Appeal details
Counselvise Citation
[2016] 130 COUNSELVISE.COM (IT) 9944 (ITAT-VISAKHAPATNAM)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
3 year(s) 2 month(s) 25 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
12-08-2016
Appeal Filed By
Department
Order Result
Dismissed
Bench Allotted
DB
Assessment Year
2009-2010
Appeal Filed On
17-05-2013
Judgement Text
ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 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.327/VIZAG/2013 ( / ASSESSMENT YEAR:2009-10) M/S. PREMIER ENGINEERING SYNDICATE RAJAHMUNDRY VS. ACIT, CIRCLE - 1, RAJAHMUNDRY [PAN: AAEFP5873L ] ( % / APPELLANT) ( &'% / RESPONDENT) ./I.T.A.NO.346/VIZAG/2013 ( / ASSESSMENT YEAR:2009-10) ACIT, CIRCLE - 1, RAJAHMUNDRY VS. M/S. PREMIER ENGINEERING SYNDICATE RAJAHMUNDRY ( % / APPELLANT) ( &'% / RESPONDENT) / APPELLANT BY : SHRI G.V.N. HARI, AR / RESPONDENT BY : SHRI M.K. SETHI, DR / DATE OF HEARING : 19.07.2016 / DATE OF PRONOUNCEMENT : 12.08.2016 ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 2 / O R D E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: THESE CROSS APPEALS FILED BY THE ASSESSEE, AS WELL AS REVENUE ARE DIRECTED AGAINST COMMON ORDER PASSED BY THE CIT(A), VISAKHAPATNAM DATED 14.3.2013 AND IT PERTAINS TO THE ASSESSMENT Y EAR 2009-10. SINCE, THE FACTS ARE IDENTICAL AND ISSUES ARE COMMON, THEY ARE HEARD TOGETHER AND DISPOSED OFF, BY THIS COMMON ORDER FOR THE SAKE OF CONVENIENCE. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E IS A PARTNERSHIP FIRM ENGAGED IN THE BUSINESS OF CONSTRUCTION OF APA RTMENTS, VILLAS AND GATED COMMUNITY PROJECTS, FILED ITS RETURN OF INCOM E FOR THE ASSESSMENT YEAR 2009-10 DECLARING TOTAL INCOME OF ` 1,04,09,050/-. THE CASE HAS BEEN SELECTED FOR SCRUTINY AND ACCORDINGLY, NOTICE U/S 143(2) OF THE INCOME TAX ACT, 1961 (HEREINAFTER CALLED AS 'THE AC T') DATED 22.11.2011 WAS ISSUED TO THE ASSESSEE FIXING THE CASE FOR HEAR ING ON 1.12.2011. THE ASSESSEE NEITHER APPEARED BEFORE THE A.O., NOR FURNISHED ANY DETAILS AS SOUGHT BY THE ASSESSING OFFICER AND HENC E THE A.O. COMPLETED ASSESSMENT EX-PARTE U/S 144 OF THE ACT AND DETERMIN ED TOTAL INCOME OF ` 3,25,15,203/-. ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 3 3. AGGRIEVED BY THE ASSESSMENT ORDER, THE ASSESSEE PREFERRED AN APPEAL BEFORE THE CIT(A). BEFORE THE CIT(A), THE AS SESSEE HAS FILED ELABORATE WRITTEN SUBMISSIONS. DURING THE COURSE OF APPELLATE PROCEEDINGS, THE CIT(A) HAS FORWARDED ADDITIONAL EV IDENCES FILED BY THE ASSESSEE TO THE A.O. FOR HIS COMMENTS. THE A.O. VI DE HIS REMAND REPORT DATED 18.12.2013 REAFFIRMED ESTIMATION OF NET PROFI T @ 15% ON TOTAL CONTRACT RECEIPTS, HOWEVER, SUBMITTED THAT NO ADDIT ION IS REQUIRED IN RESPECT OF DUTIES AND TAXES RECEIVED AND INCOME FRO M OTHER SOURCES. SIMILARLY, THE A.O. STATED THAT AS REGARDS TREATMEN T OF PROFIT ON SALE OF PROPERTY UNDER THE HEAD INCOME FROM PROFITS AND GA INS OF BUSINESS OR PROFESSION, THE A.O. SUPPORTED HIS PREDECESSOR ASS ESSING OFFICERS FINDINGS. AS REGARDS ADDITIONS TOWARDS CAPITAL GAI N, THE A.O. STATED THAT DETAILS FILED BY THE ASSESSEE HAVE BEEN VERIFIED AN D NO ADDITION IS CALLED FOR. 4. THE CIT(A) AFTER CONSIDERING THE EXPLANATION FUR NISHED BY THE ASSESSEE AND ALSO TAKEN INTO ACCOUNT REMAND REPORT ISSUED BY THE A.O., HELD THAT THE ASSESSEE HAS NOT SUBSTANTIATED BOOK R ESULTS WITH NECESSARY SUPPORTING BILLS & VOUCHERS, THEREFORE, UPHELD THE ACTION OF THE A.O. FOR ESTIMATION OF NET PROFIT OF 15% ON GROSS RECEIPTS. SIMILARLY, THE CIT(A) HELD THAT AS REGARDS ADDITIONS TOWARDS DUTIES AND T AXES AND OTHER ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 4 INCOME, THE A.O. IN THE REMAND REPORT HAS VERIFIED DETAILS FURNISHED BY THE ASSESSEE AND REPORTED THAT THE ASSESSEE HAS SAT ISFACTORILY EXPLAINED BOTH ISSUES AND HENCE NO ADDITION IS CALLED FOR. B ASED ON THE REMAND REPORT OF THE A.O., THE CIT(A) HELD THAT ADDITIONS MADE BY THE A.O. TOWARDS DUTIES AND TAXES AND OTHER INCOME CANNOT SU STAIN IN THE EYES OF LAW. SIMILARLY, AS REGARDS PROFIT FROM SALE OF PROP ERTY UNDER THE HEAD INCOME FROM PROFITS & GAINS OF BUSINESS, THE CIT( A) HELD THAT THE ASSESSEE IS IN THE BUSINESS OF CONSTRUCTION OF APAR TMENTS, DEVELOPMENT OF VILLAS AND GATED COMMUNITY PROJECTS AND ALSO THE ASSESSEE HAS PURCHASED IMPUGNED PROPERTY FOR THE PURPOSE OF CONS TRUCTION OF APARTMENTS. THE ASSESSEES MAIN ACTIVITY IS TO EXP LOIT THE PROPERTY FOR COMMERCIAL PURPOSES BY CONSTRUCTING APARTMENTS. THE REFORE, THE A.O. WAS RIGHTLY TREATED SURPLUS FROM SALE OF PROPERTY U NDER THE HEAD INCOME FROM PROFITS & GAINS OF BUSINESS. SIMILARLY, AS RE GARDS SEPARATE ADDITIONS TOWARDS PROFIT FROM SALE OF PROPERTY UNDER THE HEAD CAPITAL GAINS, THE CIT(A) OBSERVED THAT ONCE A PARTICULAR INCOME IS TA XED UNDER ONE HEAD, SEPARATE ADDITIONS TOWARDS SAME INCOME CANNOT BE MA DE UNDER DIFFERENT HEAD. WITH THESE OBSERVATIONS, THE CIT(A ) DIRECTED THE A.O. TO DELETE ADDITIONS MADE TOWARDS SURPLUS FROM SALE OF PROPERTY UNDER THE HEAD CAPITAL GAINS. AGGRIEVED BY THE CIT(A) ORDE R, THE ASSESSEE AS WELL AS REVENUE ARE IN APPEAL BEFORE US. ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 5 5. THE ASSESSEE HAS RAISED AS MANY AS 6 GROUNDS OF APPEALS. GROUND NO.1 AND 6 ARE GENERAL IN NATURE AND HENCE N OT SPECIFICALLY ADJUDICATED. THE ASSESSEE HAS CHALLENGED LEGALITY O F THE ASSESSMENT ORDER PASSED U/S 144 OF THE ACT BY WAY OF GROUND NO S.2&3. DURING THE COURSE OF HEARING, THE LD. A.R. FOR THE ASSESSEE SU BMITTED THAT HE DID NOT PRESS GROUND NOS.2&3 CHALLENGING THE VALIDITY O F ASSESSMENT PROCEEDINGS. HENCE, GROUND NOS.2&3 ARE DISMISSED A S NOT PRESSED. 6. THE FIRST ISSUE THAT CAME UP FOR OUR CONSIDERATI ON IS ESTIMATION OF NET PROFIT FROM BUSINESS. DURING THE COURSE OF ASS ESSMENT PROCEEDINGS, THE A.O. ESTIMATED NET PROFIT OF 15% ON GROSS PROFI TS. THE A.O. WAS OF THE OPINION THAT THE NET PROFIT DECLARED BY THE ASS ESSEE IS VERY LOW WHEN COMPARED TO SIMILAR NATURE OF BUSINESSES. THE A.O. FURTHER OPINED THAT THE ASSESSEE HAS NOT SUBSTANTIATED BOOK RESULTS WIT H NECESSARY EVIDENCES. IT IS THE CONTENTION OF THE ASSESSEE TH AT NET PROFIT ESTIMATED BY THE A.O. IS QUITE HIGH WHEN COMPARED TO THE NATU RE OF BUSINESSES. THE ASSESSEE FURTHER CONTENDED THAT IT HAS MAINTAIN ED PROPER BOOKS OF ACCOUNTS ALONG WITH BILLS & VOUCHERS, HOWEVER, THE A.O. HAS NOT AFFORDED REASONABLE OPPORTUNITIES OF BEING HEARD TO SUBMIT THE BILLS & VOUCHERS. THEREFORE, THE ESTIMATION MADE BY THE A. O. SHOULD BE SCALED DOWN. ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 6 7. WE HAVE HEARD BOTH THE PARTIES, PERUSED THE MATER IALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHOR ITIES BELOW. IN THIS CASE, THE ASSESSMENT HAS BEEN COMPLETED U/S 144 OF THE ACT. THE A.O. ESTIMATED NET PROFIT OF 15% ON GROSS RECEIPTS. THE A.O. WAS OF THE OPINION THAT NET PROFIT DECLARED BY THE ASSESSEE IS LESS WHEN COMPARED TO SIMILAR NATURE OF BUSINESSES. IT IS THE CONTENT ION OF THE ASSESSEE THAT NET PROFIT ESTIMATED BY THE A.O. IS QUITE HIGH AND ALSO THE A.O. HAS NOT AFFORDED REASONABLE OPPORTUNITY OF BEING HEARD TO S UBSTANTIATE BOOK RESULTS. WE FIND NO MERITS IN THE ARGUMENTS OF THE A SSESSEE FOR THE REASON THAT EVEN DURING APPELLATE PROCEEDINGS, THE ASSESSEE HAS FAILED TO SUBSTANTIATE NET PROFIT DECLARED WITH NECESSARY EVIDENCES. THE A.O. WHILE ISSUING REMAND REPORT HAS REITERATED THAT THE ASSESSEE HAS NOT SUBMITTED ANY BILLS & VOUCHERS TO SUBSTANTIATE NET PROFIT DECLARED FOR THE YEAR. WE FURTHER NOTICED THAT EVEN BEFORE US, EXCEPT PLEADED FOR SCALED DOWN NET PROFIT ESTIMATED BY A.O., THE ASSESSEE FAI LED TO PROVE NET PROFIT DECLARED WITH NECESSARY EVIDENCES AND ALSO F AILED TO FILE ANY COMPARATIVE CASES IN THIS LINE OF BUSINESS TO JUSTI FY NET PROFIT. THE CIT(A) AFTER CONSIDERING THE RELEVANT DETAILS AFFIR MED NET PROFIT ESTIMATED BY THE A.O. WE DO NOT SEE ANY REASONS TO INTERFERE WITH THE ORDER PASSED BY THE LD. CIT(A). HENCE, WE INCLINED TO UPHELD THE CIT(A) ORDER AND REJECT THE GROUND RAISED BY THE AS SESSEE. ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 7 8. THE NEXT ISSUE THAT CAME UP FOR OUR CONSIDERATIO N IS TREATMENT OF PROFIT FROM SALE OF PROPERTY UNDER THE HEAD PROFIT S & GAINS OF BUSINESS OR PROFESSION. THE FACTS WHICH LEAD TO ADDITIONS ARE THAT DURING THE YEAR UNDER CONSIDERATION, THE ASSESSEE HAS SOLD AN IMMOVABLE PROPERTY AND COMPUTED LONG TERM CAPITAL GAIN. THE A.O. WAS OF THE OPINION THAT THE ASSESSEES DOMINANT OBJECT IS TO DEVELOP AND CO NSTRUCT APARTMENTS, VILLAS AND GATED COMMUNITY PROJECTS, THEREFORE, SUR PLUS FROM SALE OF IMMOVABLE PROPERTY SHOULD BE ASSESSABLE UNDER THE H EAD PROFITS & GAINS OF BUSINESS OR PROFESSION. IT IS THE CONTEN TION OF THE ASSESSEE THAT IT HAS PURCHASED IMPUGNED PROPERTY FOR THE PUR POSE OF DEVELOPMENT OF APARTMENTS, HOWEVER, BECAUSE OF LEGA L PROBLEMS IT COULD NOT DEVELOP THE PROPERTY. THE ASSESSEE FURTHER CON TENDED THAT IT HAS SHOWN PROPERTY AS INVESTMENT IN THE BOOKS OF ACCOUN TS AND SOLD AFTER THREE YEARS, ACCORDINGLY, SURPLUS FROM SALE OF PROP ERTY IS TAXABLE UNDER THE HEAD INCOME FROM CAPITAL GAINS. 9. 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. TREATED SURPLUS FROM SALE OF PROPERTY UNDER TH E HEAD PROFITS & GAINS OF BUSINESS OR PROFESSION. THE A.O. WAS OF THE OPINION THAT THE ASSESSEE IS INVOLVED IN THE BUSINESS OF CONSTRUCTIO N AND SALE OF ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 8 APARTMENTS AND VILLAS, ACCORDINGLY, SURPLUS FROM SA LE OF PROPERTY IS TAXABLE UNDER THE HEAD PROFITS & GAINS OF BUSINESS OR PROFESSION. IT IS THE CONTENTION OF THE ASSESSEE THAT THOUGH IT IS IN VOLVED IN THE BUSINESS OF REAL ESTATE DEVELOPMENT, THE IMPUGNED PROPERTY H AS BEEN ACQUIRED AS AN INVESTMENT AND SHOWN UNDER THE HEAD FIXED AS SETS IN THE BALANCE SHEET. THE ASSESSEE FURTHER CONTENDED THAT THE PRO PERTY HAS BEEN SOLD AFTER 3 YEARS AND ACCORDINGLY, SURPLUS FROM SALE OF PROPERTY IS TAXABLE UNDER THE HEAD CAPITAL GAINS. WE DO NOT SEE ANY M ERITS IN THE ARGUMENTS OF THE ASSESSEE FOR THE REASON THAT MERE ENTRY IN THE BOOKS OF ACCOUNTS DOES NOT DECIDE THE HEAD OF INCOME OR A LTER THE CHARACTER OF INCOME UNDER WHICH HEAD IT IS TAXABLE. IN THE PRES ENT CASE ON HAND, ON PERUSAL OF THE FACTS AVAILABLE ON RECORD, WE NOTICE D THAT THE ASSESSEES MAIN ACTIVITY IS CONSTRUCTION AND SALE OF APARTMENT S AND VILLAS. DURING THE YEAR UNDER CONSIDERATION, THE ASSESSEE HAS GENE RATED INCOME FROM SALE OF APARTMENTS. AS CLAIMED BY THE ASSESSEE, TH E ASSESSEE HAS PURCHASED SAID PROPERTY FOR THE PURPOSE OF CONSTRUC TION OF APARTMENTS. FROM THIS, IT IS EVIDENT THAT THE ASSESSEES INTENT ION IS TO COMMERCIALLY EXPLOIT THE PROPERTY BY CONSTRUCTION OF APARTMENTS. THEREFORE, WE ARE OF THE VIEW THAT ONCE PROPERTY HAS BEEN PURCHASED W ITH A INTENTION OF COMMERCIAL EXPLOITATION, ANY SURPLUS FROM SALE OF S UCH PROPERTY IS TAXABLE UNDER THE HEAD PROFITS & GAINS OF BUSINESS OR PROFESSION. THE ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 9 CIT(A) AFTER CONSIDERING RELEVANT DETAILS RIGHTLY U PHELD THE ACTION OF THE A.O. WE DO NOT SEE ANY REASONS TO INTERFERE WITH TH E ORDER PASSED BY THE CIT(A). HENCE, WE INCLINED TO UPHOLD THE CIT(A ) ORDER AND REJECT THE GROUND RAISED BY THE ASSESSEE. 10. THE NEXT ISSUE THAT CAME UP FOR OUR CONSIDERATI ON IS ADDITION TOWARDS PROFITS FROM SALE OF PROPERTY UNDER THE CAP ITAL GAINS, IN ADDITION TO ADDITIONS MADE UNDER THE HEAD PROFITS & GAINS O F BUSINESS OR PROFESSION. THE A.O. MADE SEPARATE ADDITIONS TOWAR DS PROFIT FROM SALE OF PROPERTY UNDER THE HEAD INCOME FROM CAPITAL GAI NS, IN ADDITION TO ADDITION MADE UNDER THE HEAD PROFITS AND GAINS OF B USINESS OR PROFESSION. THE CIT(A) AFTER TAKING INTO ACCOUNT TH E REMAND REPORT ISSUED BY THE A.O. AND ALSO CONSIDERING RELEVANT DE TAILS FILED BY THE ASSESSEE HELD THAT SEPARATE ADDITION IS NOT REQUIRE D UNDER THE HEAD CAPITAL GAINS, WHEN SURPLUS FROM SALE OF PROPERTY HAS BEEN BROUGHT TO TAX UNDER THE HEAD PROFIT & GAINS OF BUSINESS OR P ROFESSION. THE CIT(A) RIGHTLY DELETED ADDITIONS MADE BY THE A.O. WE DO NO T SEE ANY REASONS TO INTERFERE WITH ORDER PASSED BY THE CIT(A). HENC E, WE INCLINED TO UPHOLD THE CIT(A) ORDER AND REJECT THE GROUND RAISE D BY THE REVENUE. 11. THE NEXT ISSUE THAT CAME UP FOR OUR CONSIDERATI ON FROM REVENUES APPEAL IS ADDITIONS TOWARDS DUTIES AND TAXES RECEIV ED AND INCOME FROM ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 10 OTHER SOURCES. THE A.O. MADE SEPARATE ADDITIONS TOW ARDS DUTIES & TAXES RECEIVED AND INCOME FROM OTHER SOURCES, IN ADDITION TO ESTIMATION OF NET PROFIT FROM GROSS RECEIPTS. IT IS THE CONTENTION O F THE ASSESSEE THAT THE A.O. WAS ERRED IN MAKING ADDITIONS TOWARDS DUTIES & TAXES AND INCOME FROM OTHER SOURCES, WHEN NET PROFIT IS ESTIMATED FR OM GROSS RECEIPTS. THE ASSESSEE FURTHER CONTENDED THAT DUTIES & TAXES RECEIVED BY THE ASSESSEE ARE TAXES COLLECTED ON GROSS RECEIPTS WHIC H WERE PAID TO THE CONCERNED AUTHORITIES. THE ASSESSEE FURTHER CONTEND ED THAT IN THE BOOKS OF ACCOUNTS IT HAS SHOWN DUTIES AND TAXES COLLECTED SEPARATELY IN THE FINANCIAL STATEMENTS. WE FIND FORCE IN THE ARGUMEN TS OF THE ASSESSEE FOR THE REASON THAT THE ASSESSEE HAS SHOWN DUTIES AND T AXES COLLECTED FROM GROSS RECEIPTS AND PAYMENT OF DUTIES AND TAXES SEPA RATELY IN THE PROFIT AND LOSS ACCOUNT. ON PERUSAL OF THE FINANCIAL STAT EMENTS FILED BY THE ASSESSEE, WE NOTICED THAT DUTIES AND TAXES RECEIVED BY THE ASSESSEE AND SHOWN IN THE CREDIT SIDE OF THE PROFIT & LOSS ACCOU NT IS EQUAL TO AMOUNT PAID TO THE CONCERNED AUTHORITIES AND DEBITED TO PR OFIT & LOSS ACCOUNT. THE ASSESSEE NEITHER RECEIVED ANY INCOME NOR ACCRUE D ANY BENEFIT OUT OF DUTIES AND TAXES. IT IS ONLY AN ENTRY PASSED IN THE BOOKS OF ACCOUNTS FOR SEPARATE DISCLOSURE OF DUTIES AND TAXES COLLECT ED. THEREFORE, WE ARE OF THE VIEW THAT THE A.O. WAS NOT CORRECT IN MAKING ADDITIONS TOWARDS DUTIES AND TAXES. AS REGARDS INCOME FROM OTHER SOU RCES, THE A.O. IN THE ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 11 REMAND REPORT HAS ACCEPTED EXPLANATIONS FURNISHED B Y THE ASSESSEE AND REITERATED THAT NO SEPARATE ADDITION IS NOT CALLED FOR. THEREFORE, WE ARE OF THE VIEW THAT THE A.O. WAS NOT CORRECT IN MAKING SEPARATE ADDITIONS TOWARDS INCOME FROM OTHER SOURCES, WHEN NET PROFIT IS ESTIMATED FROM GROSS RECEIPTS. THE CIT(A) AFTER CONSIDERING RELEV ANT DETAILS FILED BY THE ASSESSEE AND ALSO TAKEN INTO ACCOUNT REMAND REPORT OF THE A.O., DELETED ADDITIONS MADE BY THE A.O. TOWARDS DUTIES AND TAXES RECEIVED AND INCOME FROM OTHER SOURCES. WE DO NOT SEE ANY REASO NS TO INTERFERE WITH ORDER PASSED BY THE CIT(A). HENCE, WE INCLINED TO UPHOLD THE CIT(A) ORDER AND REJECT THE GROUND RAISED BY THE REVENUE. 12. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IN ITA NO.327/VIZAG/2013 AND APPEAL FILED BY THE REVENUE I N ITA NO.346/VIZAG/2013 ARE DISMISSED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT ON 12 TH AUG16. SD/- SD/- ( . ) ( . ) (V. DURGA RAO) (G. MANJUNATHA) /JUDICIAL MEMBER /ACCOUNTANT MEMBER # /VISAKHAPATNAM: ' /DATED : 12.08.2016 VG/SPS ITA NOS.327&346/VIZAG/2013 M/S. PREMIER ENGINEERING SYNDICATE, RAJAHMUNDRY 12 )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT M/S. PREMIER ENGINEERING SYNDICA TE, 74-5-10, PRAKASH NAGAR, RAJAHMUNDRY 2. / THE RESPONDENT THE ACIT, CIRCLE-1, RAJAHMUNDRY 3. + / THE CIT, RAJAHMUNDRY 4. + ( ) / THE CIT (A)-11, MUMBAI, CAMP AT VISAKHAPATNAM 5. # . , . , # / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // 12 . (SR.PRIVATE SECRETARY) . , # / ITAT, VISAKHAPATNAM
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