Tulasi Seeds Private Limited, Guntur V. The Assistant Commissioner of Income Tax, Circle-2(1), , Guntur

ITA 47/VIZ/2020

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 6196 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 7 month(s) 25 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-09-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: 2017-2018
• Appeal Filed On: 31-01-2020
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: D K SONOWAL
• Assessee Lawyers: D BALAJI
• Keywords: Question of law; Set aside
• Section: 13; 68

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM (THROUGH WEB - BASED VIDEO CONFERENCING PLATFORM) . , . . , BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER& SHRI D.S. SUNDER SINGH, ACCOUNTANT MEMBER ./ I.T. A.NO. 521 /VIZ/20 18 ( / A SSESSMENT Y EAR : 20 1 2 - 1 3 ) S.V.N.HOTELS & RESORTS PRIVATE LIMITED D.NO.8 - 12 - 5 LOWER TANK BUND ROAD VIZIANAGARAM [PAN : A AJCS4959E] VS . INCOME TAX OFFICER WARD - 1, VIZIANAGARAM ( / APPELLANT) ( / RESPONDENT) / APPELLANT BY : SHRI D.BALAJI, AR / RESPONDENT BY : SHRI D.K.SONOWAL. CIT DR / DATE OF HEARING : 2 2 .09.2020 / DATE OF PRONOUNCEMENT : 25 .09. 20 20 / O R D E R P ER SHRI D.S.SUNDER SINGH, ACCOUNTANT MEMBER : TH IS APPEAL IS FILED BY THE ASSESSEE AGAINST THE ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS) [CIT(A)] - 1 , VISAKHAPATNAM IN ITA NO. 005 9 / 20 1 5 - 1 6 / ITO / WD - 1,VZM /201 6 - 17 DATED 26 . 0 7 .201 8 FOR THE ASSESSMENT YEAR (A.Y.) 2012 - 13. 2 I.T.A. NO .521 /VIZ/20 18 , A.Y.201 2 - 1 3 S.V.N.HOTELS & RESORTS PVT. LTD., VIZIANAGARAM 2. ALL THE GROUNDS OF APPEAL ARE RELATED TO SUSTAINING THE ADDITION MADE BY THE ASSESSING OFFICER (AO) U/S 68 OF THE INCOME TAX ACT, 1961 (IN SHORT ACT). 3. THE ASSESSE E FILED THE RETURN OF INCOME DECLARING TOTAL INCOME OF RS.14,59,785/ - WHICH WAS SET OFF AGAINST THE LOSS OF EARLIER YEARS. DURI NG THE COURSE OF ASSESSMENT PROCEEDINGS, THE AO FOUND THAT THE ASSESSEE HAS ALLOTTED 3 ,00,000 EQUITY SHARES OF RS.10 EACH AT A PREMIUM OF RS.90 PER SHARE TO M/S CHARANSHEELA CONSULTAN TS P.LTD, 2, HARALAL DAS LANE, J ORABAGAN PARK (W), KOLKATA, WEST BENGAL. THE SHARE CAPITAL OF RS.3 ,00,00,000/ - COMPRISES OF SHARE CAPITAL OF RS.30,00,000 AND THE SHARE PREMIUM OF RS.2,70,00,000/ - . THE SAID AMOUNT OF RS.3 .00 CRORES WAS RECEIVED BY THE ASSESSEE IN THE FINANCIAL YEAR ( F.Y . ) 2008 - 09 AND SHARES WERE ALLOTTED DURING THE F.Y. 2011 - 12 RELEVANT TO THE A.Y.2012 - 13. THEREFORE, THE AO ASKED THE ASSESSEE TO EXPLAIN AS TO WHY THE SAME SHOULD NOT BE TREATED AS INCOME U/S 68 OF THE ACT. THE ASSESSEE FILED THE DETAILS CALLED FOR BY THE ASSESSING OFFICER SUCH AS COPY OF RETURN OF INCOME OF M/S CHARANSHEELA CONSULTANCY P.LTD AND FINANCIAL STATEMENTS EXPLAINING THE SOURCE AND THE NATURE OF TRANSACTION . THE ASSESSEE OBJECTED FOR ADDITION OF RS.3 .00 CRORES IN THE IMPUGNED ASSESSMENT YEAR, SINCE , THE ASSESSEE HAD RECEIVED MONEY 3 I.T.A. NO .521 /VIZ/20 18 , A.Y.201 2 - 1 3 S.V.N.HOTELS & RESORTS PVT. LTD., VIZIANAGARAM THROUGH BANKING CHANNELS AND DULY RECORDED IN THE BOOKS OF THE ASSESSEE AS WELL AS THE INVESTOR COMPANY AND ALSO OBJECTED FOR TAXING THE AMOUNT IN A.Y.2012 - 13 AGAINST THE ACTUAL RECEIPT OF MONEY IN THE F.Y.2008 - 09, RELEVANT TO THE A.Y.2009 - 10. THE A O NOT BEING IMPRESSED WITH THE EXPLANATION OF THE ASSESSEE MADE THE ADDITION OF RS.3 ,00,00,000/ - U/S 68 OF THE ACT. 4. AGAINST THE ORDER OF THE AO, THE ASSESSEE WENT ON APPEAL BEFORE THE CIT(A) AND CHALLENGED THE VALIDITY OF MAKING THE ADDITION IN THE A.Y.2012 - 13 AGAINST THE CREDIT MADE IN THE BOOKS OF ACCOUNTS IN THE F.Y.2008 - 09 RELEVANT TO THE A.Y.2009 - 10. A CCORDING TO T HE ASSESSEE, THE AO IS NOT PERMITTED TO MAKE THE ADDITION IN THE A.Y.2012 - 13 SINCE THE MONEY WAS RECEIVED AND FOUND CREDITED IN THE F.Y. 2008 - 09, RELEVANT TO THE A.Y.2009 - 10. THE LD.CIT(A) WAS NOT CONVINCED WITH THE ARGUMENT OF THE ASSESSEE AND CONFIRMED THE ADDITION MADE BY THE AO SINCE , THE INVESTOR COMPANY FOUND TO BE HAVING NO CREDIT WORTHINESS. T HE ASSESSE E MADE DETAILED ARGUMENT IN THEIR WRITTEN SUBMISSIONS CHALLENGING THE TAXABILITY OF THE SUM IN THE IMPUGNED ASSESSMENT YEAR INSTEAD OF 2008 - 09 .THE SUBMISSIONS MADE BY THE ASSES S EE BEFORE THE LD.CIT(A) READS AS UNDER: THE PAPERS BEFORE THE LAO CLEARLY SHOW THAT THE ACTUAL FUNDS WERE RECEIVED IN THE FINANCIAL YEAR FY 2008 - 09 RELEVANT TO THE ASSESSMENT YEAR 2009 - 10. IT IS ALSO CLEAR FROM THE LAO'S OWN OBSERVATION IN PARA - 2 OF THE ASSESSMENT ORDER WHERE HE 4 I.T.A. NO .521 /VIZ/20 18 , A.Y.201 2 - 1 3 S.V.N.HOTELS & RESORTS PVT. LTD., VIZIANAGARAM OBSERVED THAT 'THE SAID AMOUNT IS RECEIVED IN FY 2008 - 09 AND THE SHARES HAVE BEEN ALLOTTED ONLY DURING THE FINANCIAL YEAR 2011 - 12 RELEVANT TO THE ASSESSMENT YEAR 12 - 13' SECTION 68, AS IT WAS IN THE A SSESS MENT YEAR 2012 - 13, IS REPRODUCED BELOW 68 - CASH CREDITS: WHERE ANY SUM IS FOUND CREDITED IN THE BOOKS OF THE ASSESSEE MAINTAINED FOR ANY PREVIOUS YEAR; AND ASSESSEE OFFERS NO EXPLANATION ABOUT THE NATURE AND SOURCES THEREOF OR THE EXPLANATION OFFERED BY HIM IS NOT, IN THE OPINION OF THE ASSESSING OFFICER, SATISFACTORY, THE SUM SO CREDITED MAY BE CHAR GED TO INCOME - TAX AS THE INCOME OF THE ASSESSEE IN THE PREVIOUS YEAR.' IT IS WELL SETTLED THAT THE AMOUNT RECEIVED AND CREDITED IN THE PREVIOUS YEAR RELEVANT TO THE ASSESSMENT YEAR ONLY CAN BE CONSIDERED U/S 68. THE HONBLE DELHI HIGH COURT IN 'CIT VS USHA STUD AGRICULTURAL FARMS LTD REPORTED IN 301 ITR 0384 (DELHI), HELD THAT NO ADDITIONS U/S 68 CAN BE SUSTAINED SINCE THERE IS A FINDING RECORDED BY THE COMMISSIONER (APPEALS) THAT THE CREDIT BALANCE APPEARING IN THE ACCOUNTS OF THE ASSESSEE DOES NOT PE RTAIN TO THE YEAR UNDER CONSIDERATION. THE HON'BLE HIGH COURT FURTHER HELD THAT THE ORDER OF THE TRIBUNAL WHICH UPHELD THE ORDER OF THE COMMISSIONER (APPEALS) DOES NOT GIVE RISE TO A QUESTION OF LAW, MUCH LESS A SUBSTANTIAL QUESTION OF LAW. (ANNEXURE -- 5) IN ANOTHER CASE REPORTED IN THE SAME 301 ITR AT PAGE 404, THE RAJASTHAN HIGH COURT HAD AN OCCASION TO EXAMINE AN INSTANCE WHERE THE ADDITION OF CASH CREDIT WAS MADE IN A SUBSEQUENT YEAR AND NOT IN THE YEAR IT WAS GENERATED. WITHOUT FURTHER GOING INTO THE COLLATERAL DETAILS, THE HONBLE COURT OBSERVED THAT 'IT DOES NOT REQUIRE ANY ELABORATE ARGUMENT THAT A CARRIED FORWARD AMOUNT OF THE PREVIOUS YEAR DOES NOT BECOME AN INVESTMENT OR CASH CREDIT GENERATED DURING THE RELEVANT YEAR 1993 - 1994. THIS ALONE IS SUFF ICIENT TO SUSTAIN THE ORDER OF THE TRIBUNAL IN DELETING THE AMOUNT OF RS. 1,55,316 / - FROM THE ASSESSMENT FOR AY 1993 - 94.' (CIT VS. PARMESHWAR BOHRA) (ANNEXURE - 6). 21. IN ANOTHER CASE DECIDED BY THE JURISDICTIONAL BENCH OF THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM (REPORTED IN 2016 (8) TMI 469, ITA NO. 594/VIZAG/2014) HAS UPHELD THE ORDER OF THE COMMISSIONER (APPEALS) IN A CASE WHERE THE ADDITION WAS IN RESPECT OF CREDITS TRANSFERRED BY WAY OF JOURNAL ENTRIES OF AMOUNTS RECEIVED IN EARLIER YE AR AND WHERE NO FRESH BORROWINGS WERE THERE IN THE SUBJECT ASSESSMENT YEAR. COPY OF THE JUDGEMENT IS ENCLOSED AS ANUEXU - 7. THE IMPUGNED ADDITION REQUIRES TO BE DELETED ON THIS GROUND ALONE. HOWEVER, THE ASSESSEE MADE SUBMISSIONS IN RESPECT OF ALL THE OBSER VATIONS OF THE LAO WITH A VIEW OF NOT TO SEEM TO BE TAKING SHELTER ON SOME TECHNICAL GROUND. 5 I.T.A. NO .521 /VIZ/20 18 , A.Y.201 2 - 1 3 S.V.N.HOTELS & RESORTS PVT. LTD., VIZIANAGARAM T HE LD.CIT(A) DID NOT FIND MERIT IN THE ARGUMENT OF THE ASSESSE E AND CONFIRMED THE ADDITION AND DISMISSED THE APPEAL OF THE ASSESS E E. 5. AGAINST WHICH THE ASSESSEE FILED APPEAL BEFORE THIS TRIBUNAL. DURING THE APPEAL HEARING, THE LD.AR CHALLENGING THE ORDER OF LD.CIT(A) IN GROUND NO.2 AND 3 ARGUED THAT IN THE INSTANT CASE, THE AMOUNT WAS RECEIVED IN THE F.Y. 2008 - 09 RELEVANT TO THE A.Y 200 9 - 10 AND THE SHARES WERE ALLOTTED DURING THE F.Y. 2011 - 1 2 , RELEVANT TO THE A.Y. 2012 - 13. THEREFORE, ARGUED THAT AS PER THE PROVISIONS OF SECTION 68 OF THE ACT, THE ADDITION REQUIRED TO BE MADE IN THE YEAR IN WHICH THE CREDITS WERE FOUND CREDITED IN THE BO OKS OF ACCOUNTS BUT NOT IN LATER YEARS . THEREFORE, ARGUED THAT SINCE , NO CREDIT WAS MADE IN THE YEAR UNDER CONSIDERATION, THERE IS NO CASE FOR MAKING THE ADDITION IN THE HANDS OF THE ASSESSEE U/S 68 OF THE ACT. HENCE ARGUED THAT THE ORDER OF THE LD.CIT(A ) BE SET ASIDE AND THE ADDITION BE DELETED. 6. ON THE OTHER HAND, THE LD.DR VEHEMENTLY SUPPORTED THE ORDERS OF THE LOWER AUTHORITIES AND ARGUED THAT IN THE INSTANT CASE, THE SHARE APPLICATION MONEY WAS RECEIVED FROM THE COMPANY WHICH IS HAVING NO NET WORT H, HENCE, SUBMITTED THAT THE SOURCE OF SHARE CAPITAL WAS NEITHER GENUINE NOR THE COMPANY IS HAVING NET WORTH THUS , ARGUED THAT NO INTERFERENCE IS CALLED 6 I.T.A. NO .521 /VIZ/20 18 , A.Y.201 2 - 1 3 S.V.N.HOTELS & RESORTS PVT. LTD., VIZIANAGARAM FOR IN THE ORDERS OF THE LOWER AUTHORITIES AND HENCE REQUESTED TO UPHOLD THE ORDER OF THE LD.CIT(A) AND DISMISS THE APPEAL OF THE ASSESSEE . 7. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE MATERIAL PLACED ON RECORD. THE SHORT ISSUE INVOLVED IN THE CASE IS THE YEAR IN WHICH THE ADDITION U/S 68 REQUIRED TO BE MADE. IN THIS CONNECTION IT IS RELEVANT TO EXTRACT SECTION 68 OF I NCOME T AX A CT WHICH READS AS UNDER: CASH CREDITS. 68. WHERE ANY SUM IS FOUND CREDITED IN THE BOOKS OF AN ASSESSEE MAINTAINED FOR ANY PREVIOUS YEAR, AND THE ASSESSEE OFFERS NO EXPLANATION ABOUT THE NATURE AND SOURCE THEREOF OR THE EXPLANATION OFFERED BY HIM IS NOT, IN THE OPINION OF THE ASSESSING OFFICER, SATISFACTORY, THE SUM SO CREDITED MAY BE CHARGED TO INCOME - TAX AS THE INCOME OF THE ASSESSEE OF THAT PREVIOUS YEAR : FROM PLAIN READING OF SECTION 68, IT IS CLEAR THAT ANY SUM FOUN D CREDITED IN THE BOOKS OF THE ASSESSEE FOR WHICH NO EXPLANATION WAS OFFERED, THE SAID SUM REQUIRED TO BE BROUGHT TO TAX U/ S 68 IN THAT PREVIOUS YEAR. IN THE INSTANT CASE, THE AMOUNT OF RS.3 .00 CRORES WAS RECEIVED BY THE ASSESSEE IN THE F.Y.2008 - 09 AND ON LY THE JOURNAL ENTRY WAS MADE CONVERTING THE SHARE APPLICATION MONEY IN TO S HARE CAPITAL IN THE F.Y.2011 - 12 RELEVANT TO THE A.Y.2012 - 13 THUS NO MONEY WAS RECEIVED IN THE IMPUGNED ASSESSMENT YEAR. HENCE, THE SUMS FOUND CREDITED IN THE BOOKS OF ACCOUNTS REQUI RED TO BE BROUGHT TO TAX IN THE YEAR IN WHICH SAID SUM WAS FOUND CREDITED IN THE BOOKS OF ACCOUNTS , B UT NOT IN THE SUBSEQUENT YEARS. THE ASSESSEE RELIED ON THE DECISION OF HONBLE DELHI HIGH COURT IN THE CASE OF USHA STUD 7 I.T.A. NO .521 /VIZ/20 18 , A.Y.201 2 - 1 3 S.V.N.HOTELS & RESORTS PVT. LTD., VIZIANAGARAM AGRICULTURAL FARMS LTD. REPORTE D IN 301 ITR 0384 (DELHI) AND THE DECISION OF HONBLE RAJASTHAN HIGH COURT IN 301 ITR 404 AND THE DECISION OF THIS TRIBUNAL IN 2016 (8) TMI 469 AND ITA NO.594/VIZ/2014. FOR THE SAKE OF CLARITY AND CONVENIENCE, WE EXTRACT RELEVANT PART OF THE ORDER OF TH IS TRIBUNAL IN ITA NO.594/VIZ/2014 WHICH READS AS UNDER : 6. WE HAVE HEARD BOTH THE PARTIES, PERUSED THE MATERIALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHORITIES BELOW. THE A.O. MADE ADDITIONS U/S 68 OF THE ACT TOWARDS UNSECURED LOANS . THE A.O. WAS OF THE OPINION THAT THE ASSESSEE HAS NOT PROVED THE GENUINENESS OF THE TRANSACTIONS AND CREDITWORTHINESS OF THE PARTIES IN RESPECT OF THESE 5 CREDITORS OUT OF 9 CREDITORS. THE A.O. FURTHER OBSERVED THAT THE CREDITORS HAVE ADMITTED THAT THEY THEMSELVES HAVE INVESTED THE MONEY IN THE PARTNERSHIP FIRM OUT OF THE BORROWINGS FROM THEIR FRIENDS AND RELATIVES IN LAST 6 MONTHS THAT TOO IN CASH. THE ASSESSEE CLAIMS THAT IT HAS ACCEPTED LOANS FROM VARIOUS INDIVIDUALS DURING THE FINANCIAL YEAR 2008 - 09 AND DURING THIS FINANCIAL YEAR IT HAS RE - GROUPED THE LOANS STANDING IN THE NAME OF VARIOUS INDIVIDUALS INTO THESE 5 PERSONS ACCOUNTS BY PASSING NECESSARY JOURNAL ENTRIES IN THE BOOKS OF ACCOUNTS OF THE FIRM. THERE IS NO FRESH LOAN ACCEPTED DURING THE CU RRENT FINANCIAL YEAR, THEREFORE, THE A.O. WAS NOT CORRECT IN COMING TO THE CONCLUSION THAT THE ASSESSEE HAS ACCEPTED FRESH LOAN DURING THE FINANCIAL YEAR 2009 - 10. 7. THE ISSUE BEFORE US IS UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, THE A.O. WAS RIGHT I N INVOKING THE PROVISIONS OF SECTION 68 OF THE ACT, TO MAKE ADDITION TOWARDS CREDITS BROUGHT FORWARD FROM LAST YEAR. SEC. 68 PROVIDES FOR ADDITION, WHERE ANY SUM IS FOUND CREDITED IN THE BOOKS OF ASSESSEE MAINTAINED FOR THE PREVIOUS YEAR AND THE ASSESSEE O FFERS NO EXPLANATIONS ABOUT THE NATURE AND SOURCE THEREOF, OR EXPLANATIONS OFFERED BY THE ASSESSEE IS NOT IN THE OPINION OF THE A.O. SATISFACTORY, THEN SUM FOUND CREDITED MAY BE CHARGED TO INCOME TAX AS THE INCOME OF THE ASSESSEE OF THAT PREVIOUS YEAR. A PLAIN READING OF SECTION 68 OF THE ACT MAKES IT CLEAR THAT ANY SUM FOUND CREDITED IN THE BOOKS OF ACCOUNTS OF THE ASSESSEE, ASSESSEE OFFERS NO EXPLANATIONS ABOUT NATURE AND SOURCE OF THE CREDITS, THEN THE SUMS FOUND CREDITED IN THE BOOKS OF ACCOUNTS IS TAX ABLE DURING THAT FINANCIAL YEAR. IN THE PRESENT CASE ON HAND, ON PERUSAL OF THE FACTS AVAILABLE ON RECORD, WE NOTICED THAT THE ASSESSEE HAS ACCEPTED LOANS FROM VARIOUS INDIVIDUALS DURING THE PREVIOUS FINANCIAL YEAR 2008 - 09. DURING THE FINANCIAL YEAR 2009 - 1 0 THE ASSESSEE HAS RE - GROUPED THE VARIOUS LOAN ACCOUNTS INTO THESE 5 CREDITORS ACCOUNTS BY PASSING NECESSARY JOURNAL ENTRIES. WE FURTHER NOTICED THAT THERE IS NO FRESH CREDIT ACCEPTED DURING THE CURRENT FINANCIAL YEAR. ALL THE CREDITS ARE TRANSFERRED FR OM THE PREVIOUS FINANCIAL YEAR. 8 I.T.A. NO .521 /VIZ/20 18 , A.Y.201 2 - 1 3 S.V.N.HOTELS & RESORTS PVT. LTD., VIZIANAGARAM THEREFORE, WE ARE OF THE VIEW THAT THE A.O. WAS NOT CORRECT IN MAKING ADDITIONS TOWARDS BROUGHT FORWARD CREDITS DURING THE FINANCIAL YEAR 2009 - 10. THE CIT(A) AFTER CONSIDERING THE RELEVANT DETAILS DELETED THE ADDITIONS MADE BY THE A.O. WE DO NOT SEE ANY ERROR OR INFIRMITY IN THE ORDER PASSED BY THE CIT(A). HENCE, WE INCLINED TO UPHOLD THE CIT(A) ORDER AND DISMISS THE APPEAL FILED BY THE REVENUE. THE DEPARTMENT HAS NOT BROUGHT ANY OTHER DECISION OF SUPERIOR COURT TO CONTROV ERT THE SUBMISSION AND CASE LAWS RELIED UPON BY THE ASSESSEE. THEREFORE, S INCE, THE FACTS ARE IDENTICAL , RESPECTFULLY FOLLOWING THE DECISION OF THIS TRIBUNAL WE HOLD THAT THERE IS NO CASE FOR MAKING ADDITION FOR THE A.Y.2012 - 13 SINCE , THE AMOUNT WAS FOUND CREDITED IN THE BOOKS OF ACCOUNTS OF F.Y.2008 - 09, RELEVANT TO THE A.Y.2009 - 10 . ACCORDINGLY ,WE SET A SIDE THE ORDER OF THE LD.CIT(A) , DELETE THE ADDITION MADE BY THE AO AND ALLOW THE APPEAL OF THE ASSESS E E. 8 . SINCE, WE HAVE ALLOWED THE APPEAL OF THE ASSESSEE IN GROUND NO.2 AND 3, WE CONSIDER IT IS NOT NECESSARY TO ADJUDICATE THE OTHER GROUNDS RAISED BY THE ASSESSEE IN THIS APPEAL. 9. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWED . 9 I.T.A. NO .521 /VIZ/20 18 , A.Y.201 2 - 1 3 S.V.N.HOTELS & RESORTS PVT. LTD., VIZIANAGARAM ORDER PRONOUNCED IN THE OPEN COURT ON 25 TH SEPTEMBER , 2020. S D/ - S D/ - ( . ) ( . . ) (V. DURGA RAO) ( D.S. SUNDER SINGH ) /JUDICIAL MEMBER /ACCOUNTANT MEMBER /DATED : 25 . 0 9 .20 20 L.RAMA, SPS / COPY OF THE ORDER FORWARDED TO : - 1 . / THE ASSESSEE S .V.N.HOTELS & RESORTS PRIVATE LIMITED , D.NO.8 - 12 - 5, LOWER TANK BUND ROAD , VIZIANAGARAM 2 . / THE REVENUE INCOME TAX OFFICER, WARD - 1, VIZIANAGARAM 3. THE PR. COMMISSIONER OF INCOME TAX - 1 , VISAKHAPATNAM 4. THE COMMISSIONER OF INCOME TAX (APPEALS) - 1 , VISAKHAPATNAM 5 . , , / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // SR. PRIVATE SECRETARY ITAT, VISAKHAPATNAM