARRIVING AT A TOTAL INCOME OF RS. 3,61,30,302/-. THE AO MADE ADJUSTMENT AS PROPOSED BY THE TPO OF RS. 3,35,03,147/- TOWARDS ADJUSTMENT OF ARMS LENGTH PRICE. THE AO ALSO HELD THAT AS PER THE PROVISO TO SUB-SECTION (4) OF SECTION 92C, NO DEDUCTION IS ALLOWABLE U/S 10A ON T HE ENHANCED ARMS LENGTH PRICE ADJUSTMENT. 3. WHEN THE ASSESSEE FILED OBJECTIONS BEFORE THE DR P, THE DRP VIDE ITS ORDER DATED 28/11/2014 HAS DIRECTED TO EXC LUDE E-CLERX SERVICES LTD., TCS ESERVE LTD., AND INFOSYS BPO LTD ., FROM THE LIST OF 11 COMPARABLES AND ALSO DIRECTED THAT NEGATIVE WORK ING CAPITAL ADJUSTMENT TO THE ARITHMETIC MEAN MARGIN OF THE COM PARABLE SHALL NOT BE MADE. ACCORDINGLY, THE TPO HAS RECOMPUTED THE A DJUSTMENT U/S 92CA AT RS. 1,26,74,678/-. 3.1 AS REGARDS EXEMPTION U/S 10A, THE DRP HAS DIREC TED TO REDUCE TELECOMMUNICATION CHARGES NOT ONLY FROM THE EXPORT TURNOVER BUT ALSO FROM THE TOTAL TURNOVER FOR THE PURPOSE OF COMPUTAT ION OF DEDUCTION I/S 10A OF THE ACT. 4. AGGRIEVED BY THE ORDER OF THE DRP, THE REVENUE I S IN APPEAL BEFORE US RAISING THE FOLLOWING GROUNDS OF APPEAL: 1. THE DRP ERRED IN DIRECTING TO EXCLUDE E-CLERX SE RVICES LTD, TCS ESERVE LTD., AND INFOSYS BPO LTD., AS COMPARABL E WITHOUT ANY BASIS. 3 ITA NOS. 180 & 326 /HYD/2015 KNOAH SOLUTIONS PVT. LTD. 2. THE DRP ERRED IN DIRECTING TO EXCLUDE TELECOMMUN ICATION CHARGES FROM BOTH TOTAL TURNOVER AND EXPORT TURN OV ER WHEN DEFINITION WAS GIVEN ONLY FOR EXPORT TURN OVER BUT NOT TOTAL TURN OVER WHICH GOES TO DEFEAT THE SPIRIT AND INTENTION OF THE PARLIAMENT. 5. AS REGARDS GROUND NO. 1 REGARDING EXCLUSION OF C OMPARABLES OF THREE COMPANIES, THE SAME ARE TO BE DECIDED AS UNDE R: 5.1 ECLERX SERVICES LTD., I) THE TPO ADDED THIS COMPANY AS COMPARABLE WHICH I S FUNCTIONALLY DIFFERENT BEING KPO COMPANY. II) THE OBJECTIONS OF THE ASSESSEE ARE THAT THE THI S COMPANY IS A KNOWLEDGE PROCESS OUTSOURCING (KPO) ENTITY PROVIDIN G CONSULTING AND OUTSOURCING SERVICES FOR FINANCIAL INSTITUTIONS. TH E ASSESSEE COMPANY RENDERING LOW END BPO SERVICES KNOWN AS KPO SERVICE S. THE SIZE OF THE COMPARABLE COMPANY IS HIGH WITH A TURNOVER OF R S. 257 CRORES AND CANNOT BE COMPARED WITH THE ASSESSEE COMPANY WHICH HAS ONLY RS. 20.40 CRORES. MOREOVER THE SKILL SETS OF THE EMPLOY EES ENGAGED, THE INTANGIBLES AND THE ASSETS EMPLOYED ETC. IN THE COM PARABLE COMPANY ARE DIFFERENT FROM THE ASSESSEE COMPANY. 5.2 INFOSYS BPO LTD., AND TCS ESERVICE LTD., I) THE TPO ADDED THESE COMPANIES AS COMPARABLE WH ICH ARE FUNCTIONALLY DIFFERENT BESIDES BEING SUPER TURNOVER COMPANY, WHICH IS ABOVE RS. 200 CRORES. II) THE OBJECTIONS OF THE ASSESSEE ARE THAT THE COM PARABLE COMPANY UNDER TNMM SHOULD BE SIMILAR TO THE TESTED COMPANY IN FUNCTIONALLY, SIZE, EMPLOYEES SKILL SETS, BRAND VAL UE AND INTANGIBLES. AS THESE THREE COMPANIES ARE DIFFERENT FROM THE ASS ESSEE COMPANY IN TERMS OF THE TURNOVER, BRAND VALUE, INTANGIBLES AND OTHER ASSETS EMPLOYED, EMPLOYEE SKILL SETS, AND ALSO THE CUSTOME RS THAT IT CATERS ALL OVER THE WORLD, THESE CANNOT BE COMPARABLES FOR ASSESSEE 4 ITA NOS. 180 & 326 /HYD/2015 KNOAH SOLUTIONS PVT. LTD. COMPANY WHICH RENDERS LOW END BPO SERVICES AS CAPTI VE SERVICE PROVIDER TO ITS AE COMPANY LOCATED IN US ON A COST PLUS MODEL. 6. THE DRP HELD AS FOLLOWS: 11.2 THE TAXPAYER VEHEMENTLY ARGUED THAT THE FOUR C OMPANIES SHOULD NOT BE INCLUDED IN VIEW OF THEIR BRAND VALUE AND HIGH TURNOVER AS WELL AS RELYING ON THE DECISION OF THE ITAT TO EXCLUDE M/S. INFOSYS TECHNOLOGIES LTD ALSO ARGUED THAT M/S ECLERX IS KPO NOT COMPARABLE. THE PANEL FEELS THAT ONLY M/S I NFOSYS SPO AND TCS E SERVE LTD SHOULD NOT BE INCLUDED AS COMPA RABLE IN VIEW OF THEIR ADVANTAGEOUS BRAND VALUE ALONG WITH H IGH TURNOVER OF 1000 CRORES AND ABOVE. SIMILARLY, M/S. ECLERX SE RVICES THAT ALSO TO BE EXCLUDED AS IT RENDERS HIGH END SERVICES AND CONSIDERED AS KPO. HOWEVER, THE ARGUMENT OF THE TAX PAYER WITH REGARD TO THE COMPARABLE COMPANY M/S. TCS ESERVE INTERNATIONAL LTD. IS NOT ACCEPTABLE, AS THE SAID C OMPANY HAS PASSED ALL THE FILTERS AND IT IS TRUE COMPARABLE TO THE TAXPAYER COMPANY. HENCE, THE TAXPAYER'S OBJECTION FOR EXCLUS ION OF TCS ESERVE INTERNATIONAL LTD. IS REJECTED AND DIRECT TH E TPO/AO TO EXCLUDE THE FOLLOWING COMPARABLES FROM THE FINAL SE T OF COMPARABLES AND RECOMPUTE THE ARM'S LENGTH PRICE. (I) ECLERX SERVICES LTD. (II) TCS ESERVE LTD. (III) INFOSYS BPO LTD. ACCORDINGLY THE TPO/AO IS DIRECTED TO REWORK THE AL P BY EXCLUDING THE ABOVE THREE COMPANIES FROM THE ALP AD JUSTMENT. 7. CONSIDERED THE SUBMISSIONS OF BOTH THE PARTIES A ND PERUSED THE MATERIAL FACTS ON RECORD. THE ISSUE IN DISPUTE IS S QUARELY COVERED BY THE DECISIONS OF THE ITAT INCLUDING THE DECISION IN ASSESSEES OWN CASE FOR AY 2007-08 VIDE ORDER DATED 25/04/2014 IN ITA NO. 1407/HYD/2013 AND FOR AY 2009-10 VIDE ORDER DATED 3 1/10/2014 IN ITA NO. 392/HYD/2014 WHEREIN THE COORDINATE BENCH D IRECTED TO EXCLUDE THE SAID COMPANIES FROM THE LIST OF COMPARA BLES AND RECOMPUTE THE ALP ACCORDINGLY. THEREFORE, WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF THE DRP IN DIRECTING THE AO/TPO TO EXCLUDE THE SAID COMPANIES FROM THE LIST OF COMPARABLES CON SIDERING THEIR ADVANTAGEOUS BRAND VALUE ALONG WITH HIGH TURNOVER. ACCORDINGLY, THIS GROUND OF APPEAL OF REVENUE IS DISMISSED. 5 ITA NOS. 180 & 326 /HYD/2015 KNOAH SOLUTIONS PVT. LTD. 8., AS REGARDS GROUND NO. 2 PERTAINING TO EXCLUSION OF TELECOMMUNICATION CHARGES, W E DO NOT FIND ANY INFIRMITY IN THE ORDER OF THE DRP AS IT IS IN CONFORMITY WITH THE RATIO LA ID DOWN BY THE HONBLE BOMBAY HIGH COURT IN CASE OF CIT VS. GEM PL US JEWELLERY (330 ITR 175) AS WELL AS DIFFERENT BENCHES OF TRIBU NAL INCLUDING ITAT, CHENNAI BENCH (SB) IN THE CASE OF ITO VS. SAK SOFT (313 ITR (AT) 853) WHEREIN IT IS HELD THAT COMMUNICATION CHARGES ATTRIBUTABLE DIRECTLY TO THE EXPORT OF ARTICLE OR THING OUTSIDE INDIA HAS TO BE EXCLUDED BOTH FROM EXPORT TURNOVER AS WELL AS TOT AL TURNOVER WHILE COMPUTING EXEMPTION U/S 10A OF THE ACT. IN VIEW OF THE RATIO LAID DOWN AS ABOVE, THE FINDING OF THE DRP ON THIS ISSUE IS UPHELD AND GROUND RAISED BY THE REVENUE IS DISMISSED. 9. IN THE RESULT, APPEAL OF THE REVENUE IS DISMISSE D. ITA NO. 326/HYD/2015 BY ASSESSEE 10. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS O F APPEAL IN ITS APPEAL: 1. THE LEARNED ASSESSING OFFICER/TPO/DRP HAVE ERRE D IN MAKING ADJUSTMENT U/S 92CA(3) OF RS. 1,26,74,678, W ITHOUT TAKING INTO ACCOUNT THE SUBMISSION OF THE ASSESSEE FOR INCLUSION OF 2 COMPARABLE COMPANIES PROPOSED BY THE ASSESSEE AND FURTHER BY ADDING ONE COMPANY WHICH IS NOT FUNCTION ALLY COMPARABLE. 2. THE LEARNED ASSESSING OFFICER/TPO/DRP OUGHT TO HAVE INCLUDED INTERGLOBE TECHNOLOGIES PVT LTD AND MASTIF F TECH PVT. LTD IN THE LIST OF COMPARABLE COMPANIES SINCE BOTH THE COMPANIES ARE FULLY AND FUNCTIONALLY COMPARABLE AND FURTHER T HE ASSESSEE HAS PROVIDED THE DATA INCLUDING ANNUAL REPORTS OF T HE ABOVE TWO COMPANIES. 3. THE LEARNED ASSESSING OFFICER/TPO/DRP OUGHT NOT TO HAVE ADDED ONE COMPANY I.E., TCS E-SERVE INTERNATIO NAL LTD, SINCE THE SAID COMPANY IS NOT COMPARABLE FUNCTIONAL LY AND IS ALSO A GIANT COMPANY WITH ITS OWN BRAND IMAGE AND H UGE TURN OVER AND HENCE NOT COMPARABLE. 6 ITA NOS. 180 & 326 /HYD/2015 KNOAH SOLUTIONS PVT. LTD. 11. THE ASSESSEE HAS NOT PRESSED GROUND NOS. 1 & 2 AT THE TIME OF HEARING BEFORE US, THEREFORE, THE SAME ARE DISMISSE D AS NOT PRESSED. 12. AS REGARDS GROUND NO. 3, THE TPO HAS SELECTED T HE TCS E- SERVE INTERNATIONAL LTD. AS COMPARABLE ON THE GROUN D THAT THIS COMPANY BELONGING TO ITES/BPO AND IT WAS VIEWED THA T BRAND DOES NOT PLAY A ROLE IN THE PROFITABILITY. 13. THE DRP UPHELD THE ACTION OF THE TPO. 14. THE MAIN ARGUMENTS OF LD AR OF ASSESSEE FOR EXC LUSION OF THE SAID COMPANY ARE THAT THE COMPANY IS FUNCTIONALLY DIFFERENT, INVOLVING IN TRANSACTION PROCESSING AND TECHNICAL SERVICES WH ICH ARE HIGH END SKILL PROCESSES. MOREOVER, THE OP/OC % IS ABNORMALL Y HIGH BEING 51.51%. THE LD. AR RELIED ON THE FOLLOWING CASE LAW S: 1. MARKET TOOLS RESEARCH LTD. VS. ACIT, 2013 32 TAX MANN.COM 358 (HYD.). 2. HCL EAI SERVICES LTD. VS. DCIT, [2013] 35 TAXMAN N.COM 146 (BANG.) 3. WITNESS SYSTEMS SOFTWARE INDIA (P) LTD. VS. DCIT , [2013] 34 TAXMANN.COM 183 (BANG.) 4. MAERSK GLOBAL CENTRES (INDIA) (P) LTD. VS. ACIT (SB) MUM. ITAT 5. CNO IT SERVICES (INDIA) P. LTD. VS. DCIT, [2014] 43 TAXMANN.COM 231 (HYD.) 6. CORDYS R & D (INDIA) P. LTD. VS. DCIT, 43 TAXMAN N.COM 64 (HYD.) 7. DE SHAW INDIA (SOFTWARE (P) LD. VS. ACIT, [2014] 42 TAXMANN.COM 74 HYD. 8. M/S AVINEON INDIA P. LTD. VS. DCIT, ITA NO. 152/ HYD/2015 AND OTHERS, DATED 20/01/2016. 9. C3I SUPPORT SERVICES (P) LTD. VS. DCIT, 103/HYD /2015, AY 2010- 11, 7 TH APRIL, 2016. 15. LD. DR RELIED ON THE ORDERS OF REVENUE AUTHORIT IES. 7 ITA NOS. 180 & 326 /HYD/2015 KNOAH SOLUTIONS PVT. LTD. 16. CONSIDERED THE SUBMISSIONS OF BOTH THE COUNSELS AND PERUSED THE MATERIAL FACTS ON RECORD. WE FIND THAT THE ISSU E IN DISPUTE IS COVERED IN FAVOUR OF THE ASSESSEE BY VARIOUS DECISI ONS OF ITAT INCLUDING THE DECISIONS OF COORDINATE BENCHES OF HY DERABAD. IN THE CASE OF C3I SUPPORT SERVICES (P) LTD. VS. DCIT (SUP RA) HAS DIRECTED THE AO/TPO TO EXCLUDE THE SAID COMPANY AS COMPARABL E BY OBSERVING AS UNDER: 10. IN SO FAR AS TCS ESERVE INTERNATIONAL LTD., AS RIGHTLY POINTED OUT BY THE LD. COUNSEL FOR THE ASSESSEE, THE SUDDEN TURN A ROUND OF THE SAID COMPANY, BY EARNING HIGH PROFIT MARGIN, WAS MAINLY ON ACCOUNT OF THE BRAND VALUE THAT TATA GROUP CARRIES. UNDER IDENTICA L CIRCUMSTANCES, WHILE CONSIDERING COMPARABLE CASE OF INFOSYS BPO, THE ITA T A BENCH, HYDERABAD IN THE ASSESSEES OWN CASE FOR THE A.Y. 2 008-09 OBSERVED THAT BRAND DEFINITELY COMMANDS PREMIUM PRICE AND THE CUS TOMER WOULD BE WILLING TO PAY FOR THE SERVICES OF A COMPANY WHICH HAS A BRAND IMAGE. THUS, IT WAS CONCLUDED THAT SUCH COMPANY CANNOT BE REGARDED AS A COMPARABLE COMPANY. IN THE INSTANT CASE ALSO CIRCUM STANCES BEING IDENTICAL, WE ARE OF THE VIEW THAT TCS ESERVE INTER NATIONAL LTD., CANNOT BE TREATED AS COMPARABLE HAVING REGARD TO THE BRAND VA LUE IT COMMANDS. WE, THEREFORE, DIRECT THE A.O. TO EXCLUDE THE SAME AS C OMPARABLE. 16.1 I N THE CASE OF HYUNDAI MOTORS INDIA ENGG. P. LTD., I N ITA NO. 1743/HYD/2014 FOR AY 2010-11 VIDE ORDER DATED 13/11 /2015, WHEREIN THE TRIBUNAL HAS HELD AS FOLLOWS: 11.2.2. WE FIND THAT THE ASSESSEES CONTENTIONS A BOUT THE PRESENCE OF BRAND VALUE AND OWNING OF INTANGIBLES IS SUPPOR TED BY THE EVIDENCE ON RECORD. HOWEVER, AS REGARDS THE EXTRAORDINARY EVENT OR EXCEPTIONAL CIRCUMSTANCE THERE IS NO MATERIAL PLACED BEFORE US BY THE LD. COUNSEL FOR THE ASSESSEE. THEREFORE, MERELY BECAUSE THE TPO IN ANOTHER CASE HAS HELD THAT THERE IS AN EXTRAORDINARY EVENT FOR WHICH THIS COMPANY HAS TO BE EXCLUDED FROM THE LIST OF COMPARABLES, IT CANNOT BE EXCLUDED. SUCH CLAIM HAS TO BE SUPPORTED BY EVIDENCE ON RECORD. AS REGAR DS THE FUNCTIONAL DISSIMILARITY AND HUGE TURNOVER AND BRAND VALUE IS CONCERNED, WE FIND THAT THIS TRIBUNAL IN ASSESSEES OWN CASE FOR A.Y. 2009- 10 WHILE CONSIDERING THE COMPARABILITY OF THE ASSESSEE WITH INFOSYS BPO LTD., HAS TAKEN NOTE OF THE POSSESSION OF THE BRAND VALUE AND INTANGIBLES W HICH INFLUENCED THE FINANCIAL RESULTS OF THIS COMPANY. THE HONBLE DELH I HIGH COURT IN THE CASE OF CIT VS. AGNITY INDIA TECHNOLOGIES P. LTD., (2013 ) 219 TAXMAN 26 (DEL.), HELD THAT HUGE TURNOVER COMPANIES LIKE INFOSYS AND WIPRO CANNOT BE CONSIDERED AS COMPARABLE TO SMALLER COMPANIES LIKE ASSESSEE THEREIN. IN THE CASE BEFORE THE HONBLE HIGH 16 COURT (SUPRA), THE TURNOVER OF THE ASSESSEE WAS ABOUT RS.15.79 CRORES AS AGAINST THE T URNOVER OF RS.1016 CRORES OF THE INFOSYS. CONSIDERING THESE FACTS, THE HONBLE HIGH COURT HAD 8 ITA NOS. 180 & 326 /HYD/2015 KNOAH SOLUTIONS PVT. LTD. DIRECTED FOR EXCLUSION OF INFOSYS BPO BECAUSE OF IT S BRAND VALUE AND ALSO ON THE GROUNDS OF FUNCTIONAL DISSIMILARITY AND HUGE TURNOVER. THOUGH, THE COMPANY BEFORE US IS TCS E-SERVICE LTD., AND NOT IN FOSYS BPO, WE FIND THAT THE TURNOVER OF THE ASSESSEE COMPANY FOR THIS ASSESSMENT YEAR IS AROUND RS.50 CRORES AS AGAINST THE TURNOVER OF TCS E-SERVE LIMITED OF RS.1405.10 CRORES. THEREFORE, FOLLOWING THE TURNOVE R FILTER AS WELL AS TAKING NOTE OF THE FACT THAT IT OWNS AND POSSESSES BRAND V ALUE AND INTANGIBLES AS COMPARED TO THE ASSESSEE WHICH DOES NOT OWN SUCH AS SETS, WE DIRECT THAT THIS COMPANY BE EXCLUDED FROM THE LIST OF FINAL COM PARABLES. 16.2. IN VIEW OF THE ABOVE DISCUSSION, WE THEREF ORE DIRECT THE ASSESSING OFFICER /TPO TO EXCLUDE THE SAID COMPANY FROM THE LIST OF COMPARABLES AND DETERMINE THE ALP KEEPING IN VIEW O F OUR DIRECTIONS GIVEN HEREINABOVE AND IF ON SUCH DETERMINATION THE PRICE CHARGED BY THE ASSESSEE FOR ITS INTERNATIONAL TRANSACTION IS F OUND TO BE WITHIN THE ARMS LENGTH THEN NO ADJUSTMENT IS REQUIRED TO BE MA DE. 17. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. 18. TO SUM UP, REVENUE APPEAL IN ITA NO. 180/HYD/20 15 IS DISMISSED AND THE ASSESSEES APPEAL IN ITA NO. 326/ HYD/2015 IS PARTLY ALLOWED. PRONOUNCED IN THE OPEN COURT ON 24 TH AUGUST, 2016. SD/- SD/- (P. MADHAVI DEVI) (S. RIFAUR RAH MAN) JUDICIAL MEMBER A CCOUNTANT MEMBER HYDERABAD, DATED: 24 TH AUGUST, 2016 KV COPY TO:- 1) KNOAH SOLUTIONS PVT. LTD., BUILDING NO. 2A, 5 TH FLOOR, MAXIMUS TOWERS, MINDSPACE, RAHEJA IT PARK, CYBERABAD, H YD 500 081. 2) ITO, WARD 2(1), HYDERABAD. 3) DRP, HYDERABAD 4. CIT, (INTERNATIONAL TAXATION & TP), INCOME TAX T OWERS, 10-2-3, AC GUARDS, HYDERABAD 500 004. 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDE RABAD. 9 ITA NOS. 180 & 326 /HYD/2015 KNOAH SOLUTIONS PVT. LTD. S.NO. DESCRIPTION DATE INTLS 1. DRAFT DICTATED ON SR.P.S./P.S 2. DRAFT PLACED BEFORE AUTHOR SR.P.S/PS 3 DRAFT PROPOSED & PLACED BEFORE THE SECOND MEMBER JM/AM 4 DRAFT DISCUSSED/APPROVED BY SECOND MEMBER JM/AM 5 APPROVED DRAFT COMES TO THE SR.P.S./PS SR.P.S./ P.S 6. KEPT FOR PRONOUNCEMENT ON SR. P.S./P.S. 7. FILE SENT TO THE BENCH CLERK SR.P.S./P.S 8 DATE ON WHICH FILE GOES TO THE HEAD CLERK 9 DATE OF DISPATCH OF ORDER