Appeal details
Counselvise Citation
[2017] 127 COUNSELVISE.COM (IT) 2648 (ITAT-HYDERABAD)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
4 year(s) 5 month(s) 11 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
29-08-2017
Appeal Filed By
Assessee
Order Result
Dismissed
Bench Allotted
A
Next Hearing Date
15-06-2017
Assessment Year
2008-2009
Appeal Filed On
18-03-2013
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES A : HYDERABAD BEFORE SHRI D. MANMOHAN, VICE PRESIDENT AND SHRI INTURI RAMA RAO , ACCOUNTANT MEMBER ITA.NO S . 336 TO 338/HYD/ 2013 ASSESSMENT YEAR S 2007 - 08 TO 2009 - 2010 SPECIAL DEPUTY COLLECTOR (L.A), TELUGU GANGA PROJECT, UNIT - II, KADAPA. VS. ITO, TDS - (3)(6), TIRUPATHI. (APPELLANT) (RESPONDENT) FOR ASSESSEE: SHRI G. CHINNAIAH, DEPUTY TAHASILDAR FOR REVENUE : SHRI V. SREEKAR, DR DATE OF HEARING : 29.08 .2017 DATE OF PRONOUNCEMENT : 29.08 .2017 ORDER PER D. MANMOHAN , VP. THESE THREE APPEALS ARE FILED AT THE INSTANCE OF THE ASSESSEE AND THEY ARE DIRECTED AGAINST THE ORDER PASSED BY THE LD. CIT(A), VIJAYAWADA. IN RESPECT OF THE A.Y. 2007 - 2008, THE FOLLOWING GROUND WERE URGED BY THE ASSESSEE. 1. THE HONBLE COMMISSIONER OF INCOME TAX APPEALS OUGHT NOT HAVE REJECTED APPELLANTS CLAIM FOR RELIEF FROM TDS SHORT DEDUCTION IN RESPECT OF NON - FILERS OF INCOME TAX RETURNS, AS THERE IS NO REVENUE LOSS ENVISAGED IN CASE OF NON - FI LES ALSO, AS THE NON - FILERS ARE MAINLY AGRICULTURISTS / AGRICULTURAL LABOUR AND NOT AWARE OF INCOME TAX PROCEEDINGS, HENCE NOT FILED THEIR IT RETURNS. THE LARGE SAMPLE OF INCOME TAX ASSESSMENT ORDERS OF OTHER CLAIMANTS ESTABLISHED THAT THERE IS NO REVENUE LOSS. 2. THE APPELLANT PRAYS YOUR HONOUR TO GRANT RELIEF RS. 7,04,742/ - FROM TDS SHORT DEDUCTION DEMAND PERTAINING TO NON - FILERS OF INCOME TAX RETURNS. 3. APPELLANT FURTHER PRAYS YOUR HONOUR TO GRANT CONSEQUENTIAL RELIEF IN INTEREST U/S 201(1A) ON ACCOUNT OF GRANTING RELIEF IN TDS SHORT DEDUCTION DEMAND. 2 2. F OR THE AYS 2008 - 2009 AND 2009 - 2010 THE FOLLOWING COMMON GROUND WAS URGED. 1. THE HONBLE COMMISSIONER OF INCOME TAX APPEALS OUGHT NOT HAVE REJECTED APPELLANTS CLAIM FOR RELIEF FROM TDS SHORT DEDUCTION IN RESPECT OF NON - FILERS OF INCOME TAX RETURNS, AS THERE IS NO REVENUE LOSS ENVISAGED IN CASE OF NON - FILES ALSO, AS THE NON - FILERS ARE MAINLY AGRICULTURISTS / AGRICULTURAL LABOUR AND NOT AWARE OF INCOME TAX PROCEEDINGS, HENCE NOT FILED THEIR IT RETURNS. THE LARGE SAMPLE OF INCOME TAX ASSESSMENT ORDERS OF OTHER CLAIMANTS ESTABLISHED THAT THERE IS NO REVENUE LOSS. 3. FACTS NECESSARY FOR THE DISPOSAL OF THE APPEAL ARE STATED IN BRIEF. THE APPELLAN T IS A SPECIAL DEPUTY COLLECTOR, LAND ACQUISITION, WHO IS VESTED WITH THE POWERS TO ACQUIRE LAND FOR SOMASILA PROJECT AND IN TURN PAYS COMPENSATION TO THE BENEFICIARIES. THE ASSESSEE IS UND ER OBLIGATION TO DEDUCT TAX AT SOURCE UPON PAYMENTS MADE TO THE PARTIES IN THE COURSE OF ACQUIRING LAND OWNED BY THE PARTIES . 4. DURING THE COURSE OF SURVEY PROCEEDINGS IT WAS NOTICED THAT THE ASSESSEE HAS NOT FOLLOWED THE TDS PROVISIONS PROPERLY I.E., (A) WHILE PAYING COMPENSATION TO THE AWARDEES, THE ASSESSEE HAS TO DEDUCT TAX AT SOURCE. ASSESSEE WAS OF THE OPINION THAT IN RESPECT OF PAYMENTS BELOW RS. 1 LAKH IT IS EXEMPTED FROM DEDUCTING TAX AT SOURCE WHEREAS THE ASSESSING OFFICER IS OF THE VIEW THAT NO SUCH EXEMPTION IS PERMITTED AND AS PER THE PROVISIONS OF SECTION 194 - LA OF THE ACT TAX HAS TO BE DEDUCTED AT SOURCE WHERE THE AGGREGATE PAYMENT EXCEEDS RS. 1 LAKH; (B) THE TDS APPLIED BY THE ASSESSE DEFERRED FROM CASE TO CASE RANGING BETWEEN 5% TO 7% WITH OUT FOLLOWING AN UNIFORM RATE AS SPECIFIED IN THE ACT I.E., 10%; (C) IN SOME CASES, THE ASSESSEE - DEDUCTOR COMMITTED ONE MORE MISTAKE OF APPLYING THE RATES PRESCRIBED FOR CONTRACT WORKS U/S 194C INSTEAD OF 10% PRESCRIBED U/S 194 - LA OF THE ACT. 3 5. DURING T HE COURSE OF PROCEEDINGS THE ASSESSEE SUBMITTED THAT THERE IS NO DISCREPANCY IN THE TAX DEDUCTED AT SOURCE . IT WAS ALSO SUBMITTED THAT THE LAND WAS ACQUIRED IN RURAL AREAS AND MOST OF THE RECIPIENTS ARE AGRICULTURISTS WHO DO NOT HAVE ANY OTHER SOURCE OF I NCOME OTHER THAN AGRICULTURAL INCOME. IN FACT HOUSES, WHICH WERE ACQUIRED, WERE SITUATED IN RURAL AREAS. THE COMPENSATION RECIPIENTS ARE THOUSANDS IN NUMBER WHO HAVE LEFT THEIR RESPECTIVE VILLAGES AND SCATTERED OVER VARIOUS VILLAGES IN KADAPA DISTRICT AN D SURROUNDING DISTRICTS . T HEREFORE TRACING THEM NOW IS IMPOSSIBLE. UNDER THESE CIRCUMSTANCES COLLECTION AND RECOVERY OF ANY AMOUNT OF TDS FROM THE BENEFICIARIES / COMPENSATION RECIPIENTS IS ALMOST IMPOSSIBLE. IT WAS ALSO STATED THAT THE TAX DEDUCTED BY THE ASSESSEE WAS PROPER IN THE CIRCUMSTANCES OF THE CASE. 6 . THE A.O. OBSERVED THAT THE SPECIAL DEPUTY COLLECTOR / DDO IS A RESPONSIBLE PERSON FOR MAKING VARIOUS PAYMENTS BY DEDUCTING THE TAX FROM THE PA YMENTS MADE WHEREAS , IN THE INSTANT CASE, THERE WAS SHORT DEDUCTION / NON - REMITTANCE OF THE TDS INTO CENTRAL GOVERNMENT ACCOUNT. HE HAS CALCULATED THE SHORT DEDUCTION AND THE INTEREST PAYABLE AS PER THE CHART GIVEN IN HIS ORDER FOR THE FY 2006 - 07 DATED 26 .10.2007. IN THIS REGARD, HE ALSO OBSERVED AS UNDER: - ON VERIFICATION OF THE BOOKS OF ACCOUNTS AND MATERIAL PRODUCED IT IS NOTICED THAT THE ASSESSEE DEDUCTOR HAS NOT FOLLOWED THE PROVISIONS OF TDS IN THE FOLLOWING INSTANCES. 1. WHILE MAKING THE COMPENSATION TO THE AWARDEES, THE PROVISIONS OF TDS HAS NOT BE FOLLOWED PROPERLY. AS PER THE PROVISION OF TDS IF THE COMPENSATION WAS PAID BELOW RS. ONE LAKH IT IS EXEMPTED FROM THE DEDUCTION OF TDS. IF THE TOTAL COMPENSATION PAID TO THE AWARDEES EXCEEDS ABOVE ONE L AKH, THE TDS AT THE RATE OF 10% (EXCLUDING SURCHARGE, EDUCATION CESS ETC...) HAS TO BE DEDUCTED ON THE ENTIRE COMPENSATION PAID. THE QUESTION OF EXEMPTION OF RS. ONE LAKH DOES NOT ARISE. ON VERIFICATION OF THE OFFICE RECORDS IT IS NOTICED THAT THE TDS WA S WORKED OUT ON THE COMPENSATION AFTER EXEMPTING RS. ONE LAKH WHICH IS NOT CORRECT. ON QUESTIONING THE SAME THE ASSESSEE DEDUCTOR EXPLAINED THAT HIS PREDECESSORS FOLLOWED SUCH A METHOD DUE TO WRONG INTERPRETATION OF TDS PROVISIONS AND ACCEPTED THE MISTAKE . AS PER 4 THE PROVISIONS LAID DOWN IN THE INCOME TAX ACT SECTION 194L A SPEAKS AT THE TIME OF PAYMENT OF COMPENSATION FOR ACQUIRING THE LAND AND BUILDING OTHER THAN AGRICULTURAL LAND AT THE RATE OF 10% IS TO BE DEDUCTED AS TDS WHERE THE AGGREGATE PAYMENT E XCEEDS RS. ONE LAKH DURING THE FINANCIAL YEAR. AS SUCH THE CORRECT TDS IS WORKED OUT ON THE COMPENSATION PAID TO THE AWARDEES AND THE SHORT DEDUCTION WAS BROUGHT OUT INVOKING THE PROVISIONS U/S 201(1) ALONG WITH INTEREST CHARGEABLE U/S 201(1A) FOR FY 2006 - 07. 2. THE PRESCRIBED RATE OF TDS TO BE DEDUCTED ON THE COMPENSATION HAS NOT APPLIED PROPERLY. THE RATE OF TDS APPLIED IS DIFFERED FROM CASE TO CASE. FOR SOME OF THE BENEFICIARIES THE RATE HAS BEEN APPLIED FOR 5% AND 6% AND IN SOME CASES 7% WITHOUT HAVING ANY UNIFORM RATE AS SPECIFIED IN THE INCOME TAX ACT I.E., 10% (EXCLUDING SURCHARGES AND EDUCATION CESS ETC...) 3. IN SOME CASES THE ASSSESSEE DEDUCTOR HAS COMMITTED ONE MORE MISTAKE WHILE DEDUCTING THE TDS AT THE TIME OF PAYMENT OF COMPENSATION. THE ASSESSEE DEDUCTOR HAS APPLIED THE RATES PRESCRIBED FOR CONTRACT WORKS TO BE DEDUCTED U/S 194C INSTEAD OF 10% PRESCRIBED FOR 194LA. IN SUCH A PASSION THE ASSESSEE DEDUCTOR HAS APPLIED 2. 24%, 2.3% AND 2.06% LIKE WISE WHICH RESULTED IN A HIGHER SIDE OF SHORT DEDUCTION ON THE PAYMENTS MADE FOR COMPENSATION. 7 . IN RESPECT OF THE FY RELEVANT TO THE A.Y. 2008 - 2009 AND 2009 - 10 TDS OFFICER NOTICED THAT THERE IS NON - REMITTANCE OF TDS WHILE PAYIN G COMPENSATION TO THE AWARDEES. IN RESPONSE TO THE NOTICE , THE PARTY ADMITTED THAT HIS PREDECESSOR OFFICER WAS OF THE OPINION THAT TDS PROVISIONS ARE APPLICABLE ONLY WHEN THE TOTAL COMPENSATION PAYABLE TO THE AWARDEES EXCEED RS. 1 LAKH. IN OTHER WORDS, T HE WRONG INTERPRETATION OF TDS PROVISIONS WAS ACCEPTED BY THE PRESENT INCUMBENT. ACCORDINGLY THE ASSESSING OFFICER WORKED OUT THE SHORT DEDUCTION OF TAX FOR THE PURPOSE OF RAISING A DEMAND U/S 201(1) OF THE ACT AND ALSO COMPUTED INTEREST CHARGEABLE U/S 20 1(1A) OF THE ACT ON SUCH SHORT DEDUCTION. 8 . AGGRIEVED , ASSESSEE CONTENDED BEFORE THE LD. CIT(A) THAT THE ASSESSEE IS A STATE GOVERNMENT AUTHORITY WHICH HAS NO INTENTION TO DEVIATE FROM THE PROVISIONS OF THE ACT THOUGH AT THE RELEVANT POINT IN TIME THE INCUMBENT OFF ICER MIGHT HAVE HAD MISCONCEPTION WHICH MIGHT HAVE RESULTED INTO INADVERTENT ERRORS. IT WAS ALSO CONTENDED THAT LAND WAS ACQUIRED MAINLY FROM THE AGRICULTURISTS , WHO WERE LIVING IN 5 SUBMERGED VILLAGES , HAVING AGRICULTURAL INCOME AS TH EIR SOURCE , WHICH IS EXEMPT UNDER THE INCOME TAX ACT. THE RELEVANT EXTRACTS FROM THE STATEMENT OF FACTS AND GROUNDS OF APPEAL ARE REPRODUCED TO APPRECIATE THE STAND OF THE ASSESSEE. 3......... THE APPELLANT FURTHER SUBMITS THAT THE BENEFICIARIES OF LAND / STRUCTURES ACQUISITION ARE MAINLY AGRICULTURISTS WHO WERE LIVING IN SUBMERGED VILLAGES, HAVING AGRICULTURAL INCOME AS THEIR ONLY SOURCE, WHICH IS EXEMPTED INCOME UNDER THE INCOME TAX ACT. WE UNDERSTAND FROM OUR ENQUIRIES THAT SEVERAL BENEFICIARIES, WHO HAVE COLLECTED FORM 16A FROM OUR OFFICE, HAVE APPLIED FOR REFUNDS AND GOT REFUND OF TDS ALSO. IN A NUTSHELL, WE SUBMIT THAT THE TDS ALREADY EFFECTED (EVEN THOUGH SHORT DEDUCTION IN SOME CASES) IS REFUNDED BY THE INCOME TAX DEPARTMENT IN VIRTUALLY ALL CASE S AS THE BENEFICIARIES ARE MAINLY AGRICULTURISTS AND THEY DO NOT HAVE ANY SOURCE OF INCOME OTHER THAN AGRICULTURAL INCOME. WE PRAY TO YOUR HONOUR TO APPRECIATE THE FACT THAT THE SHORT DEDUCTION OF TDS IF ANY, HAS NOT RESULTED IN ANY REVENUE LOSS TO THE IN COME TAX DEPARTMENT. WHILE WE REGRET FOR THE INADVERTENT ERROR COMMITTED BY THE THEN IN CHARGE OFFICER, WE PRAY YOUR HONOUR TO APPRECIATE THE FACTS AND CIRCUMSTANCES OF THE CASE, THE FACT OF TDS BEING REFUNDED TO VIRTUALLY ALL COMPENSATION RECIPIENTS AS T HEY ARE ALL AGRICULTURISTS. ............. .............. .............. THE LEARNED AO HAS ERRED IN ADOPTING THE ASST. YEAR OF TAX DEDUCTION OBLIGATION RESULTING IN OVERSTATEMENT OF SHORT DEDUCTION OF TDS IN THE INITIAL YEARS (FY 2006 - 07, FY 2007 - 08) AND THE CONSEQUENTIAL UNDERSTATEMENT OF SHORT DEDUCTION IN LATER YEARS. WE SUBMIT THAT WHEN THE MATTER IS DECIDED BY THE HONBLE COURTS, THE YEAR OF ACTUAL DISBURSEMENT BY THE JUDGE TO THE CLAIMANTS, SHALL BE TREATED AS THE YEAR OF TAX DEDUCTIBILITY, BUT NOT THE YEAR WHEN FUNDS ARE DEPOSITED WITH THE JUDGE AND WE FURTHER SUBMIT THAT THE HONBLE JUDGE IS HOLDING APPELLANTS FUNDS AS TRUSTEE TO ENSURE PROPER DISBURSEMENT TO CLAIMANTS. WE HUMBLY SUBMIT THAT THE AP PELLANT HAS PROMPTLY DEPOSITED TDS INTO CENTRAL G OVT. ACCOUNT AS PER APPELLANTS VERSION OF YEAR OF TAX DEDUCTIBILITY EXPLAINED ABOVE I.E., ON RETURN OF TDS AMOUNT FROM THE HONBLE JUDGE. WE REQUEST YOUR HONOUR TO ISSUE SUITABLE DIRECTIONS TO THE AO TO CORRECTLY WORKOUT THE SHORT DEDUCTION ON THE BASIS OF YEAR OF DEDUCTIBILITY EXPLAINED ABOVE. 9 . DURING THE COURSE OF HEARING LD AR SHRI JAGANNADHA RAO APPEARED ALONG WITH A SPECIAL DEPUTY COLLECTOR AND FILED WRITTEN SUBMISSIONS IN SUPPORT OF THEIR STAND THAT IT IS A BONAFIDE CASE FOR WHICH THE ASSESSEE CANNOT BE TREATED AS DEFAULTER U/S 201(1) OF THE ACT AND INTEREST IS NOT CHARGEABLE U/S 201(1A) OF THE ACT. IT WAS ALSO 6 SUB MITTED, VIDE LETTER DATED 23.3.2013, THAT THERE ARE DOUBLE ACCOUNTING OF SAME ITEMS RESULTING IN EXCESS TDS DEMANDS. 10 . HAVING PERU SED THE FACTS AND CIRCUMSTANCES OF THE CASE, LD. CIT(A) OBSERVED THAT THE LAND ACQUISITION OFFICER (LAO) HAS NOT PROPERLY DEDUCTED TAX ON THE ORIGINAL COMPENSATION / ENHANCED COMPENSATION PAID TO THE LAND OWNERS. IN FACT THE LAO DEDUCTED TAX ON AMOUNTS EX CEEDING RS. 1 LAKH , WHICH IS NOT IN ACCORDANCE WITH LAW. THUS ON REAPPRAISAL OF THE FACTS AND CIRCUMSTANCES, THE LD. CIT(A) MADE THE FOLLOWING MODIFICATIONS TO THE ORDERS PASSED BY THE TDS OFFICER. FOR A.Y. 2007 - 2008 : DATE OF COMPENSATION OF PAYMENT AMOUNT OF COMPENSATION PAID FOR LANDS / STRUC./DECREETAL CHARGES AS PER IMPUGNED ORDERS RELIEF OF COMPENSATION TO BE ALLOWED TO THE APPELLANT 194LA 194A LESS THAN RS. 1 LAKH TO EACH CLAIMANT AGRICULTURAL LAND INTEREST SPREAD OVER 15.08.2006 26579768 1743699 -- -- 16.08.2006 24580662 365446 -- -- 04.09.2006 4856141 2115673 -- 951409 30.08.2006 13419220 1184214 -- 226944 05.09.2006 2947028 874395 -- 166972 05.09.2006 4357171 1944494 -- 795319 05.09.2006 4749359 1961248 -- 689737 03.02.2007 51247861 19060056 9297049 127680 31.03.2007 3648924 457174 -- -- 31.03.2007 544021 2527491 -- -- 12.12.2006 24957694 18874917 1212100 18019 13.02.2008 269844 81114 -- TOTAL 52308615 10509149 2976080 FOR A.Y. 2008 - 2009: DATE OF COMPENSATION OF PAYMENT AMOUNT OF COMPENSATION PAID FOR LANDS / STRUC./DECREETAL CHARGES AS PER IMPUGNED ORDERS RELIEF OF COMPENSATION TO BE ALLOWED TO THE APPELLANT 194LA 194A LESS THAN RS. 1 LAKH TO EACH CLAIMANT AGRICULTURAL LAND INTEREST SPREAD OVER 7 31.072007 43640706 3010487 16529315 63065 02.07.2007 6149131 2554877 -- 128391 02.07.2007 5778587 1665068 -- -- TOTAL 7230432 16529315 191456 FOR A.Y. 2009 - 2010: DATE OF COMPENSATION OF PAYMENT AMOUNT OF COMPENSATION PAID FOR LANDS / STRUC./DECREETAL CHARGES AS PER IMPUGNED ORDERS RELIEF OF COMPENSATION TO BE ALLOWED TO THE APPELLANT 194LA 194A LESS THAN RS. 1 LAKH TO EACH CLAIMANT AGRICULTURAL LAND INTEREST SPREAD OVER 07.08.2008 4246905 -- 3057010 -- 28.01.2009 22707596 9141759 -- 1817410 13.10.2008 7333356 1886103 -- 692561 13.10.2008 6623817 2351831 -- 129001 TOTAL 13379693 3057010 2638972 11 . WITH REGARD TO THE PERIOD OF DEFAULT , THE A.O. WAS DIRECTED TO RECALCULATE THE INTEREST FROM THE DATE OF ISSUE OF DEMAND DRAFT FOR COMPENSATION AMOUNT BY THE COURT TO THE DATE OF PAYMENT COMMITTED BY THE ASSESSEE. THE LD CIT (A) APPLIED THE RATIO OF THE DECISION OF THE APEX COURT IN THE CASE OF HINDUSTAN COCA COLE BEVERAGE PRIVATE LIMITED VS. CIT [2007] 293 ITR 226 (SC) AND HELD THAT SINCE TAX WAS ALREADY COLLECTED, THE TDS NEED NOT BE DEDUCTED AGAIN SUBJECT TO FURNISHING OF DOCUMENTS BEFORE THE AO. AS REGARDS THE DOUBLE ACCOUNTING OF THE SAME ITEMS LD CIT (A) MADE SUITABLE MODIFICATIONS AND DIRECTED THE AO TO VERIFY THE APPELLA NT S CONTENTIONS IN THAT REGARD. 12 . FURTHER AGGRIEVED , APPEALS WERE FILED BEFORE US. 13 . SHRI G. CHINNAIAH, DEPUTY TAHASILDAR, APPEARED ON BEHALF OF THE LAND ACQUISITION OFFICER AND SHRI V. SREEKAR APPEARED ON BEHALF OF THE REVENUE. BOTH OF THEM RELIED UPO N THE RESPECTIVE ARGUMENTS MADE BEFORE THE LD CIT (A). 8 14 . WE HAVE CAREFULLY CONSIDERED THE ISSUE BY PERUSING THE RECORD. ADMITTEDLY THE LAO HAS NOT DEDUCTED APPROPRIATE TAX AT SOURCE ON THE AMOUNTS PAID TO THE AGRICULTURISTS AND THE ONLY ARGUMENT ADVANCE D BEFORE THE TAX AUTHORITIES WAS THAT THERE IS NO REVENUE LOSS TO THE GOVERNMENT AND HENCE THE D D O SHOULD NOT BE TREATED AS AN ASSESSEE IN DEFAULT. NO FURTHER MATERIAL WAS BROUGHT BEFORE US TO CONTRADICT THE FINDINGS AND CONCLUSIONS OF THE LD CIT (A) WITH R EGARD TO THE APPLICATION OF PROVISIONS OF SECTION 201(1) AND 201(1A) OF THE ACT. IN FACT THE CASE OF THE ASSESSEE IS THAT IT WAS A BONA FIDE ERROR ON THE PART OF THE LAO. 15. EQUITY AND TAXATION ARE STRANGERS AND THERE CANNOT BE ANY LAXITY E V E N I F I T I S O N A C C O U N T O F A BONA FIDE ERRORS. UNDER THESE CIRCUMSTANCES, THE LD CIT (A) EXPRESSED HIS IN ABILITY TO ACCORD ANY RELIEF, B EYOND THE RELIEF ACCORDED IN THE FORM OF RECALCULATION OF THE PENALTY AS WELL AS THE INTEREST PAYABLE U/ S 201(1) AND 201(1A) OF THE ACT. W E ARE TH EREFORE OF THE OPINION THAT THE ORDERS PASSED BY THE LD CIT (A) DO NOT CALL FOR ANY INTERFERENCE. 16 . IN THE RESULT, THE APPEALS BY THE ASSSESSEE / LAO ARE DISMISSED. S D / - S D / - ( INTURI RAMA RAO ) (D. MANMOHAN) ACCOUNTANT MEMBER VICE PRESIDENT HYDERABAD, DATED: 29 TH AUGUST , 2017 OKK, SR.PS 9 COPY TO 1. THE SPECIAL DEPUTY COLLECTOR, TELUGU GANGA PROJECT, UNIT - II, MAMILLAPALLI, C.K. DINNE, KADAPA CITY (AP) PIN CODE - 516003. 2. INCOME TAX OFFICER, TDS (3)(6), AAYAKAR BHAVAN, K.T. ROAD, TIRUPATHI. 3. CIT(A) - VIJAYAWADA. 4. THE ITO (TDS - 2), TIRUPATHI. 5. D.R. ITAT A BENCH, HYDERABAD. 6. GUARD FILE
