W.S. Industries(India),Ltd., Visakhapatnam V. The ITO, Visakhapatnam

ITA 357/VIZ/2016

• Counselvise Citation: [2017] 126 COUNSELVISE.COM (IT) 6548 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 1 year(s) 3 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-11-2017
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2008-2009
• Appeal Filed On: 26-07-2016
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: V APPALA RAJU
• Keywords: Non-deduction of tax
• Section: 133A; 12A; 201(1); 11

Judgement Text

ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 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.357/VIZAG/2016 ( / ASSESSMENT YEAR: 2008-09) W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM ITO, WARD - 6(1) VISAKHAPATNAM [PAN NO. AAACW0572E ] ( ' / APPELLANT) ( ()' / RESPONDENT) / APPELLANT BY : SHRI G.V.N. HARI, AR / RESPONDENT BY : SHRI V. APPALA RAJU, DR / DATE OF HEARING : 31.10.2017 / 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 AGAI NST ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS)-2 {CIT(A)}, VI SAKHAPATNAM VIDE ITA NO.165/2013-14/CIT(A)-2/VSP/W-6(1)/2016-17 DATE D 2.6.2016 FOR THE ASSESSMENT YEAR 2007-08. ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 2 2. THE ASSESSEE IS A COMPANY ENGAGED IN THE BUSINES S OF MANUFACTURE OF ELECTRO PORCELAIN INSULATORS AND TUR NKEY PROJECTS. THE ASSESSEE WAS MAINLY DEDUCTING TDS ON SALARIES U/S 1 92B, CONTRACT WORKS U/S 194C, INTEREST PAYMENTS U/S 194A, PROFESS IONAL CHARGES U/S 194J, RENTAL PAYMENTS U/S 1941 OF THE I.T ACT, 1961 AND ALSO DEDUCTING TDS ON FOREIGN PAYMENTS U/S 195 OF THE I.T. ACT. A SURVEY OPERATION U/S 133A OF THE I.T. ACT, 1961 WAS CONDUCTED IN THE BUSINESS PREMISES OF THE ASSESSEE IN UNIT-II, A P SPECIAL ECONOMIC ZO NE, DUPPITURU VILLAGE, ACHUTAPURAM MANDAL, VISAKHAPATNAM ON 13-03-2013 TO VERIFY THE COMPLIANCE OF THE TAX DEDUCTION WITH THE PROVISIONS OF TDS. 2.1 DURING THE COURSE OF SURVEY PROCEEDINGS AND ALS O SUBSEQUENT VERIFICATION OF BOOKS OF ACCOUNTS, IT WAS FOUND/ NO TICED THAT THE ASSESSEE COMPANY HAD PAID RS. 4,80,08,850/- ON 16-0 5-2007 TOWARDS LEASE CHARGES WHICH WAS PAID IN THE FORM OF UPFRONT PAYMENT FOR THE LAND OF 47.77 ACRES RS. 10,05,000 /- PER ACRE FOR 35 YEARS LEASE PERIOD TO M/S ANDHRA PRADESH INDUSTR IAL INFRASTRUCTURE CORPORATION LIMITED (APIIC LTD) RELA TING TO THE FINANCIAL YEAR 2007-08 RELEVANT TO THE ASSESSMENT Y EAR 2008-09 WITHOUT DEDUCTION OF TAX AS REQUIRED TO BE DEDUCTIB LE @ 10% U/S 1941 OF THE I.T. ACT, 1961. THUS THE TOTAL SHORT DE DUCTION FOR THE FINANCIAL YEAR 2007-08 RELEVANT TO THE ASSESSMENT Y EAR 2008-09 ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 3 WORKS OUT TO RS. RS. 48,00,885/- FOR THE ONE TIME L EASE CHARGES PAID FOR 35 YEARS LEASE PERIOD. 2.2 ACCORDINGLY, A SHOW CAUSE NOTICE WAS ISSUED TO THE ASSESSEE BY THE A.O. ON 15-03-2013 INTIMATING THAT THE PAYME NT MADE TO M/S APIIC LTD, HYDERABAD FALLS WITHIN THE PURVIEW OF TH E SECTION 194I OF THE INCOME TAX ACT, 1961 (HEREINAFTER CALLED AS 'TH E ACT') AS THE ONE TIME PAYMENT MADE TOWARDS LEASE CHARGES IN THE FORM OF UPFRONT CHARGES TO M/S APIIC LTD, WAS RELATING TO THE USE O F LAND FOR 35 YEARS TAKEN ON LEASE BASIS FROM THE APIIC LTD, HYDE RABAD WHICH FALLS WITHIN THE PURVIEW OF THE SECTION 194I OF THE ACT. 2.3 IN RESPONSE TO THE SHOW CAUSE NOTICE ISSUED, TH E ASSESSEE APPEARED BEFORE THE A.O. ON 27-03-2013 AND FILED A LETTER INFORMING THAT THE RECIPIENT I.E. M/S APIIC LTD, HYDERABAD HA S ALREADY TAKEN INTO ACCOUNT THE LEASE CHARGES/UPFRONT CHARGES PAID BY THE COMPANY IN THEIR BOOKS OF ACCOUNTS PERTAINING TO THE FINANC IAL YEAR 2007-08 RELEVANT TO THE ASSESSMENT YEAR 2008-09 AND ALSO FI LED A CONFIRMATION LETTER ENCLOSING COPY OF THE INCOME-TAX RETURN FILE D FOR THE F.Y. 2007- 08 BY THE M/S APIIC LTD. AFTER VERIFICATION OF THE SAME, THE REQUEST OF THE ASSESSEE FOR NOT CHARGING THE PROVISIONS U/S 20 1(1) WAS CONSIDERED AS M/S. APIIC LTD. HAS TAKEN INTO ACCOUN T THE LEASE ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 4 CHARGES/UPFRONT CHARGES PAID BY THE ASSESSEE IN ITS BOOKS OF ACCOUNTS. HOWEVER, THE A.O. WAS OF THE OPINION THA T THE ASSESSEE IS LIABLE FOR PAYMENT OF INTEREST U/S 201(1A) OF THE A CT FROM THE DATE OF PAYMENT OF LEASE CHARGE TO M/S. APIIC LTD., HYDERAB AD TO THE DATE OF PAYMENT OF TAXES OR DATE OF FILING OF INCOME TAX RE TURN I.E. 30.9.2008 ON WHICH DATE M/S. APIIC LTD. FILED ITS RETURN OF I NCOME CLAIMING A REFUND DUE TO THEM. THEREFORE, THE A.O. CONCLUDED THAT THE ASSESSEE IS LIABLE TO PAY INTEREST U/S 201(1A) OF THE ACT FR OM THE DATE OF PAYMENT TO THE DATE OF FILING OF INCOME TAX RETURN AND ACCORDINGLY LEVIED THE INTEREST CHARGEABLE U/S 201(1A) OF THE A CT FOR THE ONE TIME LEASE CHARGES/UPFRONT CHARGES PAID TO M/S. APIIC LT D. WORKED OUT TO RS.8,16,150/- AS FOLLOWS: DATE /MONTH ! MONTH AMOUNT PAID TDS REQUIRES TO REQUIRES TO DELAY IN NO OF TOTAL INTEREST OF PAYMENT /CREDITED TOW ARDS TO BE MADE @10% MONTHS PAYABLE ANNUAL TEASE RENT U/S 1941 U/S 201(1A) CHARGES 1% P . M 16 - 05 - 2007 4,80,08,850 48,00,885 17 MONTHS (FROM 8,16,150/ - (FROM 16 - 05 - 2007 TO 30 - 09 - 2008) TOTAL 8,16,150/ - 3. AGGRIEVED BY THE ORDER OF THE A.O., THE ASSESSEE WENT ON APPEAL BEFORE THE CIT(A) AND THE CIT(A) UPHELD THE ORDER O F THE A.O. AND DISMISSED THE APPEAL OF THE ASSESSEE. ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 5 4. AGGRIEVED BY THE ORDER OF THE LD. CIT(A), THE AS SESSEE FILED AN APPEAL BEFORE THIS TRIBUNAL. THE LD. A.R. FOR THE ASSESSEE REITERATED THE SUBMISSION MADE BEFORE THE LD. CIT(A) THAT THE INCO ME OF THE PAYEE I.E. APIIC LIMITED IS EXEMPT FROM TAX U/S 11 OF THE ACT AS THEY ARE REGISTERED U/S 12A OF THE ACT. THE LD. A.R. FURTHE R CONTENDED THAT THE INTEREST CHARGEABLE U/S 201(1A) OF THE ACT IS COMPE NSATORY IN NATURE AND SINCE APIIC LIMITED IS NOT LIABLE TO PAY ANY TA X ON ITS INCOME BY VIRTUE OF THE EXEMPTION OF INCOME OF THE PAYEE U/S 11 OF THE ACT. THE LD. A.R. CONTENDED THAT THERE IS NO LOSS OF REVENUE TO THE EXCHEQUER AND CONSEQUENTLY THE ASSESSEE CANNOT BE CHARGED WIT H INTEREST U/S 201(1A) OF THE ACT. IN THIS REGARD, THE LD. A.R. P LACED RELIANCE IN THE CASE OF THOMAS MUTHOOT VS. DCIT (2012) 80 DTR (COCH ) (TRIB) 33 WHEREIN THE HONBLE COCHIN BENCH ACCEPTED THIS CONT ENTION AND REQUESTED TO ALLOW THE APPEAL OF THE ASSESSEE TO NO T LEVY INTEREST OF ` 8,16,150/- U/S 201(1A) FOR ALLEGED FAILURE OF THE A SSESSEE TO DEDUCT TAX AT SOURCE U/S 194I OF THE ACT FROM THE PAYMENT OF L EASE CHARGES TO M/S. APIIC LTD. 5. ON THE OTHER HAND, THE LD. D.R. SUPPORTED THE OR DER OF THE LD. CIT(A). ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 6 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 ISSUE IN THIS CASE IS LEVY OF INTEREST U/S 201(1A) OF THE ACT IN CASE OF ASSESSEE FAILING TO DEDUCT TAX AT SOURCE U/S 194I O F THE ACT WHEN THERE IS NO TAX LIABILITY IN THE HANDS OF THE PAYEE AND T HE ASSESSEE IS NOT DEEMED TO BE ASSESSEE IN DEFAULT UNDER THE FIRST PR OVISO TO SECTION 201(1) OF THE ACT. THIS ISSUE HAS BEEN CONSIDERED BY THIS TRIBUNAL ON THE SIMILAR FACTS IN THE CASE OF AAYUSH NRI LEPL HE ALTH CARE PVT. LTD., VIJAYAWADA VS. ACIT, CIRCLE-3(1), VIJAYAWADA IN ITA NOS.10 & 11/VIZAG/2016 DATED 18.10.2017 AND HELD THAT THE IN TEREST IS NOT COMPENSATORY IN NATURE AND THE INTEREST U/S 201(1A) OF THE ACT IS LEVIABLE EVEN WHEN DEDUCTEE HAS NO TAX LIABILITY. FOR READY REFERENCE, WE EXTRACT THE RELEVANT PARAGRAPHS OF THE ORDER OF THIS TRIBUNAL, WHICH READS AS UNDER: 6. WE HAVE HEARD BOTH THE PARTIES, PERUSED THE MATE RIALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHORITI ES BELOW. THE ASSESSEE REQUIRED TO DEDUCT TAX AT SOURCE ON PAYMEN TS MADE TO THE DOLPHIN IMAGING SERVICES ON THE AMOUNTS OF ` 88,43,1 93/- FOR THE FINANCIAL YEAR 2012-13 AND ` 87,04,620/- FOR THE FI NANCIAL YEAR 2013-14. THE ASSESSEE HAS NOT DEDUCTED THE TAX AT SOURCE AND DID NOT REMIT TO THE GOVERNMENT ACCOUNT. THERE IS NO DISPUTE WITH REGAR D TO THE DEDUCTIBILITY OF TAX AT SOURCE. THE LD. CIT(A) HAS DECIDED IN A PPEAL THAT THE ASSESSEE REQUIRED TO DEDUCT TAX AT SOURCE ON THE PAYMENTS MA DE U/S 194J OF THE ACT ,WHICH IS NOT DISPUTED BY THE ASSESSEE. THE AS SESSEES ARGUMENT WAS THE DEDUCTEE HAS ALREADY FILED THE RETURN OF INCOME AND THE TAX LIABILITY IN THE HANDS OF THE DEDUCTEE WAS NIL, AND NOT LIABLE T O PAYMENT OF ANY TAX, THUS NO LOSS OF REVENUE AND HENCE, THE INTEREST U/S 201(1A) OF THE ACT DOES NOT ATTRACT IN THE ASSESSEES CASE. THE LD. A. R FURTHER ARGUED THAT THE INTEREST U/S 201 & 201(1A) OF THE ACT IS COMPEN SATORY IN NATURE. SINCE THE DEDUCTEES INCOME WAS BELOW TAXABLE LIMIT AND NEED NOT PAY ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 7 ANY ADVANCE TAX, THE LD. A.R. CONTENDED THAT THERE IS NO LOSS TO REVENUE AND INTEREST NEED NOT BE CHARGED U/S 201(1A) OF THE ACT. THE LD. A.R. TAKEN THE SUPPORT OF THE DECISION OF ITAT COCHIN BE NCH IN THE CASE OF THOMAS MUTHOOT VS. DCIT (SUPRA) AND THE DECISION OF SAHARA INDIA COMMERCIAL CORPORATION LIMITED REPORTED IN (2015) 1 69 TTJ 0292 LUCKNOW BENCH. THE LD. A.R. FURTHER ARGUED THAT TH E DECISION OF ITAT LUCKNOW BENCH WAS CONFIRMED BY THE HONBLE HIGH COU RT OF ALLAHABAD. THE LD. A.R. ALSO TAKEN THE SUPPORT OF THE DECISION OF THIS TRIBUNAL IN THE CASE OF MANNE RAJESH KUMAR IN ITA NO.40/VIZAG/2017 DATED 6.9.2017 AND ARGUED THAT WHEN THE DEDUCTEE HAS NO TAXABLE INCOME , THE INTEREST U/S 201(1A) OF THE ACT IS NOT EXIGIBLE, ACCORDINGLY, RE QUESTED TO ALLOW THE APPEAL OF THE ASSESSEE. WE HAVE GONE THROUGH THE D ECISIONS RELIED UPON BY THE LD. A.R. THE DECISION OF THIS TRIBUNAL IN T HE CASE OF MANNE RAJESH KUMAR (SUPRA) IS RENDERED FOLLOWING THE CIRCULAR NO .2 OF 2014 OF CBDT, WHEREIN THE CBDT HAS ISSUED A SPECIFIC CIRCULAR NOT TO TREAT THE ASSESSEE IN DEFAULT IN THE CASE OF NON-RESIDENT U/S 195 OF T HE ACT. IN THE CIRCULAR, THE BENEFIT WAS NOT EXTENDED TO THE RESIDENT. THER EFORE, THE DECISION OF THIS TRIBUNAL IN THE CASE OF MANNE RAJESH KUMAR (SU PRA) IS NOT APPLICABLE IN THE ASSESSEES CASE. THE DECISION OF ITAT COCHI N BENCH WAS RENDERED IN RELATION TO THE ASSESSMENT YEARS 2007-08, 2006-0 7 & 2005-06 AND THE DECISION OF ITAT COCHIN BENCH WAS RENDERED FOR THE ASSESSMENT YEARS 2003-04 TO 2006-07. THE INCOME TAX ACT HAS BEEN AME NDED BY INSERTING PROVISO TO SECTION 201(1A) OF THE ACT, BY THE FINAN CE ACT, 2012, W.E.F. 1- 7-2012. WHICH READS AS UNDER: [(1A) WITHOUT PREJUDICE TO THE PROVISIONS OF SUB-SE CTION (1), IF ANY SUCH PERSON, PRINCIPAL OFFICER OR COMPANY AS IS REFERRED TO IN THAT SUB-SECTION DOES NOT DEDUCT THE WHOLE OR ANY PART O F THE TAX OR AFTER DEDUCTING FAILS TO PAY THE TAX AS REQUIRED BY OR UN DER THIS ACT, HE OR IT SHALL BE LIABLE TO PAY SIMPLE INTEREST,-- (I) AT ONE PERCENT FOR EVERY MONTH OR PART OF A MONTH O N THE AMOUNT OF SUCH TAX FROM THE DATE ON WHICH SUCH TAX WAS DED UCTIBLE TO THE DATE ON WHICH SUCH TAX IS DEDUCTED; AND (II) AT ONE AND ONE-HALF PER CENT FOR EVERY MONTH OR PAR T OF A MONTH ON THE AMOUNT OF SUCH TAX FROM THE DATE ON WHICH SU CH TAX WAS DEDUCTED TO THE DATE ON WHICH SUCH TAX IS ACTUALLY PAID, AND SUCH INTEREST SHALL BE PAID BEFORE FURNISHING T HE STATEMENT IN ACCORDANCE WITH THE PROVISIONS OF SUB-SECTION (3) O F SECTION 200:] [ PROVIDED THAT IN CASE ANY PERSON, INCLUDING THE PRINCIPAL O FFICER OF A COMPANY FAILS TO DEDUCT THE WHOLE OR ANY PART OF TH E TAX IN ACCORDANCE WITH THE PROVISIONS OF THIS CHAPTER ON THE SUM PAID TO A RESIDENT OR ON THE SUM CREDITED TO THE ACCOUNT OF A RESIDENT BUT I S NOT DEEMED TO BE AN ASSESSEE IN DEFAULT UNDER THE FIRST PROVISO TO S UB-SECTION (1), THE INTEREST UNDER CLAUSE (I) SHALL BE PAYABLE FROM THE DATE ON WHICH SUCH TAX WAS DEDUCTIBLE TO THE DATE OF FURNISHING OF RET URN OF INCOME BY SUCH RESIDENT.] ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 8 7. THE PLAIN READING OF THE PROVISO TO SECTION 201( 1A) OF THE ACT MAKES IT VERY CLEAR THAT EVEN THOUGH THE ASSESSEE I S NOT DEEMED TO BE ASSESSEE IN DEFAULT UNDER FIRST PROVISO TO SUB SECT ION (1), THE INTEREST UNDER CLAUSE (I) SHALL BE PAYABLE FROM THE DATE ON WHICH SUCH TAX IS DEDUCTIBLE TO THE DATE OF FURNISHING OF RETURN OF I NCOME BY SUCH A RESIDENT. THEREFORE, THE TAX LIABILITY IN THE HAND S OF THE DEDUCTEE HAS NO RELATION OR CONNECTION FOR CHARGING THE INTEREST U/ S 201(1A) OF THE ACT. MERE NON-DEDUCTION OF TAX AT SOURCE AND NON-REMITTA NCE TO GOVERNMENT OF INDIA ACCOUNT ATTRACTS THE INTEREST U/S 201(1A) O F THE ACT AND THAT IS THE REASON FOR WHICH THE PROVISION HAS BEEN INSERTE D TO CHARGE INTEREST FROM THE DATE OF THE TAX DEDUCTIBLE TO THE DATE OF FURNISHING OF RETURN OF INCOME BY THE RESIDENT. SINCE THE DECISIONS RELIED UPON BY THE LD. A.R. ARE RELATED PRIOR TO INSERTION OF THE PROVISO U/S 2 01(1A) OF THE ACT, THE DECISIONS RELIED UPON BY THE ASSESSE ARE NOT APPLIC ABLE IN ASSESSEES CASE. THE DECISION OF KOLKATA HIGH COURT IN THE CASE OF K ANOI PROPERTIES PVT. LTD. VS. CIT 261 ITR 488 WHICH WAS FOLLOWED BY THE LD.CIT(A) SQUARELY APPLICABLE EVEN AFTER INSERTION OF PROVISO. AFTER INSERTION OF THE PROVISION, THE CHARGING OF INTEREST FROM THE DATE OF THE TAX R EQUIRED TO BE DEDUCTED TILL THE DATE OF FURNISHING OF RETURN OF INCOME BY THE DEDUCTEE IS AUTOMATIC AND MANDATORY. FURTHER THE HONBLE MADRAS HIGH COU RT IN THE CASE OF CIT VS. CHENNAI PROPERTIES & INVESTMENTS LTD. (1999) 10 5 TAXMAN 346 EXPRESSED VIEW THAT THE INTEREST PAID U/S 201(1A) O F THE ACT IS NOT COMPENSATORY BUT PENAL IN NATURE. THEREFORE, WE HO LD THAT THE INTEREST IS CHARGEABLE FROM THE DATE OF SUCH TAX IS DEDUCTIBLE TO THE DATE OF FURNISHING OF RETURN OF INCOME AND WE UPHOLD THE OR DER OF THE LD. CIT(A) AND DISMISS THE APPEALS OF THE ASSESSEE. 8. IN THE RESULT, THE APPEALS FILED BY THE ASSESSEE FOR THE A.YS 2013- 14 AND 2014-15 ARE DISMISSED. 7. SINCE THE FACTS OF THE ASSESSEES CASE ARE SIMIL AR TO THE FACTS OF THE ABOVE CITED CASE, THIS CASE IS SQUARELY COVERED BY THE ORDER OF THIS TRIBUNAL CITED (SUPRA) AGAINST THE ASSESSEE. THERE FORE, WE UPHOLD THE ORDER OF THE LD. CIT(A) AND DISMISS THE APPEAL OF T HE ASSESSEE. 8. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS DISMISSED. THE ABOVE ORDER IS PRONOUNCED IN THE OPEN CO URT ON 8 TH NOV17. SD/- SD/- ( . ) ( . . ' ) (V. DURGA RAO) (D.S. SUNDER SINGH) /JUDICIAL MEMBER /ACCOUNTANT MEMBER ITA NO.357/VIZAG/2016 W.S. INDUSTRIES (INDIA) LTD., VISAKHAPATNAM 9 # /VISAKHAPATNAM ' /DATED : 08.11.2017 VG/SPS )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT W.S. INDUSTRIES (INDIA) LTD., SPEC IAL ECONOMIC ZONE, DUPPITUR VILLAGE, ATCHUTAPURAM, VISAKHAPATNAM 2. / THE RESPONDENT THE ITO, WARD-6(1), VISAKHAPATN AM 3. + / THE CIT(TDS), VIJAYAWADA 4. + ( ) / THE CIT (A)-2, VISAKHAPATNAM 5. # . , . , # / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // SR. PRIVATE SECRETARY ITAT, VISAKHAPATNAM