STC Transports Pvt.Ltd., Vijayawada V. The ACIT, Vijayawada

ITA 350/VIZ/2016

• Counselvise Citation: [2017] 126 COUNSELVISE.COM (IT) 6544 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 1 year(s) 3 month(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-11-2017
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Assessment Year: misc
• Appeal Filed On: 18-07-2016
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Keywords: Rule of consistency

Judgement Text

ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 1 , , IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM . , . . ' , % BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER & SHRI D.S. SUNDER SINGH, ACCOUNTANT MEMBER ./I.T.A.NO.350/VIZAG/2016 ( / ASSESSMENT YEAR: 2012-13) STC TRANSPORTS (PVT) LTD., VIJAYAWADA ACIT, CIRCLE - 2(1) VIJAYAWADA [PAN NO. AAJCS7810C ] ( ' / APPELLANT) ( ()' / RESPONDENT) / APPELLANT BY : SHRI C. SUBRAHMANYAM, AR / RESPONDENT BY : SHRI M.N. MURTHY NAIK, DR / DATE OF HEARING : 25.10.2017 / DATE OF PRONOUNCEMENT : 08.11.2017 / O R D E R PER D.S. SUNDER SINGH, ACCOUNTANT MEMBER: THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAIN ST ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS) {CIT(A)}, VIJA YAWADA VIDE ITA NO.468/CIT(A)/VJA/14-15 DATED 2.3.2016 FOR THE ASSE SSMENT YEAR 2012-13. ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 2 2. THE FIRST ISSUE IS RELATED TO THE DISALLOWANCE O F INTEREST FOR DIVERSION OF FUNDS. MR. D.L.V. SRIDHAR IS THE MANA GING DIRECTOR OF THE COMPANY. DURING THE PREVIOUS YEAR RELEVANT TO THE ASSESSMENT YEAR 2012-13, THE ASSESSING OFFICER FOUND AS PER BALANC E SHEET THAT, THE COMPANYS OWN FUNDS WERE ` 4,28,82,458/- AND THE TANGIBLE ASSETS WERE ` 4,43,47,169/-, THUS, THE A.O. VIEWED THAT THE ASSE SSEES FUNDS WERE BLOCKED IN TANGIBLE ASSETS AND NO INTEREST FRE E FUNDS ARE AVAILABLE TO THE COMPANY. THE A.O. FURTHER NOTED THAT THERE WAS AN AMOUNT OF ` 1 CRORE REPRESENTING SHARE APPLICATION MONEY WITH M /S. ECOREN ENERGY INDIA PVT. LTD. WAS SHOWN AS AN ASSET. THE ABOVE A SSET WAS BROUGHT FORWARD FROM FINANCIAL YEAR 2010-11. THE A.O. OBS ERVED THAT THE COMPANY HAS NOT TRANSFERRED THE AMOUNT OF ` 1.00 CRORE TO M/S. ECOREN ENERGY INDIA PRIVATE LIMITED AND THE ASSESSEE COMPA NY HAS PAID THE SAME TO MR. D.L.V. SRIDHAR WHO IN TURN HAS MADE THE INVESTMENT TOWARDS SHARE APPLICATION MONEY IN M/S. ECOREN ENER GY INDIA PRIVATE LIMITED. THE COMPANY OF M/S. ECOREN ENERGY INDIA P RIVATE LIMITED HAS ISSUED SHARES TO MR. SRIDHAR, THE M.D. OF THE COMPA NY AND SUBSEQUENTLY MR. SRIDHAR HAS TRANSFERRED THE SHARES TO THE ASSES SEE COMPANY. THEREFORE, THE A.O. HELD THAT THE ASSESSEE COMPANY DIVERTED THE INTEREST BEARING FUNDS TO THE M.D. AND THE TRANSFER OF SHARES TO THE ASSESSEE COMPANY IS A COLOURABLE DEVICE TO AVOID TH E INTEREST ON INTEREST ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 3 BEARING FUNDS. THE A.O. FURTHER OBSERVED THAT THE COMPANY HAS GIVEN INTEREST FREE ADVANCE OF ` 1,47,27,123/- TO ITS DIRECTORS AND EXPLAINED THAT THE SAID SUM WAS GIVEN TOWARDS ADVANCE FOR PUR CHASE OF VACANT LAND FROM MR. SRIDHAR. BUT THE ASSESSEE COMPANY DI D NOT PRODUCE NECESSARY EVIDENCE SUCH AS RESOLUTION OF BOARD OF D IRECTORS, TIME FRAME OF PAYMENT SCHEDULE, REGISTERED COPY OF AGREEMENT, ETC. THEREFORE, THE A.O. HELD THAT THE ASSESSEE COMPANY HAS DIVERTED TH E COMPANYS INTEREST BEARING FUNDS TO THE EXTENT OF ` 1,47,27,123/- AS INTEREST FREE ADVANCES TO THE DIRECTORS. THE COMPANY HAS DEBITED A TOTAL SUM OF ` 57,19,116/- AS INTEREST. HENCE, THE A.O. DISALLOWE D A SUM OF ` 28,95,255/- INTEREST RELATABLE TO THE ADVANCES GIVE N TO THE DIRECTOR AS INTEREST FREE ADVANCE @ 12% AND ADDED BACK TO THE I NCOME. AGGRIEVED BY THE ORDER OF THE A.O., THE ASSESSEE WENT ON APPE AL BEFORE THE CIT(A) AND THE LD. CIT(A) CONFIRMED THE ADDITION MADE BY T HE A.O. FOR READY REFERENCE, WE EXTRACT RELEVANT PARAGRAPH OF THE LD. CIT(A)S ORDER, WHICH READS AS UNDER: 6.2 I HAVE PERUSED THE SUBMISSION OF APPELLANT AND THE ASSESSM ENT ORDER AND RELEVANT INCOME TAX MISCELLANEOUS RECORDS. 6.2.1 AS PER SCHEDULE 16 OF BALANCE SHEET FOR THE Y EAR ENDED 31.03.2012, LOANS & ADVANCES TO DIRECTORS IS AS FOLLOWS: ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 4 (AMOUNT IN RS.) DETAILS AS AT 31 ST MARCH, 2012 A S AT 31 ST MARCH , 2011 UNSECURED, CONSIDERED GOOD - D VENKATARATNAM 13,01,846 23,61 , 862 - DLV SRIDHAR 1,28,25,277 47,19,105 - D. SUSEELA -- 5,13,277 6.2.2. AS AGAINST LAST YEAR (31.03.2011) OUTSTANDIN G ADVANCE TO DIRECTORS OF RS.75,94,244/-, THIS YEAR (31.03.2012) OUTSTANDI NG ADVANCE TO DIRECTORS STOOD AT RS.1,41,27,123/-. THUS, THERE IS OVERALL I NCREASE OF RS.65,32,879/- IN ADVANCES TO DIRECTORS. ADMITTED LY, THIS IS INTEREST FREE ADVANCE GIVEN TO DIRECTORS. 6.2.3. SRI D.L.V.SRIDHAR, DIRECTOR OF THE APPELLANT COMPANY WAS HOLDING 10 LAKH SHARES OF 0.001% OPTIONALLY CONVERTIBLE REDEEM ABLE PREFERENCE SHARES, EACH RS 10/- IN ECOREN ENERGY IN DIA PRIVATE LTD. (UNQUOTED INVESTMENTS) AS PER THE SHARE CERTIF ICATE DATED 25.06.2012. AS PER FORM NO.SH.4 SECURITIES TRANSFER FORM, THE SHARES WERE TRANSFERRED IN THE NAME OF APPELLANT CO MPANY ON 06.05.2014 (DATE OF EXECUTION 25.04.2014). 6.2.4. IT IS ALSO A FACT THAT APPELLANT COMPANY HAD NOT TRANSFERRED THE MONEY DIRECTLY TO M/S.ECOREN ENERGY INDIA PVT. LTD. MONEY WAS PAID BY SRI D.L.V.SRIDHAR AND THE SHARES WERE ALLOT TED IN HIS NAME AND ONLY THROUGH FOUR JOURNAL ENTRIES (BEING TRANSF ER ENTRY MADE TOWARDS AMOUNT INVESTED THROUGH D.L.V.SRIDHAR ACCOU NT ON 27.08.20, 14.09.2010, 11.10.2010 & 28.10.2010 EACH FOR A SUM OF RS.25 LAKHS) WERE PASSED TO SHOW THIS AS INVESTMENT IN M/S. ECOREN ENERGY INDIA PVT. LTD. IN THE BOOKS OF APPEL LANT COMPANY. 6.2.5. APPELLANT HAD NOT ADMITTED ANY INCOME IN THE FORM OF DIVIDEND ETC. IN RESPECT OF INVESTMENTS IN M/S.ECOREN ENERGY INDI A PVT. LTD. 6.2.6. BORROWING MUST BE FOR THE PURPOSE OF BUSINESS. AMOU NT BORROWED IN APPELLANTS CASE HAD NOT BEEN USED FOR THE PURPO SE OF BUSINESS BUT FOR ADVANCING THE DIRECTOR OF THE COMPANY WITHOUT INTER EST. HENCE, DISALLOWANCE OF INTEREST IS JUSTIFIED. ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 5 3. DURING THE APPEAL HEARING, THE LD. A.R. SUBMITTE D THAT THE INVESTMENT WAS MADE DURING THE FINANCIAL YEAR 2010- 11 RELEVANT TO THE ASSESSMENT YEAR 2011-12 BUT NOT IN THE YEAR UNDER C ONSIDERATION. THE A.O. HAS NOT CHARGED ANY INTEREST FOR THE ASSESSMEN T YEAR 2011-12, HENCE FOLLOWING THE RULE OF CONSISTENCY NO INTEREST REQUIRED TO BE CHARGED IN THE YEAR UNDER CONSIDERATION. THE LD. A. R. FURTHER SUBMITTED THAT MR. SRIDHAR, M.D. OF THE COMPANY HAS INVESTED IN SHARE APPLICATION MONEY OF M/S. ECOREN ENERGY INDIA PRIVATE LIMITED O UT OF HIS OWN FUNDS BUT NOT FROM THE COMPANYS FUNDS. REFERRING TO PAG E NO.22 OF THE PAPER BOOK, THE LD. A.R. HAS TAKEN OUR ATTENTION TO AXIS BANK ACCOUNT COPY AND DEMONSTRATED THAT THE AMOUNT OF ` 1 CRORE WAS INVESTED OUT OF MR. SRIDHARS OWN FUNDS AND SUBMITTED THAT NO FUNDS RELATING TO THE COMPANY WAS FLOWN FOR INVESTMENT OF THE SHARE APPLI CATION MONEY. FURTHER, REFERRING TO PAGE NO.56 OF THE PAPER BOOK, THE LD. A.R. SUBMITTED THAT SUBSEQUENTLY, THE COMPANY HAS TAKEN A DECISION TO INVEST IN M/S. ECOREN ENERGY INDIA PRIVATE LIMITED, HENCE, THE SHARES OF MR. SRIDHAR WERE TRANSFERRED TO THE ASSESSEE COMPAN Y BY JOURNAL ENTRIES AND BROUGHT INTO THE BOOKS OF THE ASSESSEE COMPANY. THE PURCHASE OF SHARES OF M/S. ECOREN ENERGY INDIA PRIVATE LIMITED IS A BUSINESS DECISION HENCE CANNOT BE HELD TO BE DIVERSION OF BUSINESS FU NDS. THE ASSESSEE ALSO TAKEN US TO THE ACCOUNT COPY OF MR. D. SRIDHAR IN THE BOOKS OF M/S. ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 6 STC TRANSPORTS AND DEMONSTRATED THAT THE COMPANYS FUNDS WERE NOT USED FOR MAKING INVESTMENT IN M/S. ECOREN ENERGY IN DIA PRIVATE LIMITED FOR SHARE APPLICATION MONEY. HENCE, THE LD. A.R. A RGUED THAT THE INVESTMENTS ARE BUSINESS DECISIONS IN THE INTEREST OF BUSINESS, HENCE THERE IS NO CASE FOR DIVERSION OF FUNDS AND NO INTE REST REQUIRED TO BE DISALLOWED ON ACCOUNT OF INVESTMENT MADE IN M/S. EC OREN ENERGY PRIVATE INDIA LIMITED. 4. THE NEXT ISSUE IS THE ADVANCE GIVEN TO MR. SRIDH AR AMOUNTING TO ` 1,41,27,123/-. THE LD. A.R. SUBMITTED THAT MR. SRI DHAR, M.D. OWNS A PIECE OF LAND WHICH WAS PURCHASED BY HIM ON 25.6.20 08 AT ENIKEPADU VILLAGE ADMEASURING 1504.81 SQ.YDS. WITH AC SHEET R OOF BUILDING IN R.S. NO.168/1, 168/2. THE COMPANY INTENDED TO PURCHASE THE SAID LAND, ACCORDINGLY, ENTERED INTO AN AGREEMENT FOR PURCHASE OF THE LAND ON 8 TH DAY OF AUGUST, 2008 AND PAID THE ADVANCES ON VARIOU S DATES TO THE EXTENT OF ` 1,41,27,123/- TILL THE END OF FINANCIAL YEAR 2012. HOWEVER, THE SAID LAND WAS NOT REGISTERED FOR PAYMENT OF THE BALANCE AMOUNT. LATER, THE SAID LAND WAS REGISTERED IN FAVOUR OF TH E COMPANY BY A SALE DEED DATED 15 TH NOVEMBER, 2016 AFTER MAKING THE COMPLETE PAYMENT. THEREFORE, THE LD. A.R. SUBMITTED THAT THE ADVANCE OF ` 1,41,27,123/- IS ADVANCE PAID TO THE VENDOR FOR PURCHASE OF THE LAND BUT NOT DIVERSION OF FUNDS. THEREFORE, THE LD. A.R. ARGUED THAT THERE I S NO CASE FOR ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 7 DISALLOWING THE INTEREST AND THE LD. CIT(A) HAS COM MITTED AN ERROR WHICH REQUIRED TO BE SET ASIDE AND ALLOW THE APPEAL OF THE ASSESSEE. 5. ON THE OTHER HAND, THE LD. D.R. SUPPORTED THE OR DER OF THE LOWER AUTHORITIES AND ARGUED THAT IT IS CLEAR DIVERSION O F BORROWED FUNDS FOR NON BUSINESS PURPOSES. THE LAND WAS REGISTERED IN THE NAME OF THE COMPANY AFTER SUBSTANTIAL LAPSE OF THE TIME. THERE WAS A TIME GAP OF MORE THAN 4 YEARS AND THE PURCHASE AGREEMENT WAS UN REGISTERED, THEREFORE, THE LD. D.R. ARGUED THAT THE SALE DEED A ND ADVANCE FOR PURCHASE OF LAND IS A COLOURABLE DEVICE AND REQUEST ED TO UPHOLD THE ORDER OF THE LD. CIT(A). 6. WE HAVE HEARD BOTH THE PARTIES, PERUSED THE MATER IALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHOR ITIES BELOW. THERE WAS AN AMOUNT OF ` 1.00 CRORE OUTSTANDING WHICH WAS SHOWN AS AN ASSET IN THE BALANCE SHEET UNDER THE HEAD NON CURRE NT ASSETS. THE SAID SUM WAS REPRESENTED THE SHARE APPLICATION MONEY IN THE NAME OF M/S. ECOREN ENERGY INDIA PRIVATE LIMITED. THE SAID SHAR ES WERE PURCHASED FROM MR. D.L.V. SRIDHAR, M.D. OF THE COMPANY. THE COMPANY HAS NOT GIVEN ANY ADVANCE FOR MAKING INVESTMENT IN SHARE AP PLICATION MONEY. THE FUNDS FOR SHARE APPLICATION MONEY WERE FLOWN FR OM THE PERSONAL ACCOUNT OF MR. D.L.V. SRIDHAR BUT NOT FROM THE COMP ANY. THE ACCOUNT OF MR. SRIDHAR, M.D. HAS NOT GONE INTO NEGATIVE BALANC E AT ANY POINT OF ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 8 TIME. THIS FACT WAS DEMONSTRATED BY THE LD. A.R. B Y REFERRING TO PAPER BOOK PAGE NO.22, 56, 62 & 75. AS PER THE ACCOUNT CO PY OF MR. SRIDHAR WITH THE COMPANY AND THE BANK ACCOUNT ESTABLISHED T HAT THE COMPANYS FUNDS WERE NOT FLOWN TO MR. SRIDHAR FOR INVESTMENT IN SHARES. THE INVESTMENT WAS MADE OUT OF THE OWN FUNDS OF MR. SRI DHAR AND IN THE INTEREST OF THE COMPANY, THE ASSESSEE COMPANY HAS A CQUIRED THE SHARES FROM MR. SRIDHAR, WHICH WAS REFLECTED IN THE BALANC E SHEET. THE LD. A.R. ARGUED THAT THE DECISION TO TAKE OVER THE SHARES OF MR. SRIDHAR WAS THE BUSINESS DECISION AND THE REVENUE COULD NOT CONTROV ERT WITH ANY EVIDENCE. THEREFORE, THERE IS NO CASE FOR DIVERSIO N OF FUNDS AND DISALLOWANCE OF INTEREST RELATABLE TO DIVERSION OF FUNDS. ACCORDINGLY, WE REVERSE THE ORDER OF THE LD. CIT(A) AND ALLOW THE A PPEAL OF THE ASSESSEE. 7. THE NEXT ISSUE IS THE DISALLOWANCE OF INTEREST O N ADVANCES GIVEN TO THE M.D., MR. D. SRIDHAR AMOUNTING TO ` 1,41,27,123/-. THE LD. A.R. SUBMITTED THAT THE ADVANCES WERE GIVEN TO MR. SRIDH AR FOR PURCHASE OF LAND. IN SUPPORT, THE ASSESSEE HAS PRODUCED THE PU RCHASE AGREEMENT COPY. AS PER THE PURCHASE AGREEMENT, ASSESSEE COMP ANY INTENDED TO PURCHASE THE LAND BELONGING TO MR. SRIDHAR AT ENIKE PADU VILLAGE ADMEASURING 1504.81 SQ.YDS. IN R.S. NO.168/1, 168/2 FOR A CONSIDERATION OF ` 1.5 CRORES. THE LAND WAS ALSO REGISTERED IN FAVOU R OF ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 9 THE ASSESSEE COMPANY BY SALE DEED DATED 15.11.2016 FOR A CONSIDERATION OF ` 1.5 CRORES. SINCE THE LAND WAS REGISTERED IN THE NAME OF ASSESSEE COMPANY, THERE IS NO CASE FOR SUSPICION OF DIVERSION OF FUNDS FOR NON BUSINESS PURPOSES. THE LD.A.R HAS FURNISHE D THE EVIDENCE STATING THAT THE SALE PROCEEDS OF THE SAID LAND WAS OFFERED TO CAPITAL GAINS TAX BY MR. SRIDHAR. SINCE THE ASSESSEE HAS P RODUCED THE COPY OF PURCHASE AGREEMENT AND THE SALE DEED THE TRANSACTIO N APPEARS TO BE GENUINE AND T THERE IS NO CASE FOR DIVERSION OF F UNDS, ACCORDINGLY, WE HOLD THAT BOTH THE A.O. AND CIT(A) HAS ERRED IN HOL DING THAT INTEREST BEARING FUNDS WERE DIVERTED FOR NON BUSINESS PURPOS ES. ACCORDINGLY, WE DELETE THE INTEREST CONFIRMED BY THE LD. CIT(A) AMO UNTING TO ` 28,95,255/- AND SET ASIDE THE ORDERS OF THE LOWER A UTHORITIES AND ALLOW THE APPEAL OF THE ASSESSEE. 8. THE NEXT ISSUE IN THIS APPEAL IS RELATED TO THE ADDITION OF ` 5,09,841/- BEING HIRE CHARGES PAID. DURING THE ASS ESSMENT PROCEEDINGS, THE A.O. FOUND THAT THE ASSESSEE HAD DEBITED A SUM OF ` 50,98,410/- TOWARDS HIRE CHARGES AND MADE CASH PAYMENTS. THE A SSESSING OFFICER DISALLOWED 10% OF HIRE CHARGES ON ESTIMATION BASIS FOR NOT PRODUCING PROPER EVIDENCES AND DURING THE ASSESSMENT PROCEEDI NGS, THE A.R. OF THE ASSESSEE HAS NOT OBJECTED FOR THE DISALLOWANCE. ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 10 9. AGGRIEVED BY THE ORDER OF THE A.O., THE ASSESSEE WENT ON APPEAL BEFORE THE CIT(A) AND THE LD. CIT(A) CONFIRMED THE ADDITION MADE BY THE A.O. STATING THAT NO EVIDENCE WAS PRODUCED BY T HE ASSESSEE TO SUPPORT THAT NO DEFECT WAS FOUND DURING THE ASSESSM ENT PROCEEDINGS AND NO EVIDENCE OR DETAILS WERE PRODUCED BY THE ASS ESSEE BEFORE THE CIT(A). THE LD. A.R. DID NOT MAKE ANY ARGUMENT ON THIS ISSUE DURING THE APPEAL. SINCE THE ADDITION IS AGREED AND NO EV IDENCE WAS PRODUCED BY THE LD. A.R. TO CONTROVERT THE FINDING GIVEN BY THE LD. CIT(A), WE UPHOLD THE ORDER OF THE LD. CIT(A) AND DISMISS THE ASSESSEES APPEAL ON THIS GROUND. 10. THE NEXT ISSUE IN THIS APPEAL IS ADDITION OF ` 8,48,200/- RELATING TO DIFFERENCE IN THE RECEIPTS ADMITTED BY THE ASSESSEE AND FORM 26AS. THE LD. CIT(A) HAS REMITTED THE MATTER BACK TO THE FILE OF THE A.O. FOR NECESSARY ENQUIRIES WITH THE TDS OFFICER AND TO DEC IDE THE ISSUE AFTER THE VERIFICATION. SINCE THIS ISSUE IS RELATED TO T HE RECONCILIATION OF THE TDS RECEIPTS, WE UPHOLD THE ORDER OF THE LD. CIT(A) AND REMIT THE MATTER BACK TO THE FILE OF THE A.O. TO MAKE NECESSA RY ENQUIRIES AND TO OBTAIN THE RECONCILIATION AND TO DECIDE THE ISSUE AFTER DUE VERIFICATION OF THE DETAILS. THE APPEAL OF THE ASSESSEE ON THIS GR OUND IS ALLOWED FOR STATISTICAL PURPOSES. ITA NO.350/VIZAG/2016 M/S. STC TRANSPORTS (PVT) LTD., VIJAYAWADA 11 11. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS PARTLY ALLOWED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT O N 8 TH NOV17. SD/- SD/- ( . ) ( . . ' ) (V. DURGA RAO) (D.S. SUNDER SINGH) /JUDICIAL MEMBER /ACCOUNTANT MEMBER # /VISAKHAPATNAM: ' /DATED : 8.11.2017 VG/SPS )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT SHRI D.L.V. SRIDHAR, D.NO.52-1/3 -2B, VETERINARY COLONY, VIJAYAWADA 2. / THE RESPONDENT THE DCIT, CIRCLE-2(1), VIJAYAWA DA 3. + / THE CIT, VIJAYAWADA 4. + ( ) / THE CIT (A), VIJAYAWADA 5. # . , . , # / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // SR. PRIVATE SECRETARY ITAT, VISAKHAPATNAM