Satindersingh Sethi, Visakhapatnam V. THE ITO, Visakhapatnam

ITA 375/VIZ/2015

• Counselvise Citation: [2016] 130 COUNSELVISE.COM (IT) 9796 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 11 month(s) 11 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 07-10-2016
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2011-2012
• Appeal Filed On: 26-10-2015
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: T SATYANANDAM
• Keywords: Additional evidence; Tax effect

Judgement Text

ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 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.375/VIZAG/2015 ( / ASSESSMENT YEAR: 2011-12) SATINDER SINGH SETHI, VISAKHAPATNAM VS. ITO, WARD - 1(1), VISAKHAPATNAM [PAN: ABNPS6379L ] ( % / APPELLANT) ( &'% / RESPONDENT) ./I.T.A.NO.411/VIZAG/2015 ( / ASSESSMENT YEAR: 2011-12) ITO, WARD - 1(1), VISAKHAPATNAM VS. SATINDER SINGH SETHI, VISAKHAPATNAM ( % / APPELLANT) ( &'% / RESPONDENT) / APPELLANT BY : SHRI C. SUBRAHMANYAM, AR / RESPONDENT BY : SHRI T. SATYANANDAM, DR / DATE OF HEARING : 05.10.2016 / DATE OF PRONOUNCEMENT : 07.10.2016 ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 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 ORDER OF CIT(A)-1, VIS AKHAPATNAM DATED 29.9.2015 AND IT PERTAINS TO THE ASSESSMENT YEAR 20 11-12. SINCE, THE FACTS ARE IDENTICAL AND ISSUES ARE COMMON, THEY ARE CLUBBED, HEARD TOGETHER AND DISPOSED-OFF, BY WAY OF THIS COMMON OR DER FOR THE SAKE OF CONVENIENCE. 2. THE BRIEF FACTS OF THE CASE ARE TH AT THE ASSESSEE IS AN INDIVIDUAL DERIVING INCOME FROM HOUSE PROPERTY FILE D HER RETURN OF INCOME FOR THE ASSESSMENT YEAR 2011-12 ON 30.7.2011 DECLARING TOTAL INCOME OF ` 4,70,430/-. THE CASE HAS BEEN SELECTED FOR SCRUTI NY UNDER CASS AND ACCORDINGLY, NOTICE U/S 143(2) OF THE INCO ME TAX ACT, 1961 (HEREINAFTER CALLED AS 'THE ACT') WAS ISSUED. IN R ESPONSE TO NOTICE, THE AUTHORIZED REPRESENTATIVE OF THE ASSESSEE APPEARED FROM TIME TO TIME AND FILED THE INFORMATION CALLED FOR. DURING THE C OURSE OF ASSESSMENT PROCEEDINGS, THE A.O. NOTICED THAT THE ASSESSEE IS MAINTAINING TWO BANK ACCOUNTS AT INDUS IND BANK, SEETHAMMADHARA BRANCH, VISAKHAPATNAM AND KARNATAKA BANK LTD., JAGADAMBA JUNCTION, VISAKH APATNAM. ON PERUSAL OF THE ACCOUNT STATEMENTS OF THE ABOVE TWO ACCOUNTS, IT WAS NOTICED THAT THERE ARE HUGE CREDITS IN THE BANK ACC OUNTS AGGREGATING TO ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 3 ` 62,22,661/-. AS THE ASSESSEE HAS NOT DISCLOSED TH E ABOVE BANK ACCOUNTS EITHER IN THE RETURN OF INCOME OR DURING T HE COURSE OF HEARING, THE A.O. ISSUED A NOTICE AND ASKED TO EXPLAIN THE N ATURE AND SOURCE OF CREDITS IN THE BANK ACCOUNTS. SINCE, THE ASSESSEE NEITHER APPEARED BEFORE THE A.O. NOR FURNISHED ANY DETAILS, THE A.O. MADE ADDITIONS OF ` 62,22,661/- AS UNEXPLAINED INCOME OF THE ASSESSEE A ND BROUGHT TO TAX. 3. AGGRIEVED BY THE ASSESSMENT ORDER, THE ASSESSEE PREFERRED AN APPEAL BEFORE THE CIT(A). BEFORE THE CIT(A), THE A SSESSEE HAS FILED ADDITIONAL EVIDENCES TO EXPLAIN CREDITS IN THE BANK ACCOUNTS. THE CIT(A), DURING THE COURSE OF APPELLATE PROCEEDINGS, FORWARDED ADDITIONAL EVIDENCES FILED BY THE ASSESSEE TO THE A .O. FOR HIS COMMENTS. THE A.O. VIDE HIS REMAND REPORT DATED 12.12.2014 HA S EXAMINED THE ADDITIONAL EVIDENCES FILED BY THE ASSESSEE AND COMM ENTED ON EACH AND EVERY ADDITIONS MADE TOWARDS CREDITS IN THE BANK AC COUNTS. THE CIT(A) AFTER CONSIDERING THE EXPLANATIONS FURNISHED BY THE ASSESSEE AND ALSO TAKEN NOTE OF THE REMAND REPORT ISSUED BY THE A.O., PARTLY ALLOWED APPEAL FILED BY THE ASSESSEE. THE CIT(A) FOR THE R EASONS RECORDED IN HIS ORDER, HAS CONFIRMED ADDITIONS TO THE EXTENT OF ` 26,97,500/- OUT OF TOTAL ADDITIONS OF ` 62,22,661/- AND REMAINING AMOUNT HAS BEEN DELETED. AGGRIEVED BY THE CIT(A) ORDER, THE ASSESSEE AS WELL AS REVENUE ARE IN APPEAL BEFORE US. ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 4 4. THE LD. A.R. FOR THE ASSESSEE SUBMITTED THAT THE CIT(A) IS NOT JUSTIFIED IN CONFIRMING ADDITION OF ` 5,22,500/- FOUND CREDIT IN THE BANK ACCOUNT OF KARNATAKA BANK LTD., WHEN THE ASSESSEE H AS EXPLAINED THE SOURCE AND NATURE OF DEPOSIT WITH SUBSTANTIAL EVIDE NCES. THE A.R. FURTHER SUBMITTED THAT THE ASSESSEE HAS EXPLAINED T HE SOURCES OF DEPOSITS FOUND IN THE KARNATAKA BANK LTD. OUT OF TH E MONEY WITHDRAWN FROM THE SAME BANK ACCOUNT ON 7.6.2010, THEREFORE, THE CIT(A) WITHOUT FINDING ANYTHING CONTRARY THAT THE CASH WITHDRAWAL IN THE EARLIER OCCASIONS HAS BEEN UTILIZED OR DEPLOYED IN OTHER AS SETS, THE SOURCES AVAILABLE CANNOT BE IGNORED. THE A.R. FURTHER SUBM ITTED THAT THE CIT(A) IS NOT CORRECT IN CONFIRMING BANK DEPOSIT OF ` 8,20,000/- IN A CASUAL MANNER, WHEN THE ASSESSEE EXPLAINED THE SOURCE WITH CREDIBLE EVIDENCE. THE LD. CIT(A) FAILED TO TAKE COGNIZANCE OF THE FAC T THAT THE SAID AMOUNT HAS BEEN TRANSFERRED FROM ASSESSEES DAUGHTER AND T HE CREDITOR HAS CONFIRMED TRANSACTIONS BY FILING CONFIRMATION LETTE RS ALONG WITH HER INCOME TAX RETURN COPIES. IT WAS FURTHER SUBMITTED THAT THE CIT(A) GROSSLY ERRED IN CONFIRMING THE DEPOSIT OF ` 13,50,000/- IN INDUS IND BANK AS UNEXPLAINED. THE CIT(A) FAILS TO TAKE NOTE OF THE FACT THAT THE SAID DEPOSIT AMOUNT IS FROM OUT OF WITHDRAWALS MADE FROM ANOTHER BANK ACCOUNT I.E. KARNATAKA BANK LTD. AND THE ASSESSEE H AS FILED THE DETAILS OF BOTH BANK ACCOUNTS. THE A.R. FURTHER SUBMITTED T HAT THE CIT(A) ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 5 GROSSLY ERRED IN CONFIRMING THE ADDITIONS WITHOUT P OINTING OUT THAT THE SAID AMOUNT HAS BEEN UTILIZED OR DEPLOYED IN ANOTHE R ASSETS. WHEN THE SOURCES ARE AVAILABLE IN THE FORM OF WITHDRAWALS IN EARLIER OCCASIONS, UNLESS THE REVENUE PROVES THAT THE SAID AMOUNT HAS BEEN EXPENDED BY THE ASSESSEE, THE SOURCES AVAILABLE CANNOT BE IGNOR ED. THEREFORE, REQUESTED TO DELETE THE ADDITIONS MADE BY THE A.O. 5. ON THE OTHER HAND, THE LD. D.R. SUPPORTED THE OR DER PASSED BY THE CIT(A). THE D.R. FURTHER SUBMITTED THAT AS REGARDS AMOUNT DELETED BY THE CIT(A), THE CIT(A) FAILED TO APPRECIATE THE FAC T THAT THE ASSESSEE NEITHER APPEARED BEFORE THE A.O. NOR FURNISHED ANY DETAILS WITH REGARD TO THE CREDITS IN THE BANK ACCOUNTS. IN THE ABSENC E OF NECESSARY DETAILS, THE A.O. HAS MADE ADDITIONS AND ALSO THESE BANK ACC OUNTS WERE NOT DISCLOSED IN THE INCOME TAX RETURN FILED BY THE ASS ESSEE. IT WAS FURTHER SUBMITTED THAT WHEN THE ASSESSEE WAS ASKED TO EXPLA IN THE SOURCES FOR THE CREDITS, THE ASSESSEE NOT CHOSEN TO EXPLAIN THE SOURCES WITH NECESSARY EVIDENCES. THEREFORE, THE A.O. HAS MADE ADDITIONS AND HIS ORDER SHOULD BE UPHELD. 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 A.O. MADE ADDITIONS TOWARDS CREDITS IN THE BANK ACC OUNTS FOR THE REASON THAT THE ASSESSEE HAS FAILED TO EXPLAIN THE NATURE AND SOURCE OF CREDITS ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 6 IN THE BANK ACCOUNT. THE A.O. WAS OF THE OPINION T HAT THOUGH ASSESSEE FILED CONFIRMATION LETTERS FROM CREDITORS TO PROVE THE SOURCES OF CREDITS, THE CREDITORS DOES NOT HAVE CREDITWORTHINESS TO SUB STANTIATE THE AMOUNT GIVEN TO THE ASSESSEE. IT IS THE CONTENTION OF THE ASSESSEE THAT THE SOURCE FOR THE CREDITS IN THE BANK ACCOUNT HAS BEEN EXPLAINED WITH NECESSARY EVIDENCES. THE ASSESSEE FURTHER CONTENDE D THAT ALL THE CREDITS HAVE BEEN EXPLAINED WITH NECESSARY EVIDENCE S AND THE CIT(A) HAS FAILED TO TAKE COGNIZANCE OF THE EVIDENCES FILE D IN THE FORM OF BANK STATEMENTS AND INCOME TAX RETURNS OF CREDITORS. 7. HAVING HEARD BOTH THE SIDES, WE FIND FORCE IN TH E ARGUMENTS OF THE ASSESSEE, FOR THE REASON THAT THE ASSESSEE HAS FILE D DETAILS OF CREDITS IN THE BANK ACCOUNT WITH NECESSARY EVIDENCES. AS REGA RDS THE ADDITION OF ` 5,22,000/-, THE ASSESSEE CLAIMS TO HAVE EXPLAINED THE SOURCE OUT OF WITHDRAWALS FROM SAME BANK ACCOUNT IN THE EARLIER O CCASIONS. ON PERUSAL OF THE BANK STATEMENT FILED BY THE ASSESSEE , WE FIND THAT THE ASSESSEE HAS WITHDRAWN AN AMOUNT OF ` 3,90,000/- ON 7.6.2010 AND MADE DEPOSIT OF ` 2,90,000/- ON 19.6.2010. WHEN THESE FACTS WERE FIL ED BEFORE THE CIT(A), THE CIT(A) IGNORED THE EVIDENCES FILED AND CONFIRMED THE ADDITION BY STATING THAT THE ASSESSEE FAILED TO EXPLAIN WHY THESE TWO BANK ACCOUNTS WERE NOT DISCLOSED IN THE INCOME TAX RETURNS FILED FOR THE YEAR. WE DO NOT FIND ANY MERITS IN THE FINDINGS OF THE CIT(A), FOR THE ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 7 REASON THAT THE ASSESSEE IS DERIVING INCOME FROM HO USE PROPERTY AND FILED INCOME TAX RETURNS IN FORM NO.ITR-2, WHEREIN THERE IS NO SCOPE FOR THE ASSESSEE TO DISCLOSE ALL THE BANK ACCOUNTS. TH E FORM NO.ITR-2 FACILITATE THE ASSESSEE TO DISCLOSE ONE OF THE BANK ACCOUNT TO FACILITATE ISSUE OF REFUNDS, IF ANY PAYABLE TO THE ASSESSEE. THEREFORE, THE CIT(A) WAS NOT CORRECT IN HOLDING THAT THESE TWO BANK ACCO UNTS WERE NOT DISCLOSED IN THE INCOME TAX RETURNS FILED FOR THE R ELEVANT ASSESSMENT YEARS. WE FURTHER NOTICED THAT AS REGARDS THE SOUR CES OF CREDITS, THE ASSESSEE HAS EXPLAINED SOURCE OF ` 2,90,000/- OUT OF TOTAL DEPOSIT OF ` 5,22,500/-. THEREFORE, WE ARE OF THE VIEW THAT THE A.O. IS NOT CORRECT IN MAKING ADDITIONS OF ` 2,90,000/- WHEN THE ASSESSEE HAS EXPLAINED THE SOURCE WITH NECESSARY BANK ENTRIES. HENCE, WE DIRE CT THE A.O. TO DELETE ADDITION OF ` 2,90,000/-OUT OF TOTAL ADDITIONS OF ` 5,22,500/- AND BALANCE IS CONFIRMED. 8. AS REGARDS CREDITS OF ` 8,20,000/- FOUND IN THE KARNATAKA BANK LTD., ASSESSEE SOUGHT TO EXPLAIN THE SOURCES FOR CR EDITS OF ` 8,20,000/- BY WAY OF AMOUNT RECEIVED FROM HIS DAUGHTER SMT. PU NEET KAUR SETHI. THE ASSESSEE FILED BANK ACCOUNTS OF THE CREDITORS A ND HER INCOME TAX RETURNS AND EXPLAINED THE TRANSFER OF AMOUNT FROM C REDITOR ACCOUNT TO ASSESSEES ACCOUNT. THE ASSESSEE ALSO FILED A CONF IRMATION LETTER FROM THE CREDITORS, WHEREIN THE CREDITOR HAS CONFIRMED T HAT SHE HAD GIVEN ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 8 AMOUNT OF ` 8,20,000/- TO THE ASSESSEE. THE CIT(A) HAVING ACC EPTED THE FACT THAT THE CREDITOR HAS FURNISHED CONFIRMATI ON LETTERS, REJECTED THE EXPLANATIONS OFFERED BY THE ASSESSEE BY STATING THA T THE ASSESSEE HAS FAILED TO PROVE THE CREDITWORTHINESS OF THE CREDITO R. WE DO NOT FIND ANY MERITS IN THE FINDINGS OF THE CIT(A), FOR THE REASO N THAT ON PERUSAL OF THE BANK STATEMENTS FILED BY THE ASSESSEE, WE NOTICED T HAT THE SAID AMOUNT OF ` 8,20,000/- HAS BEEN TRANSFERRED FROM SMT. PUNEET K AUR SETHIS ACCOUNT TO THE ASSESSEES ACCOUNT ON TWO OCCASIONS. WE FURTHER NOTICED THAT THE ASSESSEE HAS RECEIVED AN AMOUNT OF ` 1,55,000/- ON 18.8.2010 BY WAY OF TRANSFER TO ASSESSEES BANK ACCOUNT MAINT AINED AT KARNATAKA BANK LTD. SIMILARLY, THE ASSESSEE HAS RECEIVED ANO THER CREDIT OF ` 6,65,000/- ON 15.3.2011 FROM SAVINGS BANK ACCOUNT O F SMT. PUNEET KAUR SETHI TO THE ASSESSEE BANK ACCOUNT AT KARNATA KA BANK LTD. THE ASSESSEE ALSO FILED THE INCOME TAX RETURN COPY OF T HE CREDITOR. ON PERUSAL OF THE INCOME TAX RETURN, WE FIND THAT THE CREDITOR IS HAVING RENTAL INCOME OF ` 6,70,000/- PER ANNUM. WE FURTHER NOTICED THAT THE CREDITS ARE TRANSFERRED BY WAY OF BANK TRANSFERS. THEREFORE, WE ARE OF THE VIEW THAT THE ASSESSEE HAS DISCHARGED CREDITWOR THINESS OF THE CREDITOR. THE CIT(A) WITHOUT APPRECIATING THE FACT S SIMPLY CONFIRMED THE ADDITIONS MADE BY THE A.O. HENCE, WE DIRECT THE A. O. TO DELETE ADDITIONS OF ` 8,20,000/-. ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 9 9. COMING TO THE CREDITS FOUND IN INDUS IND BANK LT D. THE A.O. MADE ADDITIONS OF ` 13,50,000/- TOWARDS CREDITS IN INDUS IND BANK LTD. THE A.O. WAS OF THE OPINION THAT THE ASSESSEE HAS F AILED TO EXPLAIN THE SOURCES FOR CREDITS FOUND IN THE BANK ACCOUNT. IT I S THE CONTENTION OF THE ASSESSEE THAT HE HAD EXPLAINED THE SOURCES FOR CRED ITS IN THE BANK ACCOUNT BY FILING NECESSARY EVIDENCES. THE ASSESSE E FURTHER CONTENDED THAT HE HAD WITHDRAWN AN AMOUNT OF ` 13,45,000/- ON 20.8.2010 FROM KARNATAKA BANK LTD. AND DEPOSITED ` 13,50,000/- ON 20.8.2010. THE ASSESSEE EXPLAINED THE REASONS FOR WITHDRAWAL OF AM OUNT FROM KARNATAKA BANK LTD. AND DEPOSITED THE SAME IN INDUS IND BANK LTD. THE ASSESSEE EXPLAINED THAT HE NEED TO BUY DOLLARS FOR HER DAUGHTER AND FOUND THAT THE EXCHANGE RATE IN INDUS IND BANK LTD. IS HIGHER THAN THE KARNATAKA BANK LTD. THEREFORE, TO MEET THE IMMEDIA TE NECESSITY OF CASH IN INDUS IND BANK LTD., HE HAD WITHDRAWN AMOUN T FROM KARNATAKA BANK AND DEPOSITED IN INDUS IND BANK LTD. WE FIND F ORCE IN THE ARGUMENTS OF THE ASSESSEE, FOR THE REASON THAT ON P ERUSAL OF BANK STATEMENT FILED BY THE ASSESSEE, WE FIND THAT THE A SSESSEE HAD WITHDRAWN AN AMOUNT OF ` 13,45,000/- ON 20.8.2010 FROM KARNATAKA BANK LTD. AND DEPOSITED AN AMOUNT OF ` 13,50,000/- INTO INDUS IND BANK LTD. THE ASSESSEE ALSO FILED CERTIFICATE FROM THE BANKERS, WHEREIN THE BANKERS HAVE CERTIFIED THAT THE ASSESSEE HAS WI THDRAWN CASH ON THE ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 10 SAME DAY FROM KARNATAKA BANK LTD. THE ASSESSEE ALS O FILED COPY OF VOUCHER ISSUED BY INDUS IND BANK LTD. FOR PURCHASE OF DOLLARS. ON PERUSAL OF THE DETAILS FILED BY THE ASSESSEE, WE NO TICED THAT ON 20.8.2010, THE ASSESSEE HAS PURCHASED 29000 US DOLL ARS IN THE NAME OF HIS DAUGHTER SMT. PUNEET KAUR SETHI. ALL THESE DOC UMENTS WERE FILED BEFORE THE CIT(A). THE CIT(A) WITHOUT APPRECIATING THE FACT IGNORED THE EVIDENCES FILED BY THE ASSESSEE AND CONFIRMED THE A DDITIONS. THEREFORE, WE DIRECT THE A.O. TO DELETE ADDITION OF ` 13,50,000/- TOWARDS CREDITS IN INDUS IND BANK LTD. 10. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS PARTLY ALLOWED. ITA NO.411/VIZAG/2015: 11. WHEN THIS APPEAL IS TAKEN UP FOR HEARING, THE LD . COUNSEL FOR THE ASSESSEE HAS SUBMITTED THAT THE TAX EFFECT INVOLVED IN THIS APPEAL IS BELOW RS.10 LAKHS. AS PER THE LATEST CIRCULAR NO.2 1/2015 DATED 10.12.2015 OF CBDT BEING RETROSPECTIVE IN NATURE, T HE APPEAL FILED BY THE REVENUE IS NOT MAINTAINABLE. THE LD. D.R. HAS NOT RAISED ANY OBJECTION. IN VIEW OF THE ABOVE, THE APPEAL FILED BY THE REVENUE IS NOT MAINTAINABLE. HENCE, THE SAME IS DISMISSED. ITA NO.375/VIZAG/2015 & ITA NO.411/VIZAG/2015 SATINDER SINGH SETHI, VISAKHAPATNAM 11 12. IN THE RESULT, THE APPEAL FILED BY THE REVENUE IS DISMISSED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT ON 7 TH OCT16. SD/- SD/- ( . ) ( . ) (V. DURGA RAO) (G. MANJUNATHA) /JUDICIAL MEMBER /ACCOUNTANT MEMBER # /VISAKHAPATNAM: ' /DATED : 7 TH OCT16 VG/SPS )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT SATINDER SINGH SETHI, D.NO.26-1- 7/A, ISHAR KRUPA COMPLEX, VISAKHAPATNAM 2. / THE RESPONDENT THE ITO, WARD-1(1), VISAKHAPATN AM 3. + / THE CIT, VISAKHAPATNAM 4. + ( ) / THE CIT (A)-1, VISAKHAPATNAM 5. # . , . , # / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // 12 . (SR.PRIVATE SECRETARY) . , # / ITAT, VISAKHAPATNAM