THE ITO, WARD - 1, Amalapuram V. Mother Theresa Educational Society, Amalapuram

ITA 326/VIZ/2013

• Counselvise Citation: [2016] 133 COUNSELVISE.COM (IT) 1988 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 2 year(s) 10 month(s) 22 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-03-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2009-2010
• Appeal Filed On: 09-05-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Charitable institution; Benefit of exemption
• Section: 43B; 142(1); 12A; 12; 28; 10; 11

Judgement Text

ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 1 , , IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM . , . , $ BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER & SHRI G. MANJUNATHA, ACCOUNTANT MEMBER ./I.T.A.NO.326/VIZAG/2013 ( / ASSESSMENT YEAR: 2009-10) ITO , WARD - 1 , AMALAPURAM VS. MOTHER THERESA EDUCATIONAL SOCIETY AMALAPURAM [PAN: AAAAM4660P ] ( % / APPELLANT) ( &'% / RESPONDENT) / APPELLANT BY : SHRI M.N. MURTHY NAIK, DR / RESPONDENT BY : SHR I C. SUBRAHMANYAM, AR / DATE OF HEARING : 22.03.2016 / DATE OF PRONOUNCEMENT : 31.03.2016 / O R D E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: THIS APPEAL FILED BY THE REVENUE IS DIRECTED AGAINS T THE ORDER OF COMMISSIONER OF INCOME TAX (APPEALS)-11, MUMBAI, C AMP AT VISAKHAPATNAM AND IT PERTAINS TO THE ASST. YEAR 200 9-10. ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 2 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E IS A SOCIETY, REGISTERED UNDER ANDHRA PRADESH SOCIETIES REGISTRAT ION ACT AND ALSO REGISTERED UNDER SEC. 12A OF THE INCOME TAX ACT, 19 61. THE SOCIETY HAS FILED ITS RETURN OF INCOME FOR THE A.Y. 2009-10, DE CLARING NIL TOTAL INCOME BY CLAIMING EXEMPTION UNDER SEC. 11 OF THE INCOME T AX ACT, 1961. THE CASE HAS BEEN SELECTED FOR SCRUTINY ASSESSMENT AND ACCORDINGLY, NOTICE UNDER SEC. 143(2) AND 142(1) OF THE INCOME TAX ACT, 1961 WERE ISSUED. IN RESPONSE TO NOTICES, THE AUTHORISED REPRESENTATI VE OF THE ASSESSEE APPEARED FROM TIME TO TIME AND FURNISHED BOOKS OF A CCOUNTS. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE A.O. NOTICED THAT THE ASSESSEE DERIVING INCOME FROM VARIOUS SOURCES, SUCH AS FEES FROM STUDENTS, INCOME FROM HOSPITAL, INCOME FROM PHARMACY, RENT FR OM PREMISES AND INTEREST INCOME FROM BANK DEPOSITS, AGAINST WHICH V ARIOUS EXPENDITURES SUCH AS SALARIES OF FACULTY AND ADMINISTRATIVE STAF F, COLLEGE MAINTENANCE AND ADMINISTRATIVE EXPENSES HAVE BEEN CLAIMED. THE A.O. FURTHER OBSERVED THAT THERE IS PERCEPTIBLE AND GRADUAL INCR EASE IN RECEIPTS FROM RS. 1,58,84,406/- TO RS. 22,57,55,509/- OVER A PERI OD OF FOUR YEARS STARTING FROM A.Y. 2005-06 TO 2008-09. THE SOCIETY HAS AVAILED TERM LOANS FROM BANKS WHICH HAVE BEEN USED FOR CONSTRUCT ION OF COLLEGE BUILDINGS ETC. THOUGH, THE OBJECTS ARE NOT UNDER DI SPUTE, NOR ANY CASE IS BEING MADE OUT FOR RECONSIDERING THE EXEMPTION BY V IRTUE OF REGISTRATION ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 3 UNDER SEC. 12A OF THE ACT, THE ASSESSEES ACTIVITIE S ARE AKIN TO ANY COMMERCIAL ACTIVITY, THEREFORE, ASSESSED THE INCOME OF THE ASSESSEE UNDER THE HEAD INCOME FROM BUSINESS AND MADE DISA LLOWANCES TO VARIOUS EXPENDITURES BY INVOKING THE PROVISIONS OF SEC. 40(A)(IA) FOR NON DEDUCTION OF TDS AND SEC. 43B FOR UNPAID LIABILITIE S. 3. AGGRIEVED BY THE ASSESSMENT ORDER, THE ASSESSEE PREFERRED AN APPEAL BEFORE THE CIT(A). BEFORE CIT(A), THE ASSESS EE SUBMITTED THAT THE ASSESSEE IS A SOCIETY, REGISTERED UNDER SEC. 12 A OF THE INCOME TAX ACT, 1961 WITH THE MAIN OBJECT OF IMPARTING EDUCATI ON. THE ASSESSEE FURTHER SUBMITTED THAT THE A.O. HAS NEVER DOUBTED T HE OBJECTS AND GENUINENESS OF ITS ACTIVITIES AND ALSO NOT MADE OUT ANY CASE OF VIOLATIONS OF SECTION 13(1)(C) OR 13(1)(D) OF THE ACT, SO AS T O DENY THE BENEFIT OF EXEMPTION UNDER SEC. 11, WHICH IS EVIDENT FROM THE ASSESSMENT ORDER, WHEREIN THE A.O. HIMSELF MADE OBSERVATIONS ABOUT TH E GENUINENESS OF THE ACTIVITIES OF THE SOCIETY. THE ONLY POINT ON WH ICH, THE A.O. CAME TO THE CONCLUSION THAT THE ACTIVITY OF SOCIETY IS AKIN TO ANY COMMERCIAL ACTIVITY, IS INCREASE IN RECEIPTS OF SOCIETY. IT WA S FURTHER SUBMITTED THAT UNLESS, PROVE THE OBJECTS ARE NOT GENUINE AND THE A CTIVITIES ARE NOT IN ACCORDANCE WITH THE OBJECTS OF THE TRUST, EXEMPTION CANNOT BE DENIED. THE A.O. WITHOUT POINTING OUT ANY VIOLATIONS REFERR ED TO IN SECTION 13(1) (C) OR 13(1)(D), SIMPLY ASSESSED THE INCOME UNDER T HE HEAD INCOME FROM ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 4 BUSINESS AND DISALLOWED THE EXPENDITURES, BY INVOKI NG SEC. 40(A)(IA) AND 43B, WHICH IS NOT CORRECT. IN SUPPORT OF ITS ARGUME NTS, RELIED UPON THE JUDGMENT OF ITAT, MUMBAI BENCH DECISION IN THE CASE OF MAHATMA GANDHI SEVA MANDIR VS. DDIT (2012) 52 SOT 26. THE C IT(A), AFTER CONSIDERING THE SUBMISSION OF ASSESSEE AND ALSO CON SIDERING THE DECISION OF ITAT, MUMBAI BENCH, IN THE CASE OF MAHATMA GANDH I SEVA MANDIR VS. DDIT (2012) 52 SOT 26, DELETED THE ADDITIONS. THE C IT(A), FURTHER HELD THAT THE PROVISIONS OF SEC. 40(A)(IA) AND 43B ARE N OT APPLICABLE, WHEN INCOME IS COMPUTED UNDER THE PROVISIONS OF SEC. 11 OF THE ACT. 4. THE LD. D.R. SUBMITTED THAT THE CIT(A) OUGHT TO HAVE SUSTAINED THE ADDITIONS MADE U/S 40(A)(IA) AND 43B OF THE ACT , AS THE A.O. HAS ASSESSED THE INCOME UNDER THE HEAD INCOME FROM BUSI NESS AND NOT INCOME FROM OTHER SOURCES. IT WAS SUBMITTED THAT ON CE, INCOME IS ASSESSED UNDER NORMAL PROVISIONS OF INCOME FROM BUS INESS OR PROFESSION, BY DENYING THE EXEMPTION U/S 11, THE PR OVISIONS OF SEC. 40(A)(IA) AND SEC. 43B ARE APPLICABLE. THE CIT(A) E RRONEOUSLY RELIED UPON THE JUDGMENT OF ITAT, WHICH IS RENDERED UNDER DIFFERENT FACTS. 5. PER CONTRA, THE LD. A.R. SUBMITTED THAT THE CIT( A) RIGHTLY HELD THAT THE PROVISIONS OF SEC. 40(A)(IA) AND 43B ARE NOT AP PLICABLE TO TRUST/SOCIETY CLAIMING EXEMPTION UNDER SEC. 11. THE A.R. FURTHER SUBMITTED THAT THE INCOME OF TRUST REGISTERED UNDER SEC. 12A IS TO BE ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 5 COMPUTED UNDER THE PROVISIONS OF SEC. 11, 12 & 13 O F ACT, WHICH ARE FALL UNDER CHAPTER III WHICH DEALS WITH INCOMES WHICH D O NOT FORM PART OF THE TOTAL INCOME. IT WAS FURTHER SUBMITTED THAT SE C. 40(A)(IA) AND SEC. 43B ARE FALLS UNDER CHAPTER IV D, WHICH DEALS WITH COMPUTATION OF PROFITS AND GAINS FROM BUSINESS OR PROFESSION. THE PROFITS AND GAINS FROM BUSINESS OR PROFESSION ARE COMPUTED UNDER SEC. 28. SECTION 29 PROVIDES FOR MANNER OF COMPUTATION OF INCOME UNDER THE HEAD PROFITS AND GAINS OF BUSINESS OR PROFESSION, WHICH STATES THAT THE IN COME REFERRED TO IN SEC. 28 SHALL BE COMPUTED IN ACCORDANCE WITH THE PR OVISIONS OF SEC. 28 TO 43D. THEREFORE, THE PROVISIONS OF SEC. 40(A)(IA) AND 43B ARE RELEVANT, IF INCOME IS COMPUTED UNDER THE HEAD PROFITS AND GA INS OF BUSINESS OR PROFESSION. THE A.O. HAS NOT DOUBTED THE GENUINENES S OF THE ACTIVITIES OF THE TRUST AND WITHOUT POINTING OUT ANY VIOLATION S REFERRED TO IN SECTION 13(1)( C) OR 13(1)(D), SIMPLY ASSESSED THE INCOME U NDER THE HEAD INCOME FROM BUSINESS AND DISALLOWED THE EXPENDITURE S, BY INVOKING SEC. 40(A)(IA) AND 43B WHICH IS NOT CORRECT. IN SUPPORT OF HIS ARGUMENTS, THE A.R. RELIED UPON THE JUDGMENTS OF ITAT, MUMBAI BENC H DECISION IN THE CASE OF MAHATMA GANDHI SEVA MANDIR VS. DDIT (2012) 52 SOT 26. 6. WE HAVE HEARD BOTH THE PARTIES, PERUSED THE MATER IALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHOR ITIES BELOW. THE A.O. DENIED THE BENEFIT OF EXEMPTION UNDER SEC. 11 AND COMPUTED THE ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 6 INCOME UNDER THE HEAD PROFITS AND GAINS OF BUSINESS OR PROFESSION. THE A.O. WAS OF THE OPINION THAT THOUGH, ITS OBJECTS AR E CHARITABLE IN NATURE AND ACTIVITIES ARE GENUINE, THE ACTIVITIES CARRIED OUT BY THE ASSESSEE ARE AKIN TO ANY COMMERCIAL ACTIVITY AND HENCE, COMPUTED THE INCOME UNDER THE HEAD PROFITS AND GAINS OF BUSINESS OR PROFESSIO N. IT WAS THE CONTENTION OF ASSESSEE THAT THE A.O. HAS NEVER DOUB TED THE OBJECTS AND GENUINENESS OF ITS ACTIVITIES AND ALSO NOT MADE OUT ANY CASE OF VIOLATIONS OF SECTION 13(1)(C) OR 13(1)(D) OF THE ACT, SO AS T O DENY THE BENEFIT OF EXEMPTION UNDER SEC. 11, WHICH IS EVIDENT FROM THE ASSESSMENT ORDER, WHEREIN THE A.O. HIMSELF MADE OBSERVATIONS ABOUT TH E GENUINENESS OF THE ACTIVITIES OF THE SOCIETY. THE ONLY POINT ON WH ICH, THE A.O. CAME TO THE CONCLUSION THAT THE ACTIVITY OF SOCIETY IS AKIN TO ANY COMMERCIAL ACTIVITY IS BASED ON INCREASE IN RECEIPTS OF SOCIET Y. THE ASSESSEE FURTHER SUBMITTED THAT THE PROVISIONS OF SECTION 40(A)(IA) AND 43B ARE NOT APPLICABLE, WHEN INCOME IS COMPUTED UNDER SECTION 1 1, 12 & 13 OF THE ACT. 7. THE A.O. COMPUTED THE INCOME UNDER THE NORMAL PR OVISIONS OF PROFITS AND GAINS OF BUSINESS AND PROFESSION. THE A .O. GAVE HIS OWN REASONS FOR NOT APPLYING THE PROVISIONS OF SEC. 11, 12 & 13 OF THE ACT. ON PERUSAL OF REASONS, THE REASONS GIVEN BY THE A.O . FOR DENYING THE EXEMPTIONS, APPEARS TO BE QUITE CONTRARY TO THE LAW . ADMITTEDLY, THE ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 7 SOCIETY IS REGISTERED UNDER SEC. 12A OF THE ACT AND IT IS IMPARTING EDUCATION. IT IS NOT A CASE OF A.O. THAT THE OBJECT S ARE NOT CHARITABLE IN NATURE AND THE ACTIVITIES OF THE ASSESSEE ARE NOT G ENUINE. THE A.O., ONE SIDE ADMITTED THAT THE OBJECTS OF THE SOCIETY ARE N OT UNDER DEBATE, NOR ANY CASE IS BEING MADE OUT FOR RECONSIDERATION OF E XEMPTION ALLOWABLE TO ASSESSEE, BUT ON THE OTHER HAND, DENIED THE EXEM PTION FOR THE REASON THAT THE ASSESSEE GROSS RECEIPTS HAVE INCREASED OVE R A PERIOD. ON PERUSAL OF ASSESSMENT ORDER WE FIND THAT THE A.O. N EITHER DOUBTED THE GENUINENESS OF THE ACTIVITIES OF THE SOCIETY, NOR P OINTED OUT ANY VIOLATION REFERRED TO SEC. 13(1)(C) OR 13(1)(D), WHICH ARE PR E CONDITIONS FOR DENYING EXEMPTION U/S 11 OF THE ACT. THEREFORE, WE ARE OF THE OPINION THAT THE A.O. WAS NOT CORRECT IN DENYING EXEMPTION UNDER SEC. 11 AND ASSESSED INCOME UNDER THE HEAD PROFITS AND GAINS OF BUSINESS OF PROFESSION. 8. HAVING SAID THAT LET US EXAMINE, WHETHER THE PRO VISIONS OF SEC. 40(A)(IA) AND 43B ARE APPLICABLE, WHEN INCOME IS CO MPUTED UNDER SEC. 11, 12 & 13 OF THE ACT. CHAPTER III DEALS WITH INCO MES WHICH DO NOT FORM PART OF TOTAL INCOME. SCE. 11, 12 & 13 DEALS W ITH INCOME FROM PROPERTY HELD FOR CHARITABLE OR RELIGIOUS PURPOSES AND THE MODE OF COMPUTATION OF INCOME SUBJECT TO CERTAIN CONDITIONS . ACCORDINGLY, INCOME OF ANY CHARITABLE TRUST OR SOCIETY IS EXEMPT FROM TAX, IF SUCH ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 8 CONDITIONS ARE FULFILLED. SC. 40(A)(IA) AND SEC. 43 B ARE FALLS UNDER CHAPTER IV D, WHICH DEALS WITH COMPUTATION OF PROFITS AND G AINS FROM BUSINESS OR PROFESSION. THE PROFITS AND GAINS FROM BUSINESS OR PROFESSION ARE COMPUTED UNDER SEC. 28. SECTION 29 PROVIDES FOR MAN NER OF COMPUTATION OF INCOME UNDER THE HEAD PROFITS AND GAINS OF BUSIN ESS OR PROFESSION, WHICH STATES THAT THE INCOME REFERRED TO IN SEC. 28 SHALL BE COMPUTED IN ACCORDANCE WITH THE PROVISIONS OF SEC. 28 TO 43D. T HEREFORE, THE PROVISIONS OF SEC. 40(A)(IA) AND 43B ARE RELEVANT, IF INCOME IS COMPUTED UNDER THE HEAD PROFITS AND GAINS OF BUSINESS OR PRO FESSION. IN THE PRESENT CASE ON HAND, THE INCOME OF THE ASSESSEE IS ELIGIBLE FOR EXEMPTION UNDER SEC. 11 OF THE ACT BY VIRTUE OF REG ISTRATION UNDER SEC. 12A. THE INCOME OF ANY TRUST/SOCIETY, ENJOYING EXE MPTION U/S 11, IS EXEMPT FROM TAX, SUBJECT TO CERTAIN CONDITIONS. IF , SUCH CONDITIONS ARE FULFILLED, THE WHOLE INCOME OF SUCH TRUST IS EXEMPT FROM TAX. THE CONCEPT OF COMPUTATION OF INCOME UNDER SECTION 11 I S REAL INCOME CONCEPT, WHICH IS COMPUTED ON THE PRINCIPLES OF REA L INCOME GENERATED FROM PROPERTY HELD UNDER TRUST AND NOT NOTIONAL INC OME LIKE UNDER OTHER PROVISIONS OF THE ACT. SECTION 11(1)(A) PROVIDES F OR APPLICATION OF INCOME FOR CHARITABLE PURPOSE, THEREFORE, THE QUEST ION OF APPLICATION OF INCOME ARISE ONLY WHEN INCOME IS AVAILABLE FOR APPL ICATION. IF ANY EXPENDITURE IS DISALLOWED BY INVOKING THE PROVISION S OF SECTION 40(A)(IA) ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 9 AND 43B, IT LEADS TO A SITUATION WHERE ASSESSEE INC OME AVAILABLE FOR APPLICATION IS ENHANCED WITHOUT BEING ANY REAL INCO ME FOR APPLICATION FOR CHARITABLE PURPOSE, WHICH LEADS TO AN ABSURD SITUAT ION WHERE THE TRUSTS/SOCIETIES ENJOYING EXEMPTION U/S 11 HAVE TO PAY TAXES. THIS IS BECAUSE, THE ASSESSEE CLAIMING EXEMPTION U/S 11, SH ALL APPLY 85% OF INCOME FOR THE PURPOSE OF OBJECTS OF THE TRUST. TH E LEGISLATURE IN ITS WISDOM HAS KEPT SEPARATE PROVISIONS WHICH ARE INDEP ENDENT FROM ANY OTHER PROVISIONS OF THE ACT FOR COMPUTATION OF INCO ME OF TRUSTS CLAIMING EXEMPTION U/S 11 OF THE ACT. THEREFORE, WE ARE OF T HE OPINION THAT, WHEN INCOME IS COMPUTED UNDER SEC. 11 OF THE ACT, T HE PROVISIONS OF SEC. 40(A)(IA) & 43B ARE NOT APPLICABLE. HENCE, THE A.O. WAS NOT CORRECT IN DISALLOWING THE AMOUNTS BY INVOKING THE PROVISIO NS OF SEC. 40(A)(IA) AND 43B FOR FAILURE TO DEDUCT TDS AND FAILURE TO RE MIT THE UNPAID LIABILITIES. 9. NOW, IT IS PERTINENT TO DISCUSS THE CASE LAWS RE LIED UPON BY THE ASSESSEE. THE ASSESSEE RELIED UPON THE JUDGMENT OF ITAT, MUMBAI BENCH, IN THE CASE OF MAHATMA GANDHI SEVA MANDIR VS . DDIT (EXEMPTIONS) (2012) 52 SOT 26. THE COORDINATE BENCH OF THIS TRIBUNAL, HELD THAT PROVISIONS OF SEC. 40(A) ARE NOT APPLICAB LE, WHEN INCOME IS COMPUTED UNDER SEC. 11 OF THE ACT. THE RELEVANT POR TION IS REPRODUCED HEREINUNDER. ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 10 SECTION 40 IS APPLICABLE ONLY WHEN DEDUCTIONS UNDE R SECTIONS 30 TO 38 ARE BEING MADE IN COMPUTING THE INCOME CHARGE ABLE UNDER THE HEAD PROFITS AND GAINS OF BUSINESS OR PROFESSION UNDER SECTION 28. THE EXCEPTION IN SECTION 40 IS CARVED OUT, ONLY FOR THE PURPOSE OF SECTION 28 AND NOT FOR COMPUTING THE EXEMPTION OF INCOME OF A CHARITABLE TRUST UNDER SECTION 11. THE DISALLOWANCE MADE UNDER SECT ION 40(A) WILL ONLY GO TO ENHANCE THE BUSINESS PROFIT OF AN ASSESSEE WH OSE INCOME IS ASSESSABLE UNDER SECTION 28 AND NOT OTHERWISE. HEN CE, PROVISIONS OF SECTION 40(A) ARE NOT APPLICABLE IN CASE OF CHARITA BLE TRUST OR INSTITUTION WHERE INCOME AND EXPENDITURE IS COMPUTED IN TERMS O F SECTION 11. 10. CONSIDERING THE FACTS AND CIRCUMSTANCES OF THIS CASE AND ALSO APPLYING THE RATIO OF CO-ORDINATE BENCH DECISION, I N THE CASE OF MAHATMA GANDHI SEVA MANDIR VS. DDIT (EXEMPTIONS) (2012) 52 SOT 26, WE ARE OF THE OPINION THAT SEC. 40(A)(IA) AND 43B ARE NOT APP LICABLE, WHEN INCOME IS COMPUTED UNDER SEC. 11 OF THE ACT. THE CIT(A) HA S RIGHTLY DELETED THE ADDITIONS. WE DO NOT SEE ANY ERROR OR INFIRMITY IN T HE ORDER OF CIT(A). HENCE, WE INCLINED TO UPHELD THE CIT(A) ORDER AND D ISMISS THE REVENUE APPEAL. 11. IN THE RESULT, THE APPEAL FILED BY THE REVENUE IS DISMISSED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT ON 31 ST MAR16. SD/- SD/- ( . ) ( . ) (V. DURGA RAO) (G. MANJUNATHA) /JUDICIAL MEMBER /ACCOUNTANT MEMBER # /VISAKHAPATNAM: ' /DATED : 31.03.2016 VG/SPS ITA NO.326/VIZAG/2013 MOTHER THERESA EDUCATIONAL SOCIETY, AMALAPURAM 11 )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT THE ITO WARD-1, AMALAPURAM 2. / THE RESPONDENT MOTHER THERESA EDUCATIONAL SOCI ETY, CHAITANYA NAGAR, AMALAPURAM. 3. + / THE CIT, RAJAHMUNDRY 4. THE PRINCIPAL CIT-2, VISAKHAPATNAM 5. + ( ) / THE CIT (A)-11, MUMBAI, CAMP: VISAKHAPATNAM 6. # . , . , # / DR, ITAT, VISAKHAPATNAM 7 . / GUARD FILE / BY ORDER // TRUE COPY // 12 . (SR.PRIVATE SECRETARY) . , # / ITAT, VISAKHAPATNAM