ACIT, Central Circle-3(1), Hyderabad V. Virender Kumar Gupta, Hyderabad

ITA 508/Hyd/2022

AI Insights

The case involves two connected appeals by Jitender Kumar Gupta and Virender Kumar Gupta against the common order of the CIT (A)-11, Hyderabad, for the assessment years 2012-13 and 2013-14. The primary issue was the disallowance of the claim of Long Term Capital Gain under section 10(38) and its assessment as unexplained cash receipt under section 68 of the Income Tax Act, 1961. The Assessing Officer had made these additions based on the report of the Investigation Wing following a search operation at the business premises of M/s. Jatinder Roller Flour Mills, where the assessees were partners. The Tribunal found that no incriminating material was found during the search at the premises of the assessees, and thus, the additions were not justified.

• Counselvise Citation: [2023] 140 COUNSELVISE.COM (IT) 129532 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-10-2023
• Order Result: Allowed
• Bench Allotted: DB-A
• Next Hearing Date: 24-09-2023
• Assessment Year: 2013-2014
• Appeal Filed On: 29-09-2022
• Other Referred Cases: Chintels India Limited (397 ITR 416), Vipin Khanna, Abhisar Buildwell (P) Ltd, Mahesh Reddy and others vs. ACIT, Prerana Agarwal vs. DCIT, Best Infrastructures and other decisions, Kabul Chawla, Smt. Dayawanti vs. CIT, B. Krishna Kumar vs. DCIT
• Laws Referred To: Income Tax Act
• Court: TRIBUNAL
• Keywords: Accommodation entries; Block assessment
• Section: 68; 271(1)(c); 142(1); 133A; 153A; 143(1); 143(2); 158B(b); 13; 22; 153C

Judgement Text

ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 1 of 23 आयकर अपीलȣय अͬधकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad Before Shri R.K. Panda, Vice-President AND Shri Laliet Kumar, Judicial Member ITA No.507/Hyd/2022 Assessment Year: 2012-13 Sri Jitender Kumar Gupta Hyderabad Vs. A.C.I.T Central Circle 3(1) Hyderabad (Appellant) PAN:AAPPG6606B (Respondent) ITA No.508/Hyd/2022 Assessment Year: 2013-14 Sri Virender Kumar Gupta Hyderabad Vs. A.C.I.T Central Circle 3(1) Hyderabad (Appellant) PAN:AASPG1887D (Respondent) Assessee by : Shri K.C. Devdas, Ca Revenue by: Smt. T.H. Vijaya Lakshmi, CIT(DR) Date of hearing: 25/09/2023 Date of pronouncement: 17/10/2023 ORDER Per Laliet Kumar, J.M These are the two connected appeals filed by the respective assessees are directed against the common order dated 27.07.2022 of the learned CIT (A)-11, Hyderabad relating to A.Ys. 2012-13 & 2013-14 respectively. Since identical grounds have been taken by the assessees in both these appeals, therefore, for ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 2 of 23 the sake of convenience, both appeals were heard together and are being disposed of by this common order. ITA No.507/Hyd/2022 – A.Y 2012-13 2. Facts of the case, in brief, are that the assessee is an individual having income from house property, capital gains, share income as partner in firms and other sources. He filed his return of income for the A.Y 2012-13 on 22.12.2012 declaring total income of Rs.26,07,520/-. Subsequently, a search operation u/s 132 was conducted on 2.5.2018 in the business premises of M/s. Jatinder Roller Flour Mills wherein the assessee is a partner. Notices u/s 153A was issued to the assessee for the subject A.Y and was duly served upon the assessee by e-mail and speed post. In response to the notices, the assessee filed his return of income admitting income of Rs.26,07,520/- on 23.04.2019. Later, the assessee filed his objections for issuing notice u/s 153A for the relevant A.Y being the 7 th year from the search year which was disposed of by the Assessing Officer vide letter dated 31.07.2019. Thereafter, statutory notices u/s 143(2) and 142(1) were issued to the assessee to which the AR of the assessee appeared before the Assessing Officer and filed the requisite details. 3. The assessee is a partner in M/s. Jatinder Roller Flour Mills and has purchased 1200 shares of M/s. Dignity Suppliers Ltd for Rs.400/- each on 13.10.2009. Subsequently, as per amalgamation schedule, 1200 shares of M/s. Dignity Suppliers Ltd were converted into 45600 shares of M/s. Twenty First Century Pvt Ltd. Out of 45600 shares of M/s. Twenty First Century Pvt Ltd, the assessee has sold 33500 shares on different dates relevant to A.Y 2012-13 for Rs.1,08,34,445/- and claimed ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 3 of 23 the resultant Long-Term Capital Gain of Rs.1,04,81,814/- as exempt u/s 10(38) of the I.T. Act. 4. The Assessing Officer disallowed the claim of Long Term Capital Gain u/s 10(38) and assessed the same as unexplained cash receipt u/s 68 of the I.T. Act Accordingly, the amount of Rs.1,04,81,814/- introduced/credited by the assessee against the sale of scripts of above mentioned Twenty First Century India Ltd during the financial year 2011-12 (A.Y 2012-13) in his capital account as his income being unexplained cash credit u/s 68 of the Act. The Assessing Officer also initiated separate penalty proceedings u/s 271(1)(c) for furnishing inaccurate particulars of income. 5. In appeal, the learned CIT (A) upheld the action of the Assessing Officer by observing as under: ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 4 of 23 ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 5 of 23 ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 6 of 23 ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 7 of 23 ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 8 of 23 6. Aggrieved with such order of the learned CIT (A) the assessee is in appeal before the Tribunal by raising the following grounds: ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 9 of 23 ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 10 of 23 ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 11 of 23 7. The learned Counsel for the assessee while drawing our attention to Grounds 2 to 6 contended that in the appellate proceedings the assessee had raised a specific ground with respect to absence of incriminating documents and submitted that no addition can be made in absence of any incriminating documents u/s 153A of the Act. For the above proposition, the assessee has taken ground No.2 to 6 before the learned CIT (A). He further submitted that the learned CIT (A) in para 3 of his order has duly recorded this fact. However, the learned CIT (A) dismissed the grounds raised by the assessee on legal ground as well as on merit. 8. The learned Counsel for the assessee drew our attention to the return of income filed for the A.Y 2012-13 to page 3 wherein it was pointed out that the assessee has claimed exemption u/s 10(38) for the Twenty First Century India Ltd shares (3350 shares). 9. It was submitted that the assessee had mentioned the above said fact in the return of income at Page 5 (schedule-1) which is to the following effect: ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 12 of 23 10. The learned AR further relied upon the decisions of the Hon'ble Delhi High Court in the case of Chintels India Limited (397 ITR 416) and Punjab & Haryana High Court in the case of Vipin Khanna wherein it was observed that no addition can be made after a period of 4 years since no notice u/s 143(2) was issued within a period of 4 years. He further submitted that the search took place in the business premises of M/s. Jatinder Roller Flour Mills on 2.5.2018 and during the course of search, the team has drawn a panchanama at page 38 of the paper book which was found and seized are duly mentioned. 11. The learned AR submitted that after the search, the statement of the assessee was duly recorded by the Investigation Wing wherein the assessee had clarified that no bogus Long Term Capital Gain claim was claimed by the assessee and the transaction was genuine and through proper banking channels. He also drew our attention to page 30 (Question No.47 & Answers) to that effect. ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 13 of 23 12. The learned AR fairly submitted that thereafter under the duress and pressure, the assessee was forced to forego the claim u/s 10(38) in the statement recorded on 14.6.2018 and our attention was drawn to question No.9 which is to the following effect. ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 14 of 23 13. Before us, the learned AR relying upon the Panchnama and the order of the Assessing Officer submitted that as there was no incriminating material found during the course of search pertaining to the Long-Term Capital Gain, therefore, no addition can be made in the hands of the assessee. The learned AR for the assessee for the above said proposition had relied upon decision of the Hon'ble Supreme Court in the case of Abhisar Buildwell (P) Ltd dated 24 th April, 2023 and also the decision of the Coordinate Bench in the case of Prerana Agarwal vs. DCIT in ITA No.458/Hyd/2021, dated 8.6.2023 and Mahesh Reddy and others vs. ACIT in ITA Nos.40 to 43/Hyd/2023 dated 1.8.2023. 14. It was also submitted that the statement recorded on 14.6.2018 has not been acted upon by the assessee and the same was later retracted by filing the return of income without withdrawing the claim u/s 10(38) in response to notice u/s 153A. Further, the learned AR relied upon the decision of the Hon'ble Delhi High Court in the case of Best Infrastructures and other decisions on the basis of which it was held that merely on the basis of the statement recorded, no addition can be made u/s 153A of the Act unless corroborative incriminating documents were found from the premises of the assessee. It was submitted that since no incriminating documents were found during the search, therefore, no additions can be made. 15. Per contra, the learned DR submitted that the statement recorded by the Investigation Team is binding and is an incriminating material as held by the learned CIT (A) and she relied upon the decision of Smt. Dayawanti vs. CIT and the ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 15 of 23 dismissal order of the Hon'ble Supreme Court in the SLP in the case of B. Krishna Kumar vs. DCIT. 16. In rebuttal, the learned AR submitted that the decision of Smt. Dayawanti vs. CIT was considered and distinguished by the Hon'ble Delhi High Court in the case of Kabul Chawla. Further it was submitted that the decision of the Kabul Chawla was upheld by the Hon'ble Supreme Court in the case of Abhisar Builders. It was also held that the decision of B Krishna Kumar is now applicable after the pronouncement of the decision of the Hon'ble Supreme Court in the case of Abhisar Buildwell (P) Ltd (Supra). 17. We have heard the rival submissions and perused the material available on record. The Assessing Officer in paragraph 18 had noted that survey action u/s 133A of the Act was conducted at the premises of the share-broker and the share- broker has accepted the role in providing the accommodation entries. In table reproduced at para 8, the name of the assessee namely Shri Jitender Kumar Gupta and Shri Virender Kumar Gupta have not been mentioned, in the statement so recorded by the Assessing Officer and reproduced in the assessment order. In fact during the course of search, no incriminating material pertaining to the Long Term Capital Gain was found in the premises of the assessee and the entire addition made by the Assessing Officer were based on the report of the Investigation Wing, Kolkata pursuant to the survey action carried out in the premises of the broker. ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 16 of 23 18. Recently, we had an occasion to examine an identical issue in the case of Mahesh Reddy and others vs. ACIT in ITA Nos.40 to 43/Hyd/2023 dated 1.8.2023 wherein we have held as under: 10. We have heard the rival submissions and perused the material available on record. It is an admitted fact that there is no reference to any incriminating material either by the Assessing Officer or by the ld.CIT(A) in their orders. The whole addition was made in the hands of the assessee on the basis of the search conducted by the Director of Investigation, Kolkata, in the premises of the Kolkata based share brokers wherein they have admitted that they were allegedly providing accommodation entries to various persons. However, the fact remains that no incriminating material was found during the course of search in the premises of the assessee. 10.1. In Paragraph 1.4 of the assessment order, assessee has categorically mentioned that no incriminating material constituting the tangible assets were found in the premises of the assessee. In our view, in the absence of any incriminating material, no addition can be made in the hands of the assessee. For the above said purposes, we may fruitfully reply upon the decision of Hon'ble Supreme Court in the case of Abhisar Buildwell Pvt. Ltd. (supra). The co-ordinate Bench of the Tribunal has an occasion to examine the applicability of the decision in the case of Abhisar Buildwell Pvt. Ltd. (supra) in the case of Preranaa Agarwal ITA 458/Hyd/2021 wherein the co-ordinate Bench of the Tribunal in Para 8.2 to 9.1 had held as under : “8. We have gone through the record in the light of the submissions made on either side. Insofar as the facts and figures are concerned, there is not much dispute. The return of income filed by the assessee for the assessment year 2013-14 on 27/07/2013 was processed under section 143(1) of the Act and notice under section 143(2) of the Act was never issued. By the date of search on 15/11/2018, four years elapsed after the last date for issuance of notice under section 143(2) of the Act in this case. It is also not the case of the Revenue that any incriminating material was found during the search that was considered by the learned Assessing Officer, but made the assessment. In these circumstances, the question that arises for consideration is ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 17 of 23 whether any interference could be made with the concluded assessments while assessing the income under section 153A of the Act, when no incriminating material was found. 9. As stated earlier, the return of income filed by the assessee for the assessment year 2013-14 on 27/07/2013 was processed under section 143(1) of the Act by 30/09/2014. Neither notice under section 143(2) of the Act was issued nor any proceedings were pending as on the date of search. Though the divergent views taken on this aspect are brought to our notice by both the counsel, the Hon'ble Supreme Court put a quietus to the issue by the decision in the case of PCIT vs. Abhisar Buildwell P. Ltd. (supra). While in complete agreement with the view taken by the Hon'ble Delhi High Court in the case of CIT vs. Kabul Chawla, (2015) 61 taxmann.com 412 (Delhi) and the Hon'ble Gujarat High Court in the case of PCIT Vs. Saumya Construction (2016) 387 ITR 529 and the decisions of the other High Courts taking the view that no addition can be made in respect of the completed assessments in absence of any incriminating material, Hon’ble Apex Court concluded that- i) that in case of search under Section 132 or requisition under Section 132A, the AO assumes the jurisdiction for block assessment under section 153A; ii) all pending assessments/reassessments shall stand abated; iii) in case any incriminating material is found/unearthed, even, in case of unabated/completed assessments, the AO would assume the jurisdiction to assess or reassess the ‘total income’ taking into consideration the incriminating material unearthed during the search and the other material available with the AO including the income declared in the returns; and iv) in case no incriminating material is unearthed during the search, the AO cannot assess or reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 18 of 23 assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under Sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved. 9.1. This decision applies to the facts of the case on all fours and respectfully following the same, we hold that since no incriminating material found in the case of assessee for the assessment year 2013-14, the concluded assessment cannot be disturbed and the addition made by the learned Assessing Officer and sustained by the learned CIT(A) cannot be upheld. We accordingly allow the appeal of assessee.” 11. In the present case, admittedly, no incriminating material was referred to by the Assessing Officer in the assessment order and the same is also in the case of ld.CIT(A). Therefore, in our view, no addition can be made in the hands of the assessee in view of the law laid down by the Hon'ble Supreme Court in the case of Abhisar Buildwell Pvt. Ltd. (supra). 12. Further, the question that arises is as to whether the information collected by the Director, Investigation from the Brokers in the form of statement etc. form the basis for making the addition in the hands of the assessee or not ? In our view, the answer to that is also No, as no material has been brought to our notice either in the assessment order or in the order of ld.CIT(A) showing that the said brokers in their respective statements have indicated that they had provided the accommodation entries to the assessee. Ironically, the Assessing Officer in Para 7 of his order referred to the statement of Shri Kailash Prasad Dhyawala and also of Anil Kumar. However, in none of the said statements, the name of the assessee or the firm of AMR is reflected. Further, even if we assume that some information was found during the course of search at the broker’s premises at Kolkata showing that the assessee was beneficial with those accommodation entries, then the said material only can form basis for making the addition in the hands of the assessee under section 153C of the Act and not under section 153A. For the purposes of ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 19 of 23 making addition u/s 153A of the Act, it is essential and sine qua non that during the course of search, some incriminating material must have been found from the premises of the assessee which shows the escapement of income. In the present case, no incriminating material was found during the course of search. Therefore, no addition can be made in the hands of the assessee. Furthermore, the 4 th provision to section 153A reads as under : '(4) Provided also that no notice for assessment or reassessment shall be issued by the Assessing Officer for the relevant assessment year or years unless— (a) the Assessing Officer has in his possession books of account or other documents or evidence which reveal that the income, represented in the form of asset, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more in the relevant assessment year or in aggregate in the relevant assessment years; (b) the income referred to in clause (a) or part thereof has escaped assessment for such year or years; and (c) the search under section 132 is initiated or requisition under section 132A is made on or after the 1st day of April, 2017. Explanation 1.—For the purposes of this sub-section, the expression "relevant assessment year" shall mean an assessment year preceding the assessment year relevant to the previous year in which search is conducted or requisition is made which falls beyond six assessment years but not later than ten assessment years from the end of the assessment year relevant to the previous year in which search is conducted or requisition is made. Explanation 2.—For the purposes of the fourth proviso, "asset" shall include immovable property being land or building or both, shares and securities, loans and advances, deposits in bank account.'. 13. The reading of 4 th proviso to Section 153A of the Act, make it abundantly clear that the revenue officials shall not issue notice beyond a period of six years unless (1) Assessing ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 20 of 23 Officer is in possession of books of accounts and (2) there are other documents or evidence which reveal that income reflected in the form of assets was escaped from assessment. 14. In the present case, the Assessing Officer was neither in possession of books of accounts nor other documents or evidence, at the time of reassessment which shows any escapement of amount reflected in the assets head. Admittedly, the term ‘Asset’ was defined under Explanation 2, which include immovable property being land or building or both, shares and securities, loans and advances, deposits in bank account. In the present case, the assessee has purchased 5000 shares on 27.10.2009 and 14.12.2009 of M/s. Astha Tradelink Private Limited for Rs.400/- each. Thereafter, those 5000 shares were converted into 1,90,000/- shares of M/s. Twenty First Century Private Limited and the assessee sold part of the shares in A.Y. 2011-12 relevant to A.Y. 2012-13 and earned capital gains of Rs.5,96,11,906/-. Thus, during the assessment year, the column ‘Asset’ does not show either the investment in the immovable property being land or building or both, shares and securities, loans and advances. In the absence of any asset being in possession of the assessee, the Assessing Officer shall not have issued the notice to the assessee for making the addition u/s 153A of the Act. In view of the above, the addition made in the hands of the assessee is liable to be deleted. 15. There is one more reason to come to the conclusion that the Assessing Officer should have made more efforts to bring on record some tangible material besides the statement of the assessee namely, A. Mahesh Reddy to show that the assessee has agreed to pay the profit during the assessment year under consideration and would be ready to forego the claim made by the assessee at assessment stage during the course of original assessment proceedings. 16. In our view, the statement given by the assessee or the director of M/s. Twenty First Century Securities Limited, does not bind the assessee unless it is duly supported by the cogent incriminating material and we find merit in the arguments of the ld.AR who had relied on the decision of Hon’ble High Court of Andhra Pradesh in the case of CIT vs. Shri Ramdas Motor Transport Limited reported in (2015) 55 taxmann.com and also the decisions of hon’ble Delhi High Court in the case of PCIT Vs. Best Infrastructure (India) Pvt. Ltd., (supra), and CIT Vs. Harjeev Aggarwal reported in (2016) 70 taxmann.com 95 (Delhi), wherein at Paragraph 21, it was held as under : ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 21 of 23 “21. A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The explanation to Section 132 (4), which was inserted by the Direct Tax Laws (Amendment) Act, 1987 w.e.f. 1st April, 1989, further clarifies that a person may be examined not only in respect of the books of accounts or other documents found as a result of search but also in respect of all matters relevant for the purposes of any investigation connected with any proceeding under the Act. However, as stated earlier, a statement on oath can only be recorded of a person who is found in possession of books of accounts, documents, assets, etc. Plainly, the intention of the Parliament is to permit such examination only where the books of accounts, documents and assets possessed by a person are relevant for the purposes of the investigation being undertaken. Now, if the provisions of Section 132(4) of the Act are read in the context of Section 158BB(1) read with Section 158B(b) of the Act, it is at once clear that a statement recorded under Section 132(4) of the Act can be used in evidence for making a block assessment only if the said statement is made in the context of other evidence or material discovered during the search. A statement of a person, which is not relatable to any incriminating document or material found during search and seizure operation cannot, by itself, trigger a block assessment. The undisclosed income of an Assessee has to be computed on the basis of evidence and material found during search. The statement recorded under Section 132(4) of the Act may also be used for making the assessment, but only to the extent it is relatable to the incriminating evidence/material unearthed or found during search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order to for an assessment to be based on the statement recorded.” ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 22 of 23 16.1. In view of the above, all the legal grounds raised by the assessee are decided in favour of the assessee. We further note that we have not adjudicated the other grounds on merit as the assessee gets the relief on legal grounds. Thus, the appeal of the assessee is allowed.” 19. We find no reasons to divert from our findings as the facts of the present case are identical to that of Shri Mahesh Reddy vs. ACIT (Supra). Though the learned DR had relied upon the decision in the case of Smt. Dayawanti, however, the said decision has duly been considered by the Hon'ble Delhi High Court in the subsequent case in the case of Kabul Chawla which was upheld by the hon Supreme Court in the case of Abhisar Buildwell (P) Ltd (Supra). In view of the above, the said decision is of no use to the assessee. 20. In the result, the appeal of the assessee in ITA No.507/Hyd/2022 is allowed. 21. As the facts and issues are identical in all the appeals, therefore, following our decision given in lead appeal ITA 507/Hyd/2022, the other captioned appeal i.e. ITA Nos.508/Hyd/ 2022 is also allowed. 22. To sum up, both the appeals of assessee are allowed. A copy of this order may be placed in all the respective files. Order pronounced in the Open Court on 17 th October, 2023. Sd/- Sd/- (R.K. PANDA) VICE-PRESIDENT (LALIET KUMAR) JUDICIAL MEMBER Hyderabad, dated 17 th October, 2023. Vinodan/SPS ITA Nos 507 and 508 of 2022 Jitender Kumar Gupta & Virender Kumar Gupta Page 23 of 23 Copy to: S.No Addresses 1 S/Sri Jitender Kumar Gupta & Virender Kumar Gupta, C/o Madhu Mantri & Associates, C-103 Mathrushree Apartments, 3-5-873 Hyderguda, Hyderabad 500029 2 ACIT Central Circle 2(1) 7 th Floor, Aayakar Bhavan, Basheerbagh, Hyderabad 500004 3 Pr. CIT – Central, Hyderabad 4 DR, ITAT Hyderabad Benches 5 Guard File By Order