Dy.CIT, Circle-3(3), Hyderabad V. M/s. Zen Securities Ltd., Hyderabad

ITA 353/HYD/2014

• Counselvise Citation: [2016] 121 COUNSELVISE.COM (IT) 3075 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 11 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 19-02-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 10-02-2016
• Assessment Year: 2007-2008
• Appeal Filed On: 03-03-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: K MYTHILI RANI
• Assessee Lawyers: V RAGHAVENDRA RAO
• Keywords: Business income; Rule of consistency; Bad and doubtful debts
• Section: 14A

Judgement Text

GIN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B', HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER ITA NOS. 353 & 354/HYD/2014 ASSESSMENT YEARS: 2007-08 & 2008-09 DY. COMMISSIONER OF INCOME-TAX, CIRCLE 3(3), HYDERABAD VS. M/S ZEN SECURITIES LTD., HYDERABAD PAN AAACZ0682Q APPELLANT RESPONDENT REVENUE BY: SMT. K. MYTHILI RANI ASSESSEE BY: SHRI V. RAGHAVENDRA RAO DATE OF HEARING: 10/02/2016 DATE OF PRONOUNCEMENT: /02/2016 O R D E R PER B. RAMAKOTAIAH, AM: BOTH THESE APPEALS ARE PREFERRED BY REVENUE AGAIN ST A COMMON ORDER OF LD. CIT(A) - IV, HYDERABAD, DATED 20/12/2013 FOR THE AYS. 2007-08 AND 2009-10. 2. BRIEFLY THE FACTS OF THE CASE ARE THAT ASSESSEE IS ENGAGED IN THE BUSINESS OF STOCK AND SHARE BROKING, PORTFOLIO MANAGEMENT SERVICES AND PROVISION OF DEPOSITORY SER VICES. THE AO COMPLETED THE ASSESSMENT BY MAKING THE FOLLO WING ADDITIONS/DISALLOWANCES: SL.NO. PARTICULARS 2007-08 2008-09 1. INCOME FROM STCG TREATED AS BUSINESS INCOME 77,50,201 2,31,93,041 2. DISALLOWANCE U/S 14A 1,50,000 3,00,000 3. DONATION DISALLOWED 50,000 - 4. BAD DEBTS WRITTEN OFF - 58,84,364 I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 2 2.1 ASSESSEES MAIN BUSINESS WAS STOCK AND SHARE BR OKING, DEPOSITORY SERVICES AND PORTFOLIO MANAGEMENT SERVIC ES. ASSESSEE OFFERED INCOMES FROM TRADING, BROKERAGE, P ORTFOLIO SERVICES, CAPITAL GAINS ETC. ASSESSING OFFICER FOR THE REASONS THAT THE SALE OF SHARES ON WHICH SHORT TERM CAPITAL GAINS WAS DECLARED HAS FULFILLED THE NORMS OF TRADING, TREATE D THE SAME AS BUSINESS INCOME. FOR AY 2007-08, ASSESSEE HAD MA DE PURCHASES OF RS. 3,01,22,474/ AND SALES OF RS. 3,78 ,76,903/- IN RESPECT OF SHARES ON WHICH SHORT TERM CAPITAL GA INS WAS DECLARED. THERE WERE 496 TRANSACTIONS OF PURCHASES AND 502 OF SALES AND THE TOTAL NUMBER OF SHARES SOLD WAS 1, 96,1225. FOR AY 2008-09, ASSESSEE HAD MADE PURCHASES OF RS. 12,02,28,184/- AND SALES OF RS. 14,34,21,225/ IN RE SPECT OF SHARES ON WHICH SHORT TERM CAPITAL GAINS WAS DECLAR ED. THE AO NOTED THAT SINCE THE HOLDING PERIOD OF THE SHARE S WAS VERY SMALL, THE MOTIVE COULD NOT BE SAID TO BE EARNING O F DIVIDEND. IT WAS CONSIDERED THAT ASSESSEE RECEIVED DIVIDEND O N MERELY 7250 SHARES OUT OF THE TOTAL SHARES TRADED OF 1,96, 125 FOR AY 2007-08 AND ON 66200 SHARES OUT OF THE TOTAL SHARES TRADED OF RS. 5,61,100 FOR AY 2008-09. THE AO, THEREFORE, HEL D THE SHARES ON THE SALE OF WHICH SHORT TERM CAPITAL GAIN HAD BEEN CLAIMED WAS HELD BY ASSESSEE AS STOCK IN TRADE AND NOT AS INVESTMENT AND CONSEQUENTLY, THE SHORT TERM CAPITAL GAINS RETURNED BY ASSESSEE WAS ASSESSED AS BUSINESS INCOM E. AO ALSO DISALLOWED THE BAD DEBT CLAIM IN AY 2008-09. O THER ISSUES ARE NOT SUBJECT MATTER OF PRESENT APPEALS. I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 3 3. AGGRIEVED, ASSESSEE PREFERRED APPEAL BEFORE THE CIT(A). 4. BEFORE THE CIT(A), THE AR OF ASSESSEE SUBMITTED THAT SURPLUS FUNDS WERE DEPLOYED FOR INVESTMENTS AND THA T SOME OF THE INVESTMENTS MAY HAVE BEEN LIQUIDATED WITHIN THE SAME FY FOR THE FOLLOWING REASONS: A. IF THE DIVIDEND YIELD FELL BELOW THE EXPECTATION S OR INVESTMENTS GOAL WERE REACHED EARLIER THAN ANTICIPA TED. B. IF THERE WAS A CHANGE IN THE ASSUMPTIONS BASED O N WHICH INVESTMENTS DECISION WAS ORIGINALLY MADE. C. IF THERE WAS AN URGENT REQUIREMENT OF FUNDS FOR WHICH IT WAS NECESSARY TO LIQUIDATE THE INVESTMENT. IT WAS ALSO SUBMITTED THAT ASSESSEE MAINTAINED SEPA RATE D- MAT ACCOUNTS AND TRANSACTIONS ARE SHOWN IN INVESTME NT ACCOUNTS ONLY AND WAS ACCEPTED IN EARLIER YEARS AS SUCH. THE AR RELIED UPON VARIOUS DECISIONS IN SUPPORT OF ASSE SSEES CLAIM, WHICH WERE MENTIONED BY THE CIT(A) IN HIS OR DER AT PAGE 7 & 8. 5. THE CIT(A) AFTER EXAMINING THE ISSUE ELABORATELY WITH BOARD CIRCULARS, JUDGEMENTS OF HONBLE SUPREME COUR T AND HONBLE AP HIGH COURT FOR BOTH THE YEARS UNDER CONS IDERATION, HELD THAT THE GAINS ON SHARES CATEGORIZED AS INVEST MENT IN ASSESSEES BOOKS WAS ASSESSABLE AS CAPITAL GAINS AN D NOT AS PROFITS FROM BUSINESS. AFTER DETAILED ANALYSIS LD. CIT(A) SUMMARISED THE REASONS AS UNDER: A. THE SHARES WERE CLASSIFIED AS INVESTMENT IN THE BOOKS OF ACCOUNT. B. THE TRANSACTIONS WERE DELIVERY BASED, EXCEPT FOR TWO TRANSACTIONS FOR EACH OF THE TWO YEARS FOR WHICH ASSESSEE HAS FURNISHED A REASONABLE EXPLANATION. C. ASSESSEE HAD NOT USED BORROWED FUNDS FOR THE PURPOSE OF INVESTMENT. I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 4 D. THE FREQUENCY OF BUYING AND SELLING OF SHARES WA S NOT HIGH RELATIVE TO THE INVESTMENT MADE IN IT. E. THE HIGH TURNOVER WAS ON ACCOUNT OF HUGE INVESTM ENT AND NOT BECAUSE OF FREQUENCY OF TRANSACTIONS. F. THERE WAS AN ABSENCE OF REPEATED TRANSACTIONS AN D RE-ENTRY IN THE SAME SCRIPS. 6. AGGRIEVED BY THE ORDER OF CIT(A) THE REVENUE IS IN APPEAL BEFORE US FOR THE AYS 2007-08 AND 2008-09 AG AINST THE ACTION OF THE CIT(A) IN TREATING THE GAINS ON SHARE S AS CAPITAL GAINS AS AGAINST THE PROFITS FROM BUSINESS CONSIDER ED BY THE AO. IN AY 2008-09, THERE IS ANOTHER GROUND PERTAINI NG TO THE CLAIM OF BAD DEBTS. 7. THE LD. DR BESIDES RELYING UPON THE ORDER OF THE AO SUBMITTED THAT THE LD. CIT(A) OUGHT TO HAVE ANALYSE D THE FREQUENCY, MAGNITUDE AND VOLUME OF TRANSACTIONS AND DRAWN INFERENCE FROM THE DECISIONS OF HONBLE SUPREME COU RT IN THE CASE OF RAJA BAHADUR VISHESWARA SINGH 41 ITR 685 (S C) AND AS ALSO THE HONBLE HIGH COURT OF A.P. IN THE CASE OF P.V.S. RAJU & RAJYALAKSHMI VS. ADDL. CIT 340 ITR 75 WHEREI N THE COURT AFTER CONSIDERING THE FACTS OF THE CASE, HAS HELD THAT SALE OF SHARES WOULD CONSTITUTE BUSINESS INCOME. 8. THE LD. AR SUBMITTED THAT THE LD. CIT(A) HAS MAD E COGENT AND OBJECTIVE ANALYSIS OF THE FACTORS INVOLV ED AND HAS COME TO THE CORRECT CONCLUSION THAT THE GAINS ON SH ARES AS CAPITAL GAINS. HE FURTHER SUBMITTED THAT ASSESSEE H AS SUBSTANTIAL DIVIDEND INCOME OVER THE YEARS. ASSESSE E WAS ADMITTING SHORT TERM CAPITAL GAINS FROM THE INVESTM ENT MADE EVEN BEFORE SECTION 111A WAS INSERTED W.E.F. 2005-0 6 WHEN SHORT TERM CAPITAL GAINS WAS TAXED AT THE SPECIAL R ATE OF 10%, WHICH WAS LATER INCREASED TO 15% W.E.F. 01/04/2009. THIS I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 5 WOULD SHOW THAT ASSESSEE WAS MAKING INVESTMENTS WIT H OBJECTIVE OF EARNING DIVIDEND INCOME AND THAT THE S HORT TERM CAPITAL GAINS WAS BEING EARNED EVEN WHEN NORMAL TAX RATE WAS CHARGED AND SHOWN AS SUCH IN ACCOUNTS AND INCOME TA X RETURNS. THE INTENTION AND OBJECTIVE OF ASSESSEE WO ULD BE CLEAR FROM THIS CONDUCT WHEN THE INCOME FROM SALE O F SHARES WAS BEING CATEGORIZED & OFFERED FOR ASSESSMENT UNDE R THE HEAD CAPITAL GAINS AND NOT UNDER THE HEAD BUSINESS. S.NO. AY DIVIDEND INCOME SHORT TERM CAPITAL GAIN 1 2006-07 8,55,955 1,59,31,362 2 2005-06 10,84,158 1,78,83,305 (STT) 3 2004-05 1,49,71,404 - 4 2003-04 8,49,869 2,08,139 5 2002-03 23,61,011 5,68,190 6 2001-02 73,98,933 (63,580) 7 2000-01 10,15,948 18,85,882 8 1999-00 3,82,462 2,08,682 9 1998-99 3,33,004 23,863 10 1997-98 3,08,946 - REFERRING TO THE ABOVE TABLE, THE LD. AR SUBMITTED THAT ASSESSEE WAS HAVING SHORT TERM CAPITAL GAINS RIGHT FROM THE EARLY EXISTENCE OF THE COMPANY AND REGULAR SUBSTANT IAL DIVIDENDS COULD ALSO SHOW THE OBJECTIVE OF ASSESSEE IS EARNING THE DIVIDEND INCOME. IT WAS ALSO SUBMITTED THAT AO DID NOT DISTURB THE TREATMENT GIVEN TO SALE OF SHARES IN IN VESTMENT ACCOUNT AS LONG TERM CAPITAL GAINS, BUT ONLY ON WHI CH SHORT TERM CAPITAL GAIN WAS OFFERED. THE LD. AR PLACED SU BMISSIONS UNDER THE RULE 27 OF ITAT RULES, 1963, STATING THAT THE CIT(A) IS NOT CORRECT OR JUSTIFIED IN REJECTING THE CONTEN TION THAT THE PRINCIPLE OF CONSISTENCY APPLIES TO THE FACTS OF TH E CASE. 9. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AND PER USED THE ORDERS OF REVENUE AUTHORITIES AS WELL AS OTHER MATERIAL ON RECORD. IT IS OBSERVED THAT ASSESSEE IS CLEARLY AN INVESTOR IN I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 6 RESPECT OF THE SHARES CATEGORIZED AS INVESTMENTS EV EN AT THE TIME OF PURCHASE AND THAT THEY WERE ONLY TREATED AS SUCH IN THE BOOKS. THE FACT REMAINS THAT FOR OVER 10 YEARS THE ASSESSMENTS WERE COMPLETED AFTER SCRUTINY WITHOUT A NY DOUBT OR DISTURBING THE NATURE OF INCOME FROM SHORT TERM CAPITAL GAINS. THE HON'BLE JURISDICTIONAL HIGH COURT HAD CO NSIDERED THE PRINCIPLE OF CONSISTENCY AS AGAINST THE PRINCIP LE RES JUDICATA. THE HON'BLE HIGH COURT HAS ALSO TAKEN SUP PORT OF THE CASES IN ESCORTS LIMITED (2011 338 ITR 435 [DELHI], ) DANOS PANDOLE IN (2011) 330 ITR 485 (BOM.) AND GOPAL PURO HIT (2011 336 ITR 287 [BOM.] ). THE DECISION OF THE HON 'BLE A.P HIGH COURT IN THE CASE OF SPECTRA SHARES PRIVATE LI MITED VS. CIT IS SQUARELY APPLICABLE TO THE FACTS OF THE CASE . IN THAT CASE THE HON'BLE HIGH COURT DISTINGUISHED THE DECISIONS OF THE SAME COURT IN THE CASE OF P.V.S. RAJU & P. RAJUALAK SHMI 340 ITR 75 (A.P) ON WHICH THE REVENUE IS RELYING IN ITS GROUNDS OF APPEAL. THE DISTINCTION MADE BY THE HON'BLE HIGH CO URT APPLIES TO THE FACTS OF ASSESSEE'S CASE. THE HONBL E HIGH COURT HAS ALSO CONSIDERED THE DECISION OF SUPREME C OURT IN THE CASE RAJ BAHADUR VISHWESHWARA SINGH (1961 41 IT R 685 (SC) AS REGARDS THE PRINCIPLE OF CONSISTENCY. THER EFORE, TAKING INTO CONSIDERATION THE TOTAL EFFECT OF THE P RINCIPLES, AS ADVISED BY THE BOARD, IT WOULD BE CLEAR THAT THE SH ORT TERM CAPITAL GAINS IS NOT ON ACCOUNT OF BUSINESS ACTIVIT Y. IT IS BUT SIMILAR TO THE ACTIVITY IN LONG TERM CAPITAL GAINS. AS NOTED EARLIER, AO HAS ACCEPTED THE LONG TERM CAPITAL GAIN S ON SIMILAR TRANSACTIONS IN INVESTMENT ACCOUNT. MORE OVER ASSE SSEE HAS SUBSTANTIAL TRADING INCOME WHICH WAS DEALT SEPARATE LY IN BOOKS OF ACCOUNTS. THEREFORE, WE DO NOT FIND ANY I NFIRMITY IN THE ORDER OF THE CIT(A) IN TREATING THE GAINS ON SH ARES AS CAPITAL GAINS AS AGAINST THE PROFITS FROM BUSINESS BY THE AO. ACCORDINGLY, THE GROUNDS RAISED BY THE REVENUE ON T HIS ISSUE IN BOTH THE YEARS UNDER CONSIDERATION ARE DISMISSED . I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 7 10. AS REGARDS THE SECOND ISSUE PERTAINING TO THE C LAIM OF BAD DEBTS OF RS. 58,84,364 WRITTEN OFF BY ASSESSEE IN AY 2008-09. ASSESSEE HAD CLAIMED THAT THERE WAS A FRAU D AT ONE OF ITS BRANCHES BY ITS EMPLOYEES TO THE EXTENT OF R S. 1,05,74,635/- OF WHICH A SUM OF RS. 46,90,271 WAS R ECOVERED AND THE BALANCE SUM OF RS. 58,84,364 WAS CLAIMED AS A BAD DEBT. ASSESSEE SUBMITTED THAT IT DID NOT FILE A COM PLAINT WITH THE POLICE FOR THE FOLLOWING REASONS: A. THE BUSINESS OF THE COMPANY WAS SENSITIVE IN NA TURE AND ITS REPUTATION WAS OF PARAMOUNT COMMERCIAL IMPORTANCE. B. THE EMPLOYEES CONCERNED HAD LEFT A SUICIDE NOTE DUE TO WHICH THE FOCUSED ON RECOVERY OF THE AMOUNTS IN STEAD OF TAKING ACTION AGAINST THE PERSONS CONCERNED. ASSESSEE ALSO SUBMITTED THAT DUE TO ITS EFFORTS, IT HAD RECOVERED A SUM OF RS,46,90,271 FROM THE PERPETRATO RS WHO HAD ALSO SUBMITTED CONFESSION LETTERS. 11. THE ASSESSING OFFICER DID NOT ACCEPT ASSESSEE S PLEA. HE HELD THAT FOR A CLAIM OF BAD DEBT TO BE ALLOWED, IT SHOULD BE WRITTEN OFF IN THE BOOKS OF ACCOUNT AND THAT ASSESS EE HAD ADMITTED IN ITS LETTER DATED 26.10.2010 THAT A SUM OF RS.58,84,364 WAS OUTSTANDING IN ONE OF ITS BRANCHES . THE ASSESSING OFFICER ALSO FOUND FAULT WITH THE LETTERS WRITTEN BY THE PERPETRATORS OF THE FRAUD. HE ALSO NOTED THAT A LL THE EMPLOYEES HAD SOUGHT TIME TO REPAY THE AMOUNT AND T HAT THERE WAS NO FORMAL COMPLAINT TO THE POLICE. IN VIEW OF T HE ABOVE OBSERVATIONS, HE DISALLOWED THE BAD DEBTS CLAIM OF ASSESSEE. I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 8 12. IN THE COURSE OF THE APPELLATE PROCEEDINGS BEF ORE THE LD. CIT(A), THE AR HAS SUBMITTED THAT THE AMOUNTS D UE HAD BEEN ACTUALLY WRITTEN OFF IN BOOKS OF ACCOUNT AS CO ULD BE SEEN FROM THE COPIES OF ACCOUNT OF THE CLIENTS FILED DUR ING THE ASSESSMENT PROCEEDINGS. 13. AFTER CONSIDERING THE SUBMISSIONS OF ASSESSEE, THE CIT(A) ALLOWED ASSESSEES CLAIM BY HOLDING THAT ASS ESSEE HAS FULFILLED THE CONDITION LAID DOWN IN SECTION 36(1)( VII). AGGRIEVED, THE REVENUE IS IN APPEAL BEFORE US. 14. THE LEARNED DEPARTMENTAL REPRESENTATIVE RELIED ON THE ORDER OF ASSESSING OFFICER WHILE THE LD. AR BESIDES RELYING ON THE ORDER OF CIT(A) RELIED ON THE FEW JUDGMENTS INC LUDING THE JUDGMENT OF THE HONBLE SUPREME COURT IN THE CASE OF TRF LTD., 323 ITR 397. 15. WE HAVE CONSIDERED THE SUBMISSIONS OF THE PARTI ES. THE ISSUE IS COVERED BY THE DECISION OF THE HONBLE SUP REME COURT IN THE CASE OF TRF LTD. V. CIT, [2010] 323 ITR 397 (SC) WHEREIN THE APEX COURT HELD AS UNDER:- AFTER THE AMENDMENT OF SECTION 36(1)(VII) OF THE INCOME-TAX ACT, 1961, WITH EFFECT FROM APRIL 1, 19 89, IN ORDER TO OBTAIN A DEDUCTION IN RELATION TO BAD DEBT S, IT IS NOT NECESSARY FOR ASSESSEE TO ESTABLISH THAT THE DE BT, IN FACT, HAS BECOME IRRECOVERABLE, IT IS ENOUGH IF THE BAD DEBT IS WRITTEN OFF AS IRRECOVERABLE IN THE ACCOUNT S OF ASSESSEE. IN VIEW OF THE ABOVE JUDGMENT, IT IS SETTLED LAW TH AT ONCE THE BAD DEBT IS WRITTEN OFF AS IRRECOVERABLE IN THE BOO KS OF ASSESSEE, THE CLAIM OF BAD DEBT CANNOT BE DISALLOWE D. MOREOVER AS HELD BY THE HONOURABLE BOMBAY HIGH COUR T IN THE CASE OF SHREYAS S MORAKHIA 342 ITR 285 AND BY HONOU RABLE DELHI HIGH COURT IN THE CASE OF BONANZA PORTFOLIO LTD 320 ITR 178, AS ASSESSEE OFFERED BROKERAGE INCOME WHICH WAS TAKEN INTO ACCOUNT IN THE BOOKS, THE PRINCIPLE AMOUNT HAS TO BE I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 9 CONSIDERED AS FULL AMOUNT OF DEBT FOR CLAIM OF DEDU CTION. EVEN IF A FRAUD WAS COMMITTED ON THAT ACCOUNT THE SAME I S ALLOWABLE AS BAD DEBT. WE, THEREFORE, UPHOLD THE OR DER OF THE CIT(A) IN ALLOWING ASSESSEES CLAIM OF BAD DEBTS. A CCORDINGLY, THE REVENUES GROUND IS DISMISSED. 16. IN THE RESULT, BOTH THE APPEALS OF REVENUE ARE DISMISSED. PRONOUNCED IN THE OPEN COURT ON 19 TH FEBRUARY, 2016 SD/- (P. MADHAVI DEVI) JUDICIAL MEMBER SD/- (B. RAMAKOTAIAH) ACCOUNTANT MEMBER HYDERABAD, DATED 19 TH FEBRUARY, 2016 KV COPY FORWARDED TO: 1. DCIT, CIRCLE 3(3), 7 TH FLOOR, B BLOCK, IT TOWERS, AC GUARDS, HYDERABAD. 2. M/S ZEN SECURITIES LTD., 101, VIJAYASREE APARTME NTS, NAGARJUNA COLONY, AMEERPET, HYDERABAD. 3. CIT -IV, HYDERABAD 4 CIT - III, HYDERABAD 5 THE DR, ITAT, HYDERABAD 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 I.T.A. NOS. 353 & 354/HYD/2014 M/S ZEN SECURITIES LTD., HYD. 10