M/s. Visaka Industries Limited, Sec'bad, Secunderabad V. Addl.. Commissioner of I T, Range-3, Hyderabad

ITA 503/HYD/2012

• Counselvise Citation: 50322514 RSA 2012
• Duration Of Justice: 3 year(s) 7 month(s) 16 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-11-2015
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Next Hearing Date: 04-11-2015
• Assessment Year: 2008-2009
• Appeal Filed On: 10-04-2012
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: B KURMI NAIDU
• Assessee Lawyers: M V ANIL KUMAR
• Keywords: Capital asset; Business income; Business expenditure; Additional evidence; Bad and doubtful debts; Revenue expenditure
• Section: 143(3); 80IB; 37; 2

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SHRI P.MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA NO. 503/HYD/2012 ASSESSMENT YEAR: 2008-09 M/S VISAKA INDUSTRIES LTD., HYDERABAD. PAN AAACV7263K VS. ADDL. COMMISSIONER OF INCOME-TAX, RANGE - 3, HYDERABAD. (APPELLANT) (RESPONDENT) ASSESSEE BY : SHRI M.V, ANIL KUMAR REVENUE BY : SHRI B. KURMI NAIDU DATE OF HEARING : 04-11-2015 DATE OF PRONOUNCEMENT : 27-11-2015 O R D E R PER S. RIFAUR RAHAMAN, A.M.: THIS APPEAL BY ASSESSEE IS DIRECTED AGAINST THE OR DER DATED 31/01/2012 OF LD. CIT(A) IV, HYDERABAD FOR THE A Y 2008-09. 2. BRIEFLY THE FACTS OF THE CASE ARE THAT ASSESSEE IS ENGAGED IN THE BUSINESS OF MANUFACTURE OF ASBESTOS SHEETS, SYNTHET IC BLENDED YARN AND GARMENTS. ASSESSEE FILED ITS RETURN OF INCOME A ND DECLARED TOTAL INCOME OF RS. 16,56,27,491/-. THE ASSESSMENT WAS CO MPLETED U/S 143(3) OF THE INCOME-TAX ACT (ACT) ON 22/12/2010 DE TERMINING TAXABLE INCOME OF RS. 17,37,54,026/-. AO HAD MADE TWO ADDIT IONS, VIZ.: A) DISALLOWANCE OF BAD DEBTS RELATING TO WRITE OFF OF RENTAL ADVANCE. B) OTHER INCOME NOT CONSIDERED FOR ALLOWING DEDU CTION U/S 80IB. 2 ITA NO. 503 /HYD/2012 M/S VISAKA INDUSTRIES LTD. 2.1 THE GROUNDS RAISED BY THE ASSESSEE IN THE APPEA L ARE AS UNDER: 1. THE CIT (A) OUGHT TO HAVE ALLOWED RS. 7,65,028 /- AS BUSINESS EXPENSES UNDER SECTION 37 BEING THE IRRECOVERABLE RENT DEPOSIT MADE EXCLUSIVELY FOR THE PURPOSE OF BUSINESS AND WRITTE N OFF IN THE NORMAL COURSE OF BUSINESS. 2. THE CIT (A) OUGHT TO HAVE APPRECIATED THE FACT THAT IN THE EARLIER YEARS RENT PAID WAS ALLOWED AS REVENUE EXPENSES, THEREFO RE ON THE SAME ANALOGY ADVANCE RENT GIVEN AS RENT DEPOSIT BEING F ORFEITED/ IRRECOVERABLE OUGHT TO HAVE BEEN ALLOWED AS BUSINESS EXPENSES. 3. THE CIT (A) BASED ON THE FACTS OF THE CASE AND CIRCUMSTANCES OF THE CASE SHOULD HAVE ALLOWED THE WRITE OFF OF THE ADVA NCE RENT AS REVENUE EXPENSES IN THE YEAR OF VACATING THE PREMISES TAKE N ON RENT OR TERMINATION OF THE AGREEMENT. 4. THE CIT (A) OUGHT TO HAVE CONSIDERED THE OTHER INCOME IN THE NATURE OF SALE OF SCRAP, CLAIMS ON DAMAGED SHEETS ETC., AS B USINESS INCOME OF THE UNDERTAKING ELIGIBLE FOR DEDUCTION UNDER SECTION 8 0RB OF THE INCOME TAX ACT, 1961. 5. YOUR APPELLANT SUBMITS THAT THE CIT (A) AS WELL AS THE ASSESSING OFFICER OUGHT NOT TO HAVE RESTRICTED THE CLAIM OF DEDUCTIO N UNDER SECTION 80IB OF THE INCOME TAX ACT, 1961, WHEN OTHER INCOME IS BEI NG DERIVED FROM THE BUSINESS OF THE UNDERTAKING. 3. AS REGARDS THE ISSUE RAISED IN GROUND NOS. 1 TO 3 REGARDING DISALLOWANCE OF BAD DEBTS CLAIM OF RS. 7,65,028/- R ELATING TO RENT DEPOSIT, THE ASSESSEE HAD DEBITED RS. 7,65,028/- TO WARDS NON- RECOVERY OF RENT DEPOSIT. SUBSEQUENTLY, IN REPLY TO AOS ENQUIRY, ASSESSEE SUBMITTED A COPY OF THE LEDGER ACCOUNT ALO NG WITH A COPY OF LETTER DATED 20/02/08 ADDRESSED BY IT TO M/S CHETTI PUNYAM PROPERTIES P. LTD. REQUESTING THEM TO RETURN THE SECURITY DEP OSIT. THE AO OBSERVED THAT THE ASSESSEE HAD ONLY WRITTEN A LETTE R IN THE LAST WEEK OF FEBRUARY, 2008 AND THE AMOUNT WAS WRITTEN OFF IN THE MONTH OF MARCH, 2008. HE NOTED THAT AS PER THE LETTER DATED 20/02/08, SRI K. V. SOORIYA NARAYANAN PRESIDENT (CORPORATE) AND COMPANY SECRETARY, HAD CALLED UPON THE SAID PARTY TO PAY THE BALANCE S ECURITY OF RS. 8,50,000 WITHIN 15 DAYS, FAILING WHICH LEGAL ACTION MAY BE INITIATED. THE AO OBSERVED THAT NO INFORMATION WAS FURNISHED BY THE ASSESSEE ON FURTHER ACTION TAKEN FOR RECOVERY OF RENTAL ADVA NCE. HE, THEREFORE, 3 ITA NO. 503 /HYD/2012 M/S VISAKA INDUSTRIES LTD. DISALLOWED THE CLAIM OF THE ASSESSEE TO WRITE OFF THE UNRECOVERED RENTAL ADVANCE. 4. ON APPEAL, BEFORE THE CIT(A), THE AR OF ASSESSEE CONTENDED THAT THE AO HAD NOT DISPUTED THAT THE AMOUNT OF RS. 7,65,028 BEING RENT DEPOSIT WAS NOT RECOVERABLE. HE SUBMITTED THAT THE PREMISES HAD BEEN VACATED AND ALL RENTS WERE ALSO PAID. THE PRE MISES WAS TAKEN FOR THE PURPOSE OF BUSINESS AND SUCH NON-RECOVERY O F DEPOSIT AMOUNTS TO BAD DEBT. THE PAYMENT OF RENTAL DEPOSIT WAS EXCLUSIVELY FOR THE PURPOSE OF BUSINESS AND HENCE ALLOWABLE. 5. AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESSE E, THE CIT(A) OBSERVED THAT THE RENT DEPOSIT PAID WAS NOT DIRECTL Y RELATED TO CARRYING ON OF THE BUSINESS OF THE ASSESSEE NOR THO SE WERE INCIDENTAL TO THE ASSESSEES BUSINESS. HE FURTHER OBSERVED THA T EVEN THOUGH THE RENT DEPOSIT WAS CONNECTED TO THE BUSINESS OF THE A SSESSEE, AND WAS GIVEN FOR THE PURPOSE OF CARRYING ON THE BUSINESS T HEREIN, IT IS CLEAR THAT THE SAME HAD NOT BEEN GIVEN IN THE ORDINARY CO URSE OF BUSINESS BUT ONLY FOR SECURING THE PREMISES ON RENT. THE CI T(A), THEREFORE, FOLLOWING THE DECISION OF THE HONBLE DELHI HIGH CO URT IN CASE OF CIT VS. TRIVENI ENGG. AND INDUSTRIES LTD., [2010[ INDLA W DEL 2397, DTD. 14/09/10, HELD THAT THE LOSS ON ACCOUNT OF NON RECO VERY OF RENT DEPOSIT OF RS. 7,65,028 WAS NOT IN THE NATURE OF A REVENUE LOSS ALLOWABLE AS A DEDUCTION. 6. AGGRIEVED BY THE ORDER OF CIT(A), THE ASSESSEE I S IN APPEAL BEFORE US. 7. THE LD. AR FILED A PETITION FOR ADMISSION OF ADD ITIONAL EVIDENCE. SINCE THE ASSESSEE COULD NOT FILE THE COPY OF THE L EASE AGREEMENT BEFORE THE AO AND CIT(A), NOW, THEY WANT TO FILE CO PY OF THE LEASE AGREEMENT, WHICH WAS FOUND RECENTLY IN THEIR MADRAS OFFICE. HOWEVER, LD. DR SUBMITTED THAT THIS COPY IS VERY MUCH AVAILA BLE IN THE RECORDS OF THE REVENUE. HENCE, WE PERMIT THE ASSESSEE TO FI LE ADDITIONAL EVIDENCE. 4 ITA NO. 503 /HYD/2012 M/S VISAKA INDUSTRIES LTD. 7.1 LD. AR SUBMITTED THAT THIS PROPERTY WAS TAKEN ON LEASE FROM 01/07/05 TO 30/06/06 FOR THE PURPOSE OF MANUFACTURI NG GARMENTS. UNDER THIS AGREEMENT, ASSESSEE HAS PAID SECURITY DE POSIT OF RS. 30 LAKHS AS PER THE AGREEMENT FILED. . LD. AR DREW OUR ATTENTION TO LEASE COVENANTS, POINT NO. F OF THE LEASE AGREEMENT WHERE IN LESSEE CANNOT ASSIGN, SUBLET OR PART OF THE DEMISED PREMISES OR A NY PART THEREOF EXCEPT TO THEIR SISTER CONCERNS. LD. AR SUBMITTED T HAT THIS LEASE WAS TAKEN ONLY FOR THE PURPOSE OF BUSINESS AND PAID REN T FOR THE SAME CLAIMING IT AS REVENUE EXPENDITURE. IT DOES NOT CRE ATE ANY CAPITAL ASSET SINCE THE LEASE WAS CONDITIONAL AS ENUMERATED FROM CLAUSE F (SUPRA) OF THE AGREEMENT. HENCE, IT DOES NOT FORM A NY CAPITAL ASSET. . HE RELIED ON THE FOLLOWING JUDGMENTS: 1. LG SOFT INDIA (P) LTD., VS. DCIT, 35 TAXMANN.CO M 202 (BANG.) 2. . ACIT VS. APPOLLO TYRES LTD., 33 TAXMANN.COM 5 75 3. UNITED MOTORS (INDIA) LTD. VS. ITO, 6 TAXMANN.C OM 32 (MUM.) 4. KANORIA SECURITIES & FINANCIAL SERVICES (P) LTD ., VS. ACIT, (MUM.) 15 SOT 191 5. BADRIDAS DAGA VS. CIT 34 ITR 10 (SC) 8. THE LD. DR, ON THE OTHER HAND, RELIED UPON THE O RDERS OF AO AS WELL AS RELIED ON THE DECISION OF THE HONBLE DELHI HIGH COURT IN THE CASE OF TRIVENI ENGG. INDUSTRIES LTD. (SUPRA) AND T HE ORDER OF CIT(A). HE SUBMITTED THAT THE PROPERTY TAKEN ON LEASE GIVES RIGHT OF OCCUPANCY EXCLUSIVELY AND THEREBY CREATES A CAPITA L ASSET, HENCE, WRITING OFF SUCH ADVANCE AS NON-RECOVERABLE AMOUNTS TO CAPITAL LOSS. 9. WE HAVE HEARD THE ARGUMENTS OF BOTH THE PARTIES AND PERUSED THE MATERIAL ON RECORD AS WELL AS THE ORDERS OF REV ENUE AUTHORITIES. WE HAVE ALSO APPLIED OUR MIND TO THE DECISIONS CITE D ABOVE. THE ADMITTED FACTS OF THE CASE ARE THAT AS THE RENTAL A DVANCE GIVEN BY THE ASSESSEE AS SECURITY DEPOSIT TO THE LESSOR M/S CHE TTIPUNYAM PROPERTIES PVT. LTD. FOR TAKING THEIR PREMISES ON L EASE VIDE LEASE 5 ITA NO. 503 /HYD/2012 M/S VISAKA INDUSTRIES LTD. AGREEMENT DATED 24 TH JUNE, 2005 FOR MANUFACTURING OF GARMENTS, NO DOUBT, IT IS FOR THE BUSINESS OF THE ASSESSEE . THE ASSESSEE GET A RIGHT TO OCCUPY AND RUN THE BUSINESS UNINTERRUPTEDL Y. THE QUESTION ARISES, THE RENTAL ADVANCE GIVEN BY ASSESSEE WHETHE R A CAPITAL ASSET OR REVENUE ASSET IS CREATED. AS PER THE RATIO LAID DOWN IN THE CASE OF TRIVENI ENGG. (SUPRA), CAPITAL ASSET IS CREATED, NO T THE REVENUE ASSET. THE SUBMISSIONS MADE BY THE LD. AR RELYING ON THE O THER JUDGMENTS; IN THE CASE OF LG SOFT INDIA PVT. LTD. (SUPRA), THE ASSESSEE PAID RENT FREE ADVANCE TO OBTAIN PERMISSIVE USE OR LICENCE TO USE PREMISES. THIS WAS NOT THE CASE IN THE PRESENT APPEAL ON HAND . THE APPOLLO CASE IS NOT SUBJECT UNDER CONSIDERATION. SINCE THE RATIO LAID DOWN WERE, WHICH RECONFIRMS THE PROVISIONS THAT WRITE OF F OF ADVANCE GIVEN FOR CAPITAL ASSETS LIABLE TO BE DISALLOWED. SIMILAR LY, WRITE OFF OF ADVANCE GIVEN FOR REVENUE ITEMS WAS ALLOWABLE AS DE DUCTION U/S 37. THE OTHER DECISIONS RELIED ON BY THE ASSESSEE ARE R ELATING TO CLAIMING BAD DEBTS WHICH WERE PURELY RELATING TO COMMERCIAL TRANSACTIONS AND REVENUE IN NATURE. HENCE, THESE JUDICIAL PRONOUNCEM ENTS WERE IRRELEVANT FOR THE PRESENT CASE UNDER CONSIDERATION SINCE THE TENANCY RIGHTS CREATES CAPITAL ASSETS. IN THE CASE OF BADR I DASS DAGA (SUPRA), THE HONBLE SUPREME COURT HAS HELD AS UNDER: THE RESULT IS THAT WHEN A CLAIM IS MADE FOR A DEDUC TION FOR WHICH THERE IS NO SPECIFIC PROVISION IN SECTION 10 (2), WHETHER IT IS ADMISSIBLE OR NOT WILL DEPEND ON WHETHER, HAVIN G REGARD TO ACCEPTED COMMERCIAL PRACTICE AND TRADING PRINCIPLE S, IT CAN BE SAID TO ARISE OUT OF THE CARRYING ON OF THE BUSINE SS AND TO BE INCIDENTAL TO IT. IF THAT IS ESTABLISHED, THEN THE DEDUCTION MUST BE ALLOWED, PROVIDED OF COURSE THERE IS NO PROHIBI TION AGAINST IT, EXPRESS OR IMPLIED, IN THE ACT. IT IS CLEAR THAT THIS ADVANCE PAYMENT WAS NOT FOR T HE NORMAL COURSE OF BUSINESS/TRADE. SINCE THE CAPITAL ASSET IS CREATED, THE SAME CANNOT BE TREATED AS REVENUE LOSS BUT CAPITAL LOSS. 9.1 IN THE OTHER CASES RAISED BY ASSESSEE, THE BAD DEBTS AROSE IN THE NORMAL COURSE OF BUSINESS AND ARE REVENUE IN NATURE, BUT, IN THE PRESENT CASE, 6 ITA NO. 503 /HYD/2012 M/S VISAKA INDUSTRIES LTD. ADVANCE WRITTEN OFF WAS IN THE NATURE OF CAPITAL AS SET. . ACCORDINGLY, GROUND NOS. 1, 2 & 3 ARE DISMISSED. 10. AS REGARDS THE SECOND ISSUE CLAIM OF DEDUCTIO N U/S 80IB RAISED IN GROUND NOS. 4 & 5, THE AO NOTICED THAT WHILE CALCUL ATING THE PROFITS ELIGIBLE FOR DEDUCTION U/S 80IB, THE ASSESSEE HAD CONSIDERED THE OTHER INCOME OF RS. 22,56,743/- AS ELIGIBLE INCOME U/S 80IB ALSO. HE OP INED THAT SINCE SUCH OTHER INCOME WAS NOT DERIVED FROM THE BUSINESS OF THE ASS ESSEE, THE SAME WAS NOT ELIGIBLE FOR CLAIM OF DEDUCTION U/S 80IB. THE ASSES SEE CONTENDED THAT THE OTHER INCOME WAS GENERATED OUT OF NORMAL COURSE OF BUSINE SS. HOWEVER, THE AO DID NOT ACCEPT THE SAID CONTENTION OPINING THAT IN VIEW OF VARIOUS COURT PRONOUNCEMENTS, OTHER INCOME IS NOT TO BE CONSIDERE D AS DERIVED FROM THE BUSINESS. ACCORDINGLY, HE COMPUTED THE DEDUCTION U/ S 80IB AT RS. 2,53,07,225 AS AGAINST RS. 2,59,84,248 CLAIMED BY THE ASSESSEE AND DISALLOWED THE EXCESS CLAIM OF RS. 6,77,023. 11. BEFORE THE CIT(A), IT WAS SUBMITTED BY ASSESSEE THAT THE OTHER INCOME CONSTITUTED RECEIPT FROM SALE OF SCRAP, BROKEN/DAMA GED SHEETS, GUNNIES ETC., WHICH WERE DERIVED FROM THE BUSINESS OF THE ASSESSE E . HE, THEREFORE, ARGUED THAT THE SAME SHOULD HAVE BEEN INCLUDED FOR THE PUR POSE OF CALCULATION OF DEDUCTION U/S 80IB. 12. AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESS EE, THE CIT(A) FOLLOWING THE DECISIONS OF THE ITAT AND THE DECISION OF THE H ONBLE SUPREME COURT, HELD THAT SINCE THE ASSESSEE COULD NOT ESTABLISH THAT TH E SCRAP OR BROKEN/DAMAGED SHEETS WERE GENERATED FROM THE INDUSTRIAL OPERATION S OF THE ASSESSEE COMPANY ONLY, THE OTHER INCOME ON THIS ACCOUNT CANNOT BE CO NSIDERED AS ELIGIBLE FOR DEDUCTION U/S 80IB. 13. AGGRIEVED WITH THE DECISION OF CIT(A), THE ASSE SSEE IS IN APPEAL BEFORE US. 14. THE LD. AR SUBMITTED THAT THE CIT(A) OUGHT TO H AVE CONSIDERED THE OTHER INCOME IN THE NATURE OF SALE OF SCRAP, CLAIMS ON DA MAGED SHEETS, ETC. AS 7 ITA NO. 503 /HYD/2012 M/S VISAKA INDUSTRIES LTD. BUSINESS INCOME OF THE UNDERTAKING ELIGIBLE FOR DED UCTION U/S 80IB OF THE IT ACT. THE LD. AR RELIED ON THE FOLLOWING CASES: 1. ACIT VS. BIOTECH MEDICALS (P) LTD., 119 ITD 143 (HYD) 2. CIT VS. SADHU FORGING LTD., 336 ITR 444 (DEL.) 15. THE LD. DR, ON THE OTHER HAND, RELIED ON THE OR DERS OF THE REVENUE AUTHORITIES. 16. WE HAVE HEARD THE ARGUMENTS OF BOTH THE PARTIES AND PERUSED THE MATERIAL ON RECORD AS WELL AS THE ORDERS OF REV ENUE AUTHORITIES. WE HAVE ALSO APPLIED OUR MIND TO THE DECISIONS CITE D. THE AO DISALLOWED THE CLAIM OF ASSESSEE U/S 80IB BY HOLDIN G THAT OTHER INCOME WAS NOT DERIVED FROM THE BUSINESS OF ASSESS EE. THE CIT(A) CONFIRMED THE ACTION OF THE AO. 16.1 THE CASES REFERRED BY THE ASSESSEE AND THE RAT IOS LAID DOWN IN THESE JUDGMENTS WERE, THE ASSESSEE HAD DONE A PROCE SS ON THE RAW MATERIAL WHICH WAS NOTHING BUT A PART AND PARCEL OF THE MANUFACTURING PROCESS OF THE INDUSTRIAL UNDERTAKING. THE RECEIPTS LIKE JOB WORK, SCRAP AND LABOUR CHARGES COULD NOT BE SAID TO BE IN DEPENDENT INCOME OF THE MANUFACTURING ACTIVITIES OF THE UNDERTAKING OF THE ASSESSEE AND, THUS, COULD NOT BE EXCLUDED FROM THE PROFITS A ND GAINS DERIVED FROM THE INDUSTRIAL UNDERTAKING FOR THE PURPOSE OF COMPUTING DEDUCTION U/S 80IB. THOSE WERE GAINS DERIVED FROM T HE INDUSTRIAL UNDERTAKING AND SO, ENTITLED FOR THE PURPOSE OF COM PUTING DEDUCTION U/S 80IB. 16.2 CONSIDERING THE ABOVE RATIOS LAID DOWN IN THE CASES, WE ARE OF THE OPINION THAT THE ASSESSEE IS ELIGIBLE TO CLAIM INCOME FROM SCRAP SALES. THE SCRAP IS PART AND PARCEL OF ANY INDUSTRI AL UNDERTAKING, WITHOUT WHICH, THERE IS NO MANUFACTURING ACTIVITY. HENCE, ENTITLED TO CLAIM BENEFIT U/S 80IB. 16.3 COMING TO THE INCOME FROM INSURANCE, THE UNDER TAKING CLAIMED LOSS FROM INSURANCE COMPANY, IT IS NOTHING BUT COMP ENSATION FOR THE 8 ITA NO. 503 /HYD/2012 M/S VISAKA INDUSTRIES LTD. FINISHED GOODS LOST AFTER MANUFACTURING IN THE UNDE RTAKING AND DURING TRANSIT. IT IS SIMILAR TO THE SCRAP SALES INCOME DE RIVED AS PART OF THE INDUSTRIAL PROCESS. SIMILARLY, THE INSURANCE INCOME DERIVED DUE TO LOSS OF MANUFACTURED FINISHED GOODS. HENCE, IT IS ENTITL ED TO CLAIM BENEFIT U/S 80IB. 16.4 WITH RESPECT TO OTHER INCOME LIKE INTEREST, WH ICH IS NOT PART OF INDUSTRIAL ACTIVITIES OR MANUFACTURING, HENCE, IT I S NOT ENTITLED FOR THE BENEFIT U/S 80IB. IN THE RESULT, ASSESSEE IS ALLOWE D TO CLAIM BENEFIT ON SCRAP SALES AND INSURANCE INCOME, REST ARE DISMISSE D. ACCORDINGLY, GROUND NOS. 4 & 5 ARE PARTLY ALLOWED. 17. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. PRONOUNCED IN THE OPEN COURT ON 27 TH NOVEMBER, 2015 SD/- SD/- (P. MADHAVI DEVI) (S. RIFAUR RAHM AN) JUDICIAL MEMBER ACCOUN TANT MEMBER HYDERABAD, DATED: 27 TH NOVEMBER, 2015 KV COPY TO:- 1) M/S VISAKA INDUSTRIES LTD., C/O M. ANANDAM & CO. , CAS, 7A, SURYA TOWERS, SP ROAD, SECUNDERABAD. 2) ADDL. CIT, RANGE - 3 HYDERABAD 3) CIT(A)-IV, HYDERABAD 4) CIT-III, HYDERABAD 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDE RABAD. 9 ITA NO. 503 /HYD/2012 M/S VISAKA INDUSTRIES LTD. DESCRIPTION DATE INTLS 1. DRAFT DICTATED ON SR.P.S. 2. DRAFT PLACED BEFORE AUTHOR SR.P.S 3 DRAFT PROPOSED & PLACED BEFORE THE SECOND MEMBER AM 4 DRAFT DISCUSSED/APPROVED BY SECOND MEMBER VP 5 APPROVED DRAFT COMES TO THE SR.P.S./PS SR.P.S. 6. KEPT FOR PRONOUNCEMENT ON SR.P S. 7. FILE SENT TO THE BENCH CLERK SR.P.S. 8 DATE ON WHICH FILE GOES TO THE HEAD CLERK 9 DATE OF DISPATCH OF ORDER