Y.S. Rajesh Reddy, Hyd, Hyderabad V. DCIT, Central Circle-1(1), Hyd, Hyderabad

ITA 366/HYD/2015

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 2576 (ITAT-HYDERABAD)
• Duration Of Justice: 2 year(s) 5 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 22-09-2017
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Next Hearing Date: 26-07-2017
• Assessment Year: 2008-2009
• Appeal Filed On: 07-04-2015
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: N SWAPNA
• Keywords: Unexplained investment; Assessment record
• Section: 142(1); 133A; 2

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SHRI D. MANMOHAN, VICE PRESIDENT AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA NO. 366/HYD/2015 ASSESSMENT YEAR: 2008-09 Y.S. RAJESH REDDY, HYDERABAD. PAN AAAPY 7292G VS. DY. COMMISSIONER OF INCOME- TAX, CIRCLE 1(1), HYDERABAD. (APPELLANT) (RESPONDENT) ASSESSEE BY : SHRI A. SRINIVAS REVENUE BY : SMT. N. SWAPNA DATE OF HEARING : 07-08-2017 DATE OF PRONOUNCEMENT : 22-09-2017 O R D E R PER S. RIFAUR RAHMAN, A.M.: THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAI NST THE ORDER OF THE LEARNED COMMISSIONER OF INCOME-TAX(A) - II, HYDERABAD, DATED 28-07-2014 FOR AY 2008-09. 2. BRIEFLY THE FACTS OF THE CASE ARE THAT THE ASSES SEE IS A DIRECTOR OF M/S ASIP (P) LTD. FOR THE AY 2008-09, ASSESSEE F ILED RETURN OF INCOME ON 31/07/2008 ADMITTING AN INCOME OF RS. 18, 35,510/-. THE RETURN WAS PROCESSED U/S 143(1) OF THE ACT. 2.1 IN THE CASE OF M/S ASIP (P) LTD., THERE WAS A S URVEY OPERATION U/S 133A OF THE ACT, ON 10/02/2009. AO NOTICED THAT IN THE CASE OF M/S ASIP (P) LTD., ASSESSEE HAD INVESTED AN AMOUNT OF R S. 1,93,99,313/- TOWARDS SHARE CAPITAL/SHARE APPLICATION MONEY. IN T HE COURSE OF SCRUTINY ASSESSMENT PROCEEDINGS, ASSESSEE FILED CON FIRMATION LETTERS FOR SUCH INVESTMENT. AO AFTER RECORDING SATISFACTIO N, ISSUED NOTICE U/S 2 ITA NO. 366/H/15 Y.S. RAJESH REDDY 148 ON 09/08/2011. THE ASSESSEE FILED A LETTER DATE D 09/09/2011 STATING THAT THE RETURN OF INCOME ALREADY FILED ON 31/07/2008 MAY BE TREATED AS RETURN FILED IN RESPONSE TO NOTICE U/S 1 48. SUBSEQUENTLY, NOTICES U/S 143(2) AND 142(1) WERE ISSUED. 2.2 AO OBSERVED THAT IN THE STATEMENT OF AFFAIRS AS AT 31/03/2008 AS FILED BY THE ASSESSEE, THE UNSECURED LOANS WERE RS. 3,05,45,040/-. WHEN THE ASSESSEE WAS ASKED TO SUBMIT NECESSARY EVI DENCE IN RESPECT OF SUCH UNSECURE LOANS, ASSESSEE HAD FILED CONFIRMATION LETTERS FROM THE CREDITORS ALONG WITH THEIR BANK AC COUNT STATEMENTS. AO MADE ADDITION IN RESPECT OF UNSECURED LOANS FROM MRS. SADHANA REDDY FOR RS. 25 LAKHS AND WITH RESPECT TO LOAN FRO M MR. RODNEY PAUL FOR AN AMOUNT OF RS. 1,30,000/-. 2.3 WITH REGARD TO LOAN FROM MRS. SADHANA REDDY, TH E FACTS ARE THAT THE ASSESSEE IS A MANAGING DIRECTOR OF M/S ASI P (P) LTD. FOR THE PURPOSE OF CONSTRUCTING HOUSES BY NAME WOODSTOCK AT ALWAL VILLAGE, RR DISTRICT, HE TOOK ADVANCES FROM SEVERAL PARTIES. 2.4 M/S ASIP (P) LTD. ENTERED INTO AN AGREEMENT TO PURCHASE LAND FROM MR. K. RAJALINGAM REPRESENTED BY GPA HOLDER MR . SRINIVAS VARMA. THE ABOVE LAND WAS SUBJECTED TO LITIGATION A S IT WAS IN EXCESS OF URBAN LAND CEILING LIMITS. THE GOVT. OF AP VIDE G.O. NO. 178, DATED 15/02/2006 EXEMPTED THE LAND FROM PROVISIONS OF URBAN LAND CEILING ON PAYMENT OF FOLLOWING AMOUNTS: DATE AMOUNT (RS.) BANK DD NO. 21/05/2005 5,00,000/- HDFC 145125 30/06/2005 25,20,000/- SBH 651673 30/06/2005 1,000/- SBH 000012 30/06/2005 612/- SBH 000009 COPY OF G.O.MS. NO. 178, DATED 15/02/2006 EVIDENCIN G THE ABOVE PAYMENT IS PART OF PAPER BOOK FILED BY THE ASSESSEE . M/S ASIP (P) LTD. MADE A PAYMENT OF RS. 25,20,000/- TO GOVT. OF AP AS PER GO ON 3 ITA NO. 366/H/15 Y.S. RAJESH REDDY 30/06/2005. THE SAME WAS ARRANGED FROM MRS. SADHANA REDDY AND SHE MADE THE PAYMENT THROUGH HER MOTHER MRS. Y. SUE SHEELA REDDY VIDE DD NO. 651673 DATED 30/06/2005. THE ABOVE PAYM ENT WAS DULY RECORDED IN THE BOOKS OF M/S ASIP (P) LTD. 2.5 DUE TO SOME DISPUTES BETWEEN M/S ASIP (P) LTD. AND MR. K. RAJALINGAM, THE VENTURE WOODSTOCK WAS ABANDONED. SUBSEQUENTLY, ALL THE ADVANCES THAT WERE RECEIVED FROM SEVERAL PA RTIES TOWARDS BOOKING OF HOUSES IN WOODSTOCK WAS TAKEN OVER BY TH E ASSESSEE AND ACCORDINGLY, M/S ASIP (P) LTD. ALLOTTED SHARES TO T HE ASSESSEE IN AY 2008-09. 2.6 ASSESSEE HAS FILED CONFIRMATION LETTERS FOR THE ABOVE TRANSACTION OF RS. 25 LAKHS FROM MRS. Y. SUSHEELA R EDDY AS WELL AS FROM MRS. SADHANA REDDY. 3. AGGRIEVED WITH THE ADDITION OF RS. 25 LAKHS AS U NEXPLAINED INVESTMENT, ASSESSEE PREFERRED AN APPEAL BEFORE THE CIT(A). THE CIT(A) AFTER CONSIDERING THE SUBMISSIONS OF THE ASS ESSEE CONFIRMED THE ADDITION BY OBSERVING AS UNDER: 5. THE INFORMATION ON RECORD IS CAREFULLY CONSIDERE D. THE CRUX OF THE ISSUE IS WHETHER MRS.SADHANA REDDY HAD REMIT TED AN AMOUNT OF RS.25,00,000/- FROM USA OR NOT? NO CONFIR MATION LETTER BY SMT. SADHANA REDDY WAS SUBMITTED BY THE A UTHORIZED REPRESENTATIVE. INSTEAD, THE CONFIRMATION LETTER OF ANOTHER LOAN CREDITOR SMT. SANGEETHA REDDY AND THE REPAYMENTS MA DE TO SMT. SANGEETHA REDDY BY THE ASSESSEE WERE SUBMITTED . HOWEVER, ON VERIFICATION OF THE ASSESSMENT RECORD I T WAS FOUND THAT SMT. SADHANA REDDY HAD GIVEN CONFIRMATION AS U NDER: 'I, SADHANA REDDY D/O Y.S. ANAND REDDY R/O. PLOT NO .473, PHASE-III, ROAD NO.87, JUBILEE HILLS, HYDERABAD - 5 00033, DO HERE BY CONFIRM THAT I HAVE GIVEN AN AMOUNT OF RS.2 5,00,000/- BY DD NO. 651673 DT.30.06.2005 & RS.22,20,000/- BY CHEQUE NO. 000489 DT. 19.08.2005 DRAWN ON 'BANK OF INDIA, HYDERABAD DURING THE FINANCIAL YEAR 2004-05 TO MR. Y. S. RAJE SH REDDY OF ASIP PVT LTD. 4 ITA NO. 366/H/15 Y.S. RAJESH REDDY THE ABOVE AMOUNT IS PAID OUT OF MY EARNINQ/ SAVINGS FROM EMPLOYMENT AND MY PAN IS DPPPS1466P.' . 5.1 HOWEVER, IN THE ABSENCE OF BANK ACCOUNT COPY O F SMT. Y. SUSHEELA REDDY, IT IS NOT POSSIBLE TO VERIFY WHETHE R SMT. SADHANA REDDY HAD REMITTED ANY AMOUNT FROM USA OR N OT ? FURTHER, THE DETAILS OF REPAYMENTS MADE TO SMT. SAD HANA REDDY WERE ALSO NOT SUBMITTED BY THE AR. IN STEAD R EPAYMENTS MADE TO SMT. SANGEETA REDDY WERE SUBMITTED. IN THIS BACKGROUND, IT CANNOT BE CONSIDERED THAT THE SOURCE S FOR AN AMOUNT OF RS.25,00,000/- WERE EXPLAINED. 4. AGGRIEVED WITH THE ABOVE ORDER, ASSESSEE IS IN A PPEAL BEFORE US RAISING THE FOLLOWING GROUNDS OF APPEAL: 1. THE ORDER OF THE AO IS CONTRARY TO THE LAW, FA CTS AND CIRCUMSTANCES OF THE CASE. 2. THE APPELLATE COMMISSIONER OUGHT NOT TO HAVE CON FIRMED THE ADDITION OF RS.1,30,000/- BEING UNSECURED LOAN TAKE N FROM MR.RODNEY PAUL TO THE INCOME OF THE ASSESSEE MADE B Y THE AO. 3. THE APPELLATE COMMISSIONER OUGHT NOT TO HAVE CON FIRMED THE ADDITION OF RS.25,00,000/- BEING UNSECURED LOAN TAK EN FROM MS.SADHANA REDDY TO THE INCOME OF THE ASSESSEE MADE BY THE AO. 4. THE APPELLATE COMMISSIONER OUGHT NOT TO HAVE CON FIRMED THE ADDITIONS OF THE ABOVE AMOUNTS MADE BY THE AO WITHO UT INDICATING UNDER WHICH SECTION THE SAID AMOUNTS ARE BEING ADDED. 7. WITH REGARD TO ADVANCE FROM SMT. SADHANA REDDY, LD. AR OF THE ASSESSEE SUBMITTED THAT SOME PAYMENTS WERE REQUIRE D TO BE MADE TO URBAN LAND CEILING, HYDERABAD BY SHRI P. SRINIVASA VARMA, GPA HOLDER OF SHRI K. RAJA LINGAM, FOR WHICH PAYMENTS W ERE ARRANGED BY SMT. SADHANA REDDY BY WAY OF DD NO. 651673 ON 30/06 /2005 FOR RS. 25,20,000/- ISSUED BY SBH MASAB TANK, HYDERABAD, WH ICH WAS DULY ACKNOWLEDGED BY THE REVENUE-URBAN CEILING.IV, DEPAR TMENT BY CONFIRMATION LETTER DATED 18/04/2006. THE ABOVE LET TERS WERE FILED AT PAGES 1 TO 3 OF PAPER BOOK. THE ABOVE PAYMENTS WERE MADE BY SMT. SADHANA REDDY ON BEHALF OF COMPANY, IN WHICH HER BR OTHER IS THE M.D. TO PURCHASE 3.5 ACRES OF LAND FROM MR. K. RAJA LINGAM. HE 5 ITA NO. 366/H/15 Y.S. RAJESH REDDY SUBMITTED THAT THE ABOVE PAYMENTS WERE MADE BY SMT. SADHANA REDDY ON BEHALF M/S ASIP (P) LTD. AND THE COMPANY H AS DULY ACKNOWLEDGED IN THEIR BOOKS OF ACCOUNT, FOR WHICH, HE HAS SUBMITTED STATEMENT OF ACCOUNT, WHICH IS PLACED ON RECORD AT PAGE 4 OF PAPER BOOK. HE FURTHER SUBMITTED THAT ASSESSEE HAS FILED AN AFFIDAVIT AFFIRMING THAT THE ADVANCES PAID BY HIS FAMILY MEMB ERS, RELATIVES AND FRIENDS TO THE COMPANY I.E. M/S ASIP (P) LTD. AND T HE EARLIER FIRM KNOWN AS AS INFRASTRUCTURE PROJECTS, THE PARTNERSHI P FIRM, TO THE EXTENT OF ADVANCES GIVEN TO THE COMPANY/FIRM, THE C OMPANY HAS ISSUED SHARE CAPITAL IN THE NAME OF THE ASSESSEE. T HE ABOVE AFFIDAVIT IS PLACED ON RECORD AT PAGE 5 OF PAPER BOOK. HE FUR THER SUBMITTED THAT ADVANCE AMOUNT OF RS. 25,20,000/- PAID BY SMT. SADH ANA REDDY WAS, IN FACT, PAID BY HER MOTHER SMT. SUSHEELA REDDY BY WAY OF DD BEARING NO. 651673 DATED 30/06/2005 IN FAVOUR OF UR BAN LAND CEILING, HYD THROUGH HER BANK ACCOUNT, FOR WHICH, S MT. SUSHEELA REDDY HAS FILED CONFIRMATION LETTER, WHICH WAS ALSO PART OF PAPER BOOK AT PAGE 6. HE SUBMITTED THAT PAYMENTS WERE GENUINE AND THE PAYMENTS WERE MADE BY SMT. SADHANA REDDY THROUGH HE R MOTHER DIRECTLY TO THE URBAN LAND CEILING, HYD INSTEAD OF PAYING TO THE COMPANY, AS THE COMPANY HAS PROPERLY RECORDED IN TH EIR BOOKS OF ACCOUNT. HE SUBMITTED THAT IT DEMONSTRATES THAT SMT . SADHANA REDDY HAS IN FACT MADE ADVANCES TO THE COMPANY AND IF AT ALL ANY ADDITION HAS TO BE MADE, IT SHOULD BE MADE IN THE HANDS OF T HE COMPANY AND NOT IN THE HANDS OF THE ASSESSEE. HE FURTHER SUBMIT TED THAT SMT. SADHANA REDDY HAS SUBMITTED CONFIRMATION LETTER FOR MAKING SUCH PAYMENT TOWARDS BUYING A FLAT FROM THE COMPANY. 8. LD. DR SUBMITTED THAT THE SUBMISSIONS MADE BY TH E ASSESSEE ARE FULL OF INCONSISTENCIES AS THE ASSESSEE CLAIM T HAT THE ADVANCES WERE RECEIVED FROM SMT. SADHANA REDDY AND THE SAME WAS REPAID TO HER SISTER THROUGH SMT. SUSHEELA REDDY AND ALSO TH E ASSESSEE HAS FAILED TO SUBMIT ANY BANK ACCOUNT OF SMT. Y. SUSHEE LA REDDY, MOTHER 6 ITA NO. 366/H/15 Y.S. RAJESH REDDY OF SMT. SADHANA REDDY. SHE SUBMITTED THAT THE SUBMI SSIONS OF THE ASSESSEE SHOW THAT THEY ARE NOT PROPER. 9. CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL FACTS ON RECORD. WITH REGARD TO ADVANCE RECEIVED FROM SMT . SADHANA REDDY, IT IS OBSERVED THAT THE ABOVE PAYMENTS WERE MADE BY SMT. SADHANA REDDY THROUGH HER MOTHER SMT. Y. SUSHEELA REDDY DIRECTLY TO URBAN LAND CEILING, HYD. ON 30/06/05 BY WAY OF D D FOR RS. 25,20,000/-. SMT. SADHANA REDDY HAS FILED CONFIRMAT ION LETTER BEFORE THE AO THAT THE ABOVE PAYMENTS WERE MADE TO THE COM PANY M/S ASIP (P) LTD., WHICH BELONGS TO Y. S. RAJESH REDDY, OUT OF HER EARNINGS/SAVINGS FROM EMPLOYMENT. WE FIND IT PLAUSI BLE THAT CIT(A) HAS MENTIONED IN HER ORDER THAT MRS. SADHANA REDDY HAS NOT FILED CONFIRMATION LETTER BUT IN HER OWN ORDER, SHE REPRO DUCED THE CONFIRMATION LETTER OF MRS. SADHANA REDDY. SIMILARL Y, SMT. Y. SUSHEELA REDDY, MOTHER OF SMT. SADHANA REDDY ALSO F ILED CONFIRMATION LETTER CONFIRMING THAT SHE HAD PAID AN AMOUNT OF RS. 25,20,000/- ON 30/06/2005 BY WAY OF DD TO URBAN LA ND CEILING, HYD. AS PER SMT. SADHANA REDDYS INSTRUCTIONS AND AS REQ UESTED BY M/S AS INFRASTRUCTURE PROJECTS, OUT OF REMITTANCES SENT BY HER, AS ADVANCE, FOR BOOKING AN INDEPENDENT HOUSE IN THE PR OPOSED HOUSING PROJECT WOODSTOCK. THE ABOVE REMITTANCES WERE ALS O ACKNOWLEDGED BY THE COMPANY AS INFRASTRUCTURE PROJECTS. IN THE S TATEMENT OF ACCOUNTS SUBMITTED FROM THE COMPANY, WE FIND THAT T HE ABOVE PAYMENTS WERE RECEIVED FROM SMT. SADHANA REDDY TOWA RDS PART CONSIDERATION OF RS. 3.5 ACRES OF LAND TO P. SRINIV ASA VARMA ON 30/06/2005 AND FURTHER ASSESSEE HAS FILED AN AFFIDA VIT THAT ADVANCES GIVEN BY SMT. SADHANA REDDY WAS LATER TAKEN OVER BY ASSESSEE IN HIS INDIVIDUAL CAPACITY AND THE COMPANY HAS ISSUED SHARE CAPITAL FOR THE SAME. 9.1 ALL THE ABOVE TRANSACTIONS WERE TAKEN PLACE IN FY 2005-06 RELEVANT TO AY 2006-07 AND THESE REMITTANCES WERE M ADE ON BEHALF OF 7 ITA NO. 366/H/15 Y.S. RAJESH REDDY M/S ASIP (P). LTD./AS INFRASTRUCTURE PROJECTS. AO M ADE THE ADDITION IN THE HANDS OF ASSESSEE IN THE AY 2008-09. ASSESSEE H AS FILED AN AFFIDAVIT IN SUPPORT OF THE INVESTMENT IN THE COMPA NY OF WHICH ONE OF THE SOURCE WAS THE AMOUNT RECEIVED FROM SMT. SADHAN A REDDY. THIS TRANSACTION TRACES BACK TO THE TRANSACTIONS CARRIED ON WITH/ON BEHALF OF THE COMPANY. AS FAR AS THE ASSESSEE IS CONCERNED , THE COMPANY HAS ALREADY CONFIRMED THAT THEY HAVE RECEIVED ADVAN CE FROM SMT. SADHANA REDDY AND HOW THEY HAVE TREATED THE SAME IN THEIR BOOKS OF ACCOUNT. IN OUR CONSIDERED VIEW, AS FAR AS ASSESSEE IS CONCERNED, GENUINENESS OF THE TRANSACTION IS PROPERLY PROVED. THERE IS NO DISPUTE WITH REGARD TO PAYMENT WHICH WAS MADE TO URBAN LAND CEILING DEPARTMENT EVEN THOUGH THE SAME WAS CONFIRMED IN TH E NAME OF MR. P. SRINIVAS VARMA. BUT THE FUNDS WERE PAID THROUGH THE BANK ACCOUNT OF MRS. Y. SUSHEELA REDDY. HOWEVER, THE ASSESSEE W AS ALLOTTED SHARES IN AY 2008-09 BUT THE TRANSACTIONS OF UNSECU RED LOAN ARE DATED BACK TO AY 2006-07. THE ASSESSEE HAS PROVED T HE GENUINENESS OF THE TRANSACTION BY FILING CONFIRMATION LETTERS F ROM MRS. SADHANA REDDY AND THE COMPANY. IN OUR CONSIDERED VIEW, THE ASSESSEE HAS FULFILLED HIS DUTY AND PROVED THE GENUINENESS OF TH E TRANSACTION, AO IS NOT JUSTIFIED TO MAKE SUCH ADDITION. 10. WITH REGARD TO UNSECURED LOANS FROM MR. RODNEY PAUL, THE ASSESSEE HAD SUBMITTED CONFIRMATION FROM MR. RODNEY PAUL, AS PER WHICH, MR. RODNEY PAUL WAS IN AUSTRALIA AND REMITTE D FUNDS. ON NOTICING THAT THE LETTER WAS NOT SENT FROM AUSTRALI A, THE AO TREATED THE AMOUNT OF RS. 1,30,000/- AS UNEXPLAINED INVESTMENT AND ADDED THE SAME TO THE INCOME OF THE ASSESSEE. 11. AGGRIEVED, THE ASSESSEE PREFERRED AN APPEAL BEF ORE THE CIT(A) AND THE CIT(A) OBSERVED THAT THE ASSESSEE SUBMITTED A COPY OF CONFIRMATION LETTER, WHICH HAD BEEN MAILED BY MR. P AUL. CIT(A) OBSERVED THAT THE CONFIRMATION LETTER DID NOT APPEA R TO HAVE BEEN DOWN LOADED FROM MAIL ACCOUNT, AS IT WAS TYPED ON A WHITE PAPER. THE 8 ITA NO. 366/H/15 Y.S. RAJESH REDDY CIT(A), THEREFORE, CONFIRMED THE ADDITION CONSIDERI NG THE INCONSISTENCIES OF THE SUBMISSIONS OF THE ASSESSEE. 12. AGGRIEVED WITH THE ORDER OF CIT(A), THE ASSESSE E IS IN APPEAL BEFORE US. 13. CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED TH E MATERIAL FACTS ON RECORD. ASSESSEE HAS NOT SUBMITTED ANY CONFIRMAT ION LETTER BEFORE US OR TO CLAIM OTHERWISE WHAT WAS SUBMITTED BEFORE TAX AUTHORITIES. HOWEVER, WE FIND THAT MR. RODNEY PAUL HAS MADE PAYM ENT TO THE COMPANY AS UNSECURED LOAN PRIOR TO THIS AY 2008-09. WE ARE NOT SURE FOR WHAT PURPOSE ASSESSEE OR THE COMPANY HAS TAKEN UNSECURED LOAN FROM MR. RODNEY PAUL. SINCE ASSESSEE HAS NOT SUBMIT TED ANY PROPER EVIDENCE TO SUBSTANTIATE THE ABOVE PAYMENT BEFORE U S OR BEFORE THE REVENUE AUTHORITIES, WE ARE INCLINED TO CONFIRM THE ADDITION MADE BY THE AO ACCORDINGLY, THIS GROUND IS DISMISSED. 14. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. PRONOUNCED IN THE OPEN COURT ON 22 ND SEPTEMBER, 2017. SD/- SD/- (D. MANMOHAN) (S. RIFAUR RAHMAN ) VICE PRESIDENT AC COUNTANT MEMBER HYDERABAD, DATED: 22 ND SEPTEMBER, 2017. KV COPY TO:- 1) SHRI Y.S. RAJESH REDDY, PLOT NO. 473-R, ROAD NO. 87, JUBILEE HILLS, HYDERABAD 500 033. 2) DCIT, CENTRAL CIRCLE 1(1), HYDERABAD. 3) CIT(A) - II, HYDERABAD 4 CIT - 1, HYDERABAD 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDE RABAD. 6) GUARD FILE 9 ITA NO. 366/H/15 Y.S. RAJESH REDDY 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