M/s UNI ESTATES, Secunderabad V. ACIT, Circle 6(1), Hyderabad

ITA 415/HYD/2012

• Counselvise Citation: [2012] 140 COUNSELVISE.COM (IT) 66481 (ITAT-HYDERABAD)
• Duration Of Justice: 8 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-11-2012
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2007-2008
• Appeal Filed On: 15-03-2012
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Unexplained cash credit; Source of fund; Cost of acquisition; Retraction; Revised return
• Section: 69C; 139(5); 131

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B', HYDERABAD BEFORE SHRI SANJAY ARORA, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER ITA NO.415/ HYD/2012 : ASS ESSMENT YEAR 2007-08 M/S. UNI ESTATES, HYDERABAD. [PAN - AACFU 0754F] V/S. ASSTT. COMMISSIONER OF INCOME-TAX CIRCLE 6(1), HYDERABAD (APPELLANT) (RESP ONDENT) APPELLANT BY RESPONDENT BY : SHRI Y.V.BHANUNAAYAN RAO SMT. G.V.HEMALATHA, CIT-DR DATE OF HEARING 11.10.2012 DATE OF PRONOUNCEMENT 30.11.2012 O R D E R PER SANJAY ARORA, ACCOUNTANT MEMBER: THIS IS AN APPEAL BY THE ASSESSEE, DIRECTED AGAINST THE ORDER DATED 20/01/2012 BY THE COMMISSIONER OF INCOME-TAX (APPEALS)-IV, HYDERA BAD (CIT(A) FOR SHORT), CONFIRMING THE LEVY OF PENALTY UNDER SECTION 271(1) (C) OF THE INCOME TAX ACT, 1961 (THE ACT HEREINAFTER) FOR ASSESSMENT YEAR (A.Y) 2007-08 BY THE ASSESSING OFFICER (A.O) VIDE ORDER DATED 30/6/2010. 2.1 OPENING THE ARGUMENTS FOR AND ON BEHALF OF THE ASSESSEE, IT WAS SUBMITTED BY THE LD. A.R., HIS COUNSEL, THAT THE ASSESSEE, ON BEING CONF RONTED WITH THE DOCUMENT FOR PURCHASE OF PROPERTY, CONCEDED TO THE TRUTH OF THE SAID DOCU MENT AND, CONSEQUENTLY, TO THAT OF THE CONSIDERATION STATED THEREIN. HOWEVER, AS THE SAME WAS IN EXCESS OF THE AMOUNT AS ITA NO. 415/HYD/2012 M/S. UNI ESTATES, HYDERABAD. 2 2 REFLECTED IN THE ASSESSEES BOOKS OF ACCOUNTS, HE A GREED TO SURRENDER THE BALANCE AS HIS INCOME FOR THE RELEVANT YEAR. ACCORDINGLY, A REVIS ED RETURN WAS FILED, ADMITTING THE DECLARED INCOME, AND TAX THEREON PAID. THE REVENUE THEREAFTER HAS SOUGHT TO LEVY PENALTY UNDER SECTION 271(1)(C) OF THE ACT THEREON. WHEN EN QUIRED ABOUT THE ASSESSEES EXPLANATION FOR THE SHORTFALL AS RECORDED IN HIS BO OKS OF ACCOUNTS, HE WOULD SUBMIT THAT IT NEEDS TO BE APPRECIATED THAT IN REALITY THE AMOUNT (PURCHASE CONSIDERATION) IS PAID ON THE BASIS OF SUMS RECEIVED FROM SEVERAL PERSONS, THE PR OPOSED BUYERS OF THE PROPERTY. HOWEVER, AS IS NORMALLY THE CASE, SUCH PERSONS, WHI LE ADVANCING THE MONEY, WITHHOLD THE NAMES UNDER WHICH THE SAME IS TO BE RECORDED, STATI NG THEY WOULD BE SUPPLIED SUBSEQUENTLY. THE PROPERTY IN ANY CASE HAS TO BE PU RCHASED WITHIN THE AGREED/STIPULATED TIME SCHEDULE, SO THAT THE AMOUNT BEING AVAILABLE, THE TRANSACTION IS CARRIED OUT. THIS HAS RESULTED IN THE IMPUGNED GAP, SO THAT WHILE THE STA TED CONSIDERATION PER THE DOCUMENT IS RS. 164.60 LAKHS, THAT RECORDED IN THE ASSESSEES B OOKS, FOR WANT OF SUPPLY OF THE SAID NAMES, WAS ONLY RS.60 LAKHS. THE REVENUE NEEDS TO A PPRECIATE, HE CONTINUED, THAT THOUGH OWNED BY THE ASSESSEE AS A PURCHASER OF THE PROPERT Y, MONEY DOES NOT FLOW FROM HIM OR REPRESENTS HIS UNDISCLOSED INCOME, WHICH IN ANY CAS E STANDS ADMITTED UNDER THE CIRCUMSTANCES OF THE CASE. LEVY OF PENALTY AMOUNTS TO PENALIZING THE ASSESSEE FOR WHAT WAS ESSENTIALLY A CONCILIATORY BEHAVIOR ON HIS PART . RELIANCE WAS PLACED BY HIM IN THE CASE OF CIT V. SURESH CHANDRA MITTAL [2001] 251 ITR 9 (SC) AND CIT V. SAS PHARMACEUTICALS (DELHI) (IN ITA NO.1058 OF 2009 DATED 08/4/2011, CO PY ON RECORD/ REPORTED AT 335 ITR 259), SO THAT WHERE A DECLARATION IS MADE TO BUY PE ACE WITH THE REVENUE, THE SAME MAY NOT NECESSARILY RESULT IN LEVY OF PENALTY EVEN IF T HE ASSESSEE IS UNABLE TO SUBSTANTIATE HIS CASE OR EXPLANATION. 2.2 THE LD. CIT-DR, ON THE OTHER HAND, WOULD SU BMIT THAT IF PENALTY IS NOT LEVIABLE IN SUCH A CLEAR CASE OF CONCEALMENT OF INCOME, WHERE C OULD IT AT ALL BE LEVIED. THE ASSESSEE ACCEPTED THE DOCUMENT ONLY BECAUSE IT WAS A REGISTE RED DOCUMENT, BEARING SIGNATURES OF SEVERAL PERSONS, INCLUDING THE ASSESSEE HIMSELF. HOW COULD HE DENY THE TRUTH OF THE ITA NO. 415/HYD/2012 M/S. UNI ESTATES, HYDERABAD. 3 3 TRANSACTION OR BUT NOT CONFIRM IT ? AS REGARDS THE EXPLANATION QUA THE RECEIPT OF MONEY FROM THE BUYERS OF THE PROPERTY, THE SAME IS TO N O CONSEQUENCE AS THE ASSESSEES BOOKS OF ACCOUNT REFLECT THE PURCHASE COST AT A MUCH LOWER F IGURE, RS.104.60 LAKHS TO BE PRECISE, OF WHICH, AGAIN, ONLY RS.100 LAKHS WAS CONCEDED PER TH E REVISED RETURN, THOUGH THE ASSESSMENT WAS MADE BY INCLUDING THE TOTAL DIFFEREN CE OF RS.104.60 LAKHS; THE ASSESSEE HAVING NO EXPLANATION FOR THE DIFFERENCE OF RS. 4.6 0 LACS EXCLUDED TO BE RETURNED SUBSEQUENT TO HIS ADMISSION. UNDER THE CIRCUMSTANCE S, BOTH THE CASES CITED BY THE LD. A.R. ARE DISTINGUISHABLE ON FACTS, AND WOULD NOT COME TO HIS ASSISTANCE. 3. WE HAVE HEARD THE PARTIES, AND PERUSED THE MAT ERIAL ON RECORD. 3.1 THE PRIMARY FACTS OF THE CASE ARE ADMITTED AN D NOT IN DISPUTE. THE ASSESSEE PAID ONE, M/S. PARUPATI FARMS RS.164.60 LAKHS IN CASH TOWARD IMMOVABLE PROPERTY VIDE AN AGREEMENT TO SELL CUM GPA DATED 23/6/2006, DULY REG ISTERED. THE COPY OF THE SAID DOCUMENT IS NOT ON RECORD, EVEN THOUGH ADMITTEDLY I T VESTS THE PROPERTY THEREIN IN THE ASSESSEE AND ASSESSEE ONLY, WITH THERE BEING NO MEN TION OF THE INTEREST OF ANY OTHER PERSON THEREIN OR CREATED BY VIRTUE OF THE SAID PURCHASE. THE ASSESSEE, THUS, HAS PURCHASED THE SAID PROPERTY IN HIS OWN RIGHT AS AN ABSOLUTE OWNER. HOW COULD IT, UNDER THE CIRCUMSTANCES, ALLUDE TO DIFFERENT (UNSPECIFIED) BUYERS ? THAT, IF AT ALL THERE IS SUCH AN ARRANGEMENT, IS INTERNAL TO THE ASSESSEE, TO WHICH NO COGNIZANCE IN LAW CAN BE ACCORDED. THE ONLY QUESTION, THUS, THAT IS RELEVANT IS THE EXPLANATION , IF ANY, FOR THE SOURCE OF THE BALANCE, UNRECORDED CONSIDERATION OF RS.104.60 LAKHS, BEING NOT RECORDED IN THE BOOKS OF ACCOUNTS MAINTAINED BY THE ASSESSEE TOWARD ITS KNOWN SOURCES OF INCOME. IN FACT, THE MOOT QUESTION, AND WHICH THE ASSESSEES EXPLANATION DOES NOT ANSWER, IS: WHY DID NOT THE ASSESSEE RECORD THE ACTUAL OR THE STATED CONSIDERAT ION IN HIS ACCOUNTS ? THIS IS AS RECEIPT OF MONIES FROM SEVERAL PERSONS INTERESTED IN THE LAND, AS CLAIMED, WOULD NOT IN ANY MANNER GO TO REDUCE ITS COST OF ACQUISITION, BUT ONLY GO T O FINANCE IT. THE ANSWER IS AGAIN OBVIOUS: TO ESCAPE ACCOUNTING FOR AND CONSEQUENTLY EXPLAININ G THE ADDITIONAL AMOUNT GENERATED, ITA NO. 415/HYD/2012 M/S. UNI ESTATES, HYDERABAD. 4 4 I.E., AS TO ITS NATURE AND SOURCE. THE ASSESSEES A DMISSION VIDE STATEMENT OF ITS PARTNER, SRI M.T.V. RAMANA, UNDER SECTION 131 OF THE ACT DATED 1 9/12/2008, FOLLOWED BY THE FILING OF THE RETURN FOR THE YEAR OFFERING ADDITIONAL INCOME FOR RS.100 LAKHS ON 31/3/2009, IS IN FACT AN ACCEPTANCE OF THE FACT THAT IT HAS NO EXPLANATIO N FOR THE SOURCE, OR AT LEAST TO THAT EXTENT. THERE IS NO QUESTION THUS OF THE ADMISSION BEING UN DER DURESS. EVEN FOR THE BALANCE, UNRETURNED SUM OF RS.4.60 LAKHS, FOR WHICH ASSESSEE CAN, ON THE BASIS OF HIS RETURN, BE CONSIDERED AS HAVING RETRACTED, FAILED TO FURNISH A NY EXPLANATION, SO THAT THE SAME STOOD ALSO ADDED, AND WHICH AMOUNT, AGAIN, HAS NOT BEEN D ISPUTED AND ACCEPTED BY THE ASSESSEE. 3.2 THE ONLY QUESTION THAT THUS SURVIVES IS AS TO WHETHER THE ASSESSEE HAS, IN THE PENALTY PROCEEDINGS, OFFERED ANY EXPLANATION TOWARD SHORTFA LL IN THE RECORDED CONSIDERATION WITH REFERENCE TO THE ACTUAL CONSIDERATION, I.E., RS.104 .60 LAKHS AND, IF SO, MERITS THEREOF. WE FIND NONE. WHAT THE ASSESSEE STATES BY WAY OF MONIE S RECEIVED AS ADVANCE FROM SOME PERSONS, WHOSE NAMES THOUGH STAND NOT DIVULGED BY H IM, IS SOMETHING DIFFERENT AND CONTRARY TO THE RECORD, VIZ. THE PURCHASE DEED DUL Y REGISTERED; THE ASSESSEES BOOKS OF ACCOUNTS; HIS ADMISSION VIDE STATEMENT ON OATH UNDE R SECTION 131 OF THE ACT; AND SUBSEQUENT RETURN UNDER SECTION148. IN FACT, THE S AME WOULD AMOUNT TO A RETRACTION, WHICH, THOUGH NOT BARRED BY LAW AT ANY STAGE, AS TH ERE IS NO ESTOPPEL AGAINST TRUTH, WOULD ITSELF REQUIRE TO BE TESTED FOR ADMISSION. WHY DID THE ASSESSEE NOT REVEAL THE TRUTH IN THE FIRST PLACE ? WHAT IS THE MISTAKEN PLEA OF FACT/S THAT LEAD TO TH E ADMISSION, WHICH STANDS IN FACT ACTED UPON, FOR MOST PART ? THE RETURN WAS IN FACT ITSELF FILED ONLY ON 31/3 /2009, I.E., OVER THREE MONTHS AFTER THE DEPOSITION UNDER SECTIO N 131 OF THE ACT, AND WHICH VARIES FROM THE FORMER ONLY TO THE EXTENT OF RS.4.60 LAKHS (OUT OF TOTAL DIFFERENCE OF RS.104.60 LAKHS), AND TOWARD WHICH, AGAIN, THE ASSESSEE COULD NOT FUR NISH ANY EXPLANATION IN THE ASSESSMENT PROCEEDINGS, AND ACCEPTED WITHOUT DEMUR ITS ASSESSM ENT AS HIS INCOME. THE ASSESSEE HAS CLEARLY FAILED TO DISCHARGE THE ONUS THAT LAY ON HI M IN THIS REGARD, I.E., QUA RETRACTION. NO CASE FOR ADMISSION OR ACCEPTANCE OF RETRACTION, THA T IS, ON MERITS, IS MADE OUT; THE ASSESSEE SUPPLYING NO REASON TO DOUBT THE TRUTH AND VERACITY OF HIS ADMISSION CONFIRMING THE ITA NO. 415/HYD/2012 M/S. UNI ESTATES, HYDERABAD. 5 5 PURCHASE OF PROPERTY UNDER REFERENCE BY HIM AT THE STATED CONSIDERATION. THE REFERENCE BY THE LD. CIT(A) TO THE DECISION IN THE CASE OF WESTERN AUTOMOBILES (INDIA) V. CIT , 112 ITR 1048 (BOM.) IS APPOSITE, EVEN AS THE DECISION IN TH E CASE OF CIT V. RAMDAS PHARMACY , 77 ITR 276 (MAD.) ALSO COMES READILY TO MIND. FURTHER, EVEN ADMITTING THE SAME (RETRACTION), THAT IS, FOR THE SAKE OF ARGUMENT, THE NEW EXPLANAT ION SHALL HAVE TO BE EXAMINED ON ITS MERITS. THE SAME IS NOT ONLY INCONSISTENT WITH THE MATERIAL ON RECORD (ENUMERATED SUPRA), BUT ALSO DE HORS ANY MATERIAL ON RECORD (AND WHICH HAS BEEN FOUND B Y US AS REPRESENTING THE TRUTH). IN FACT, THE SAME WOULD GIVE RISE TO A T A FRESH SET OF QUESTIONS, VIZ. WHY IS THE SAME NOT RECORDED, AS THEIR INTEREST IN THE PROPERT Y CANNOT BE EITHER ENSURED OR EVEN PRESUMED OTHERWISE? WHY WERE NO RECEIPTS ISSUED, AS THE MONEY WOULD ONLY BE DULY RECEIPTED AND, IN ANY CASE, WARRANT BEING DOCUMENTE D AND CANNOT - AS IS BEING MADE OUT, BE DE HORS ANY DOCUMENT? HAS THE PROPERTY (OR PART THEREOF) B EEN SUBSEQUENTLY TRANSFERRED TO THEM, AND IF SO, HOW AND AT WHAT PRICE? IS THE AMOUNT SOURCED FROM THEM UNIFORM, IN WHICH CASE THE ACTION IS ONLY DELIBERATE? CLEARLY, THERE IS NOTHING ON RECORD FOR US TO ADDRESS THESE QUESTIONS THAT FOLLOW AS A DIRECT COR OLLARY TO THE ASSESSEES EXPLANATION. AS SUCH, NEITHER IS THE RETRACTION, UNDER THE CIRCUMST ANCES, ADMISSIBLE NOR BACKED BY ANY CREDIBLE MATERIAL/EVIDENCE, APART FROM THE FACT THA T, AS AFORESAID, IT IS WITHOUT LEGAL BASIS, FOR US TO ACCORD ANY WEIGHT THERETO. 3.3 THE ASSESSEE, AS WOULD BE APPARENT FROM THE FOREGOING, HAS NOT OFFERED ANY EXPLANATION, MUCH LESS A BONA FIDE ONE, WITH REGARD TO THE OMISSION IN NOT RECORDING THE STATED, WHICH IS ADMITTEDLY THE FULL CONSIDERATION, IN ITS REGULAR BOOKS OF ACCOUNTS. THE ENTIRE AMOUNT BEING PAID IN CASH, EVEN IF THE ASSES SEE, IF WE MAY SO INFER, AVAILED OF UNACCOUNTED MONEY TO FINANCE THE PURCHASE TRANSACTI ON, IT IS ONLY THE ASSESSEE WHO IS LIABLE TO ACCOUNT FOR OR EXPLAIN THE DIFFERENCE IN VIEW OF THE CLEAR PROVISION OF LAW. FURTHER, UNLESS HE ESTABLISHES THE INTEREST OF THOS E PERSONS, OR EVEN A DIFFERENT SET OF PERSONS, IN THE IMMOVABLE PROPERTY (I.P.), PER THE SAID REGISTERED DOCUMENT, NO BONA FIDES COULD BE ASCRIBED TO ITS EXPLANATION. THE ADDITION TO THE INCOME (AS ORIGINALLY RETURNED) ITA NO. 415/HYD/2012 M/S. UNI ESTATES, HYDERABAD. 6 6 WOULD EITHER BE UNDER SECTION 69B OR 69C AND NOT UN DER SECTION 68, AS IT IS NOT A CASE OF UNEXPLAINED CREDIT. 3.4 IT IS TRITE LAW THAT THE CHARGE OF PENALTY IS WITH REFERENCE TO THE ORIGINAL RETURN, AND TOWARD WHICH THE LD. CIT HAS HIMSELF CITED SOME DEC ISIONS, VIZ. HENRY ISIDORE V. CIT , 222 ITR 496 (MAD.); CIT V. K. MAHIM , 149 ITR 737 (KER.); ADDL. CIT V. RADHEY SHYAM , 123 ITR 125 (ALL.). MORE RECENTLY, THE HONBLE DELHI HI GH COURT HAS ALSO CLARIFIED ON THIS ASPECT IN THE CASE OF CIT V. USHA INTERNATIONAL LTD . (IN ITA NO. 1696 OF 2006 DATED 05/11/2012), DISTINGUISHING ITS DECISION IN THE CAS E OF CIT V. SAS PHARMACEUTICALS (SUPRA). IN FACT EVEN NO ARGUMENT WAS MADE BY THE LD. A.R. O N THIS COUNT, WITH THE LD. D.R. STATING TO ADMISSION BY THE LD. A.R. THAT THE SUBSEQUEN T RETURN, THOUGH LOOSELY TERMED AS REVISED, IS NOT A REVISED RETURN UNDER THE LAW (S ECTION 139(5) OF THE ACT), BUT A RETURN FURNISHED CONSEQUENT TO DETECTION, FOLLOWED BY ADMI SSION, SO THAT ITS FURNISHING CANNOT BE REGARDED AS A VOLUNTARY ACT ON THE ASSESSEES PART; WHICH THOUGH SAVES PENALTY, ESTABLISHING THE ASSESSEES BONA FIDES . IT IS THIS, THAT IS, LACK OF BONA FIDES , THAT THE LAW SEEKS TO PENALIZE, AND WHICH WOULD NOT STAND TO BE PROVED MERELY BY THE FACT OF ADMISSION AND ACTING THEREON, WHICH RATHER BECOMES LARGELY IN CONSEQUENTIAL IN THE FACE OF UNCONVERTIBLE EVIDENCE. THE ASSESSEES CLAIM OF THE PENALTY BEING NOT EXIGIBLE IN VIEW OF THE ACCEPTANCE OF ITS REVISED RETURN, AS RAISED P ER ITS ADDITIONAL GROUND, IS THUS ALSO NOT VALID. 3.5 IN VIEW OF THE FOREGOING, WE SEE NO REASON T O INTERFERE WITH THE IMPUGNED ORDER; PENALTY HAVING BEEN, AS FOUND BY US, LEVIED ON THE BASIS OF CONFIRMED FACTS AND IN CONSISTENCE WITH LAW. HERE IT WOULD ALSO BE RELEVA NT TO ADVERT TO TWO DECISIONS CITED AT BAR BY THE LD. A.R. DURING THE HEARING. THE FIRST, I.E ., IN THE CASE OF CIT V. SURESH CHANDRA MITTAL (SUPRA), FOLLOWS THE PREMISES THAT WHERE ADMISSION IS MADE ONLY TO PURCHASE PEACE, THE SAME MAY NOT LEAD TO LEVY OF PENALTY. IN THE I NSTANT CASE, HOWEVER, THERE IS NO SCOPE OF APPLICATION OF THE SAID PRINCIPLE; THE ASSESSEES A DMISSION BEING IMPELLED BY THE RECOVERY ITA NO. 415/HYD/2012 M/S. UNI ESTATES, HYDERABAD. 7 7 OF A REGISTERED (PUBLIC) DOCUMENT IN SEARCH FROM TH E PREMISES OF A THIRD PARTY, AND ON BEING REQUIRED TO EXPLAIN THE CONSIDERATION STATED THEREIN. THERE IS NOTHING ON RECORD TO SHOW THAT THE SAID DOCUMENT HAS BEEN DENIED BY THE OTHER TRANSACTING PARTY, THE TRUTH OF THE TRANSACTION IS (ALSO) BORNE BY THE FACT OF IT B EING RECORDED IN THE BOOKS OF ACCOUNT, ALBEIT AT A LOWER AMOUNT. THE SAID DECISION IS, THE REFORE, CLEARLY NOT APPLICABLE. THE SECOND DECISION ( CIT V. SAS PHARMACEUTICALS (SUPRA)), RELATES TO THE RETURN FILED ADMITTING INCOME DECLARED IN SURVEY PROCEEDINGS. WE HAVE ALRE ADY CLARIFIED THAT PENALTY IS TO BE RECKONED WITH REFERENCE TO THE ORIGINAL RETURN (REF ER PARA 3.4). THIS ASPECT OF THE MATTER STANDS ALSO CLARIFIED BY THE HONBLE COURT ITSELF I N IS SUBSEQUENT JUDGMENT IN THE CASE OF CIT V. USHA INTERNATIONAL LTD . (SUPRA). THE SAME BEING FILED ONLY SUBSEQUENT TO THE SURVEY, WHEREAT THE TIME FOR FILING THE SAME HAD NO T LAPSED, THE HONBLE HIGH COURT, IN CONFORMITY WITH LAW, HELD THAT NO PENALTY WITH REFE RENCE TO THE ASSESSEES RETURN IS LEVIABLE. THERE IS CLEARLY NO PARITY OF FACTS WITH THE ASSESSEES RETURN IN THE INSTANT CASE, THAT IS, QUA WHICH PENALTY IS LEVIED, HAVING BEEN FILED ON 30/1 0/2007, OR MUCH PRIOR TO THE DETECTION OF IT BEING FALSE OR NOT CORRECT DURING T HE SEARCH PROCEEDINGS, AND RECOVERY OF THE RELEVANT PURCHASE DEED. THE SAID CASE, THUS, ALSO HAS NO APPLICATION IN THE FACTS OF THE CASE. 4. IN THE RESULT, THE ASSESSEES APPEAL IS DI SMISSED. ORDER PRONOUNCED IN OPEN COURT ON 30.11.2012 SD/- (SAKTIJIT DEY) SD/- (SANJAY ARORA) JUDICIAL MEMBER ACCOUNTA NT MEMBER DT/- 30 TH NOVEMBER, 2012 COPY FORWARDED TO: 1. M/S. UNI ESTATES. FLAT NO.201, VEERU CASTLE, DWARAK APURI COLONY, PANJAGUTTA, HYDERABAD ITA NO. 415/HYD/2012 M/S. UNI ESTATES, HYDERABAD. 8 8 2. 3. 4 5. ASST. COMMISSIONER OF INCOME-TAX, CIRCLE 6(1), HY DERABAD COMMISSIONER OF INCOME-TAX(APPEALS)-IV, HYDERABAD COMMISSIONER OF INCOME-TAX-III, HYDERABAD DEPARTMENTAL REPRESENTATIVE, ITAT, HYDERABAD.