M/s Nu-Tech Engineers, Visakhapatnam V. THE CIT - 1, Visakhapatnam

ITA 570/VIZ/2013

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 1106 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 2 year(s) 10 month(s) 1 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 10-06-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: 2009-2010
• Appeal Filed On: 08-08-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: G GURUSWAMY
• Assessee Lawyers: C R HEMANTH KUMAR
• Keywords: Non compliance; Assessment record
• Section: 143(3); 142(1); 194C; 263

Judgement Text

ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, 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.570/VIZAG/2013 ( / ASSESSMENT YEAR: 2009-10) M/S. NU - TECH ENGINEERS VISAKHAPATNAM VS. CIT - 1, VISAKHAPATNAM [PAN: AAEFN1563H ] ( % / APPELLANT) ( &'% / RESPONDENT) / APPELLANT BY : SHRI C.R. HEMANTH KUMAR, AR / RESPONDENT BY : SHRI G. GURUSWAMY, DR / DATE OF HEARING : 19.05.2016 / DATE OF PRONOUNCEMENT : 10. 06.2016 / O R D E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAI NST THE ORDER OF CIT, VISAKHAPATNAM DATED 11.6.2013 U/S 263 OF THE I NCOME TAX ACT, 1961 (HEREINAFTER CALLED AS THE ACT) FOR THE ASSE SSMENT YEAR 2009-10. ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 2 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E IS A PARTNERSHIP FIRM WHICH IS ENGAGED IN THE BUSINESS OF CIVIL CONT RACTS, FILED ITS RETURN OF INCOME FOR THE ASSESSMENT YEAR 2009-10 ON 29.9.2009 ADMITTING TOTAL INCOME OF RS.7,50,737/-. THE CASE HAS BEEN SELECTE D FOR SCRUTINY AND ACCORDINGLY, NOTICE U/S 143(2) & 142(1) OF THE ACT WERE ISSUED. IN RESPONSE TO NOTICE, THE AUTHORIZED REPRESENTATIVE O F THE ASSESSEE APPEARED FROM TIME TO TIME AND SUBMITTED BOOKS OF A CCOUNTS AND OTHER INFORMATION CALLED FOR. THE A.O. AFTER EXAMINING T HE BOOKS OF ACCOUNTS AND OTHER DETAILS COMPLETED THE ASSESSMENTS AND ACC EPTED THE INCOME RETURNED. 3. THE CIT-1, VISAKHAPATNAM ISSUED A SHOW-CAUSE NOT ICE DATED 2.5.2013 AND ASKED TO EXPLAIN WHY THE ASSESSMENT OR DER SHALL NOT BE REVISED U/S 263 OF THE ACT. THE CIT PROPOSED TO RE VISE THE ASSESSMENT ORDER FOR THE REASONS THAT ON EXAMINATION OF ASSESS MENT RECORDS, CERTAIN OMISSIONS AND COMMISSIONS WERE NOTICED, WHICH RENDE RED THE ASSESSMENT ORDER ERRONEOUS IN SO FAR AS IT IS PREJU DICIAL TO THE INTEREST OF THE REVENUE IN TERMS OF SECTION 263 OF THE ACT. THE CIT, IN THE SAID SHOW CAUSE NOTICE OBSERVED THAT THE ASSESSEE HAS DE CLARED A LOW NET PROFIT AND ALSO NOT DEDUCTED TDS ON RENT AND HIRE C HARGES OF RS.38,53,448/-. THE CIT, FURTHER OBSERVED THAT THE A.O. WITHOUT ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 3 EXAMINING WHETHER THE ASSESSEE HAS DEDUCTED TDS ON THE EXPENDITURE TOWARDS RENT AND HIRE CHARGES ALLOWED THE CLAIM OF THE ASSESSEE. IT WAS FURTHER OBSERVED THAT AS PER THE PROVISIONS OF SECT ION 40(A)(IA) OF THE ACT, ANY EXPENDITURE INCURRED WHICH WAS NOT SUBJECT TO TDS UNDER THE RELEVANT PROVISIONS OF THE ACT, THEN THERE IS NO DE DUCTION AVAILABLE WHILE COMPUTING THE INCOME UNDER THE HEAD PROFITS & GAINS OF BUSINESS OR PROFESSION. ON EXAMINATION OF ASSESSMENT RECORDS, IT WAS NOTICED THAT THE ASSESSMENT RECORDS DID NOT CONTAIN ANY EVIDENCE FOR HAVING DEDUCTION OF TAX AT SOURCE IN RESPECT OF RENT AND H IRE CHARGES COUPLED WITH THE FACT THAT NO EVIDENCE OR VOUCHERS COULD BE PRODUCED TOWARDS SUCH EXPENDITURE. THUS, NOT ONLY THE GENUINENESS O F SUCH EXPENDITURE IS IN DOUBTFUL BUT ALSO MANDATORY DISALLOWANCE FOR NON COMPLIANCE TO THE PROVISIONS OF SECTION 194C OF THE ACT OR 194I OF TH E ACT HAD NOT BEEN COMPLIED WITH. THE A.O. WITHOUT EXAMINING THE ABOVE ISSUES, SIMPLY ACCEPTED THE INCOME DECLARED BY THE ASSESSEE. THERE FORE, THE ASSESSMENT ORDER PASSED BY THE A.O. U/S 143(3) OF T HE ACT DATED 2.11.11 IS ERRONEOUS IN SO FAR AS IT IS PREJUDICIAL TO THE INTEREST OF THE REVENUE. 4. IN RESPONSE TO SHOW CAUSE NOTICE, THE ASSESSEE S UBMITTED THAT THE ASSESSMENT ORDER PASSED BY THE A.O. U/S 143(3) OF T HE ACT IS NOT ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 4 ERRONEOUS IN SO FAR AS IT IS PREJUDICIAL TO THE INT EREST OF THE REVENUE, AS THE A.O. HAS EXAMINED THE ISSUE OF TDS IN RESPECT O F RENT AND HIRE CHARGES. THE ASSESSEE FURTHER SUBMITTED THAT IT HAS FURNISHED BOOKS OF ACCOUNTS AND OTHER RELEVANT INFORMATION AT THE TIME OF ASSESSMENT, THE A.O. AFTER SATISFIED WITH THE DETAILS FURNISHED BY THE ASSESSEE HAS ACCEPTED THE INCOME DECLARED AND COMPLETED THE ASSE SSMENT. IT WAS FURTHER SUBMITTED THAT IT HAS BEEN EXECUTING CIVIL WORKS FOR LAST TWO YEARS AND THE INCOME FOR THE EARLIER 2 YEARS WAS AL SO DECLARED AT 3.5% TO 4% ON GROSS CONTRACT RECEIPTS. AS REGARDS THE T DS ON RENT AND HIRE CHARGES, THE A.O. HAS SPECIFICALLY CALLED FOR DETAI LS OF TDS IN RESPECT OF RENT AND HIRE CHARGES, AFTER FULLY SATISFIED WITH T HE EXPLANATIONS FURNISHED BY THE ASSESSEE HAS ACCEPTED THE CLAIM, T HEREFORE, IT IS NOT CORRECT TO SAY THAT THE A.O. HAS NOT EXAMINED THE I SSUE AT THE TIME OF COMPLETION OF ASSESSMENT. THE CIT AFTER CONSIDERIN G THE EXPLANATIONS OF THE ASSESSEE HELD THAT THE ASSESSMENT ORDER PASS ED BY THE A.O. U/S 143(3) OF THE ACT IS ERRONEOUS IN SO FAR AS IT IS P REJUDICIAL TO THE INTEREST OF THE REVENUE. THE CIT FURTHER HELD THAT THE NET PROFIT FROM THE BUSINESS IS VERY LOW WHEN COMPARED TO THE NATURE OF BUSINESS CARRIED ON BY THE ASSESSEE. THE CIT(A) FURTHER OBSERVED THAT THE ASSESSEE HAS FAILED TO EXPLAIN WHETHER THE TDS HAS BEEN DEDUCTED IN RESPECT OF RENT AND HIRE CHARGES. THE A.O. WITHOUT EXAMINING WHETHE R ASSESSEE HAS ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 5 COMPLIED WITH TDS PROVISIONS IN RESPECT OF RENT AND HIRE CHARGES, SIMPLY ALLOWED THE EXPENDITURE WHICH WAS OTHERWISE NOT ALL OWABLE TO THE ASSESSEE. SINCE, ASSESSEE HAS FAILED TO PROVE THE TDS COMPLIANCES ON RENT AND HIRE CHARGES, THE A.O. SHOULD HAVE DISALLO WED THE EXPENDITURE U/S 40(A)(IA) OF THE ACT FOR NON COMPLIANCE OF THE RELEVANT PROVISIONS OF THE TDS. WITH THESE OBSERVATIONS, SET ASIDE THE ORD ER PASSED BY THE A.O. AND DIRECTED THE A.O. TO PASS CONSEQUENTIAL OR DER WHILE GIVING EFFECT TO THIS ORDER ENHANCING THE ASSESSMENT FOR T HE ASSESSMENT YEAR 2009-10. AGGRIEVED BY THE CIT ORDER, THE ASSESSEE IS IN APPEAL BEFORE US. 5. THE LD. A.R. FOR THE ASSESSEE SUBMITTED THAT THE ASSESSMENT ORDER PASSED BY THE A.O. U/S 143(3) OF THE ACT IS NOT ERR ONEOUS IN SO FAR AS IT IS PREJUDICIAL TO THE INTEREST OF THE REVENUE, AS T HE A.O HAS EXAMINED THE ISSUE OF NET PROFIT AND ALSO TDS ON RENT AND HIRE C HARGES AT THE TIME OF COMPLETION OF ASSESSMENT. THE A.R. FURTHER SUBMITT ED THAT THE CIT WAS NOT CORRECT IN DIRECTING THE A.O. TO ENHANCE THE AS SESSMENT TO GIVE EFFECT TO THE DIRECTIONS U/S 263 OF THE ACT WITHOUT EXAMINING THE FACT THAT WHETHER PARTICULAR EXPENDITURE IS DISALLOWABLE U/S 40(A)(IA) OF THE ACT. THE A.R. FURTHER SUBMITTED THAT THE ASSESSEE H AS INCURRED THE EXPENDITURE TOWARDS RENT AND HIRE A CHARGE WHICH WA S PAID BEFORE THE ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 6 END OF THE FINANCIAL YEAR. AS PER THE DECISION OF ITAT, VISAKHAPATNAM IN THE CASE OF MERILYN SHIPPING & TRANSPORTERS VS ACIT (2012) 136 ITD 23, DISALLOWANCE U/S 40(A)(IA) OF THE ACT IS APPLICABLE ONLY WHEN ANY AMOUNT INCURRED IN RESPECT OF ANY EXPENDITURE ON WHICH TDS HAS NOT BEEN DEDUCTED WHICH REMAINS PAYABLE AT THE END OF THE FI NANCIAL YEAR. THE ASSESSEE HAS INCURRED THE EXPENDITURE AND PAID THE ENTIRE EXPENDITURE DURING THE SAME FINANCIAL YEAR, THEREFORE, NO DISAL LOWANCE CAN BE MADE U/S 40(A)(IA) OF THE ACT. THE CIT(A) REVISED THE A SSESSMENT ORDER FOR A SIMPLE REASON THAT THE A.O. HAS NOT EXAMINED THE IS SUE, IGNORING THE FACT THAT WHETHER ANY LOSS OF REVENUE TO THE GOVERN MENT. THE CIT CANNOT REVISE THE ASSESSMENT ORDER JUST BECAUSE THE ASSESSMENT ORDER IS ERRONEOUS, UNLESS IT IS ERRONEOUS AND ALSO PREJU DICIAL TO THE INTEREST OF THE REVENUE. THEREFORE, THE ORDER PASSED BY THE CIT SHOULD BE SET ASIDE. 6. ON THE OTHER HAND, THE LD. D.R. STRONGLY SUPPORT ED THE ORDER OF THE CIT(A). 7. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE MA TERIALS AVAILABLE ON RECORD. THE CIT ASSUMED THE JURISDICTI ON TO REVISE THE ASSESSMENT ORDER FOR THE REASON THAT THE A.O. HAS N OT CONDUCTED PROPER ENQUIRY BEFORE COMPLETION OF ASSESSMENT, THEREBY TH E ASSESSMENT ORDER ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 7 PASSED BY THE A.O. U/S 143(3) OF THE ACT IS ERRONEO US IN SO FAR AS IT IS PREJUDICIAL TO THE INTEREST OF THE REVENUE. THE CIT REVISED THE ASSESSMENT ORDER FOR THE REASON THAT THE NET PROFIT DECLARED BY THE ASSESSEE IS LESS AND ALSO THE ASSESSEE HAS NOT PROV ED WHETHER TDS HAS BEEN DEDUCTED IN RESPECT OF EXPENDITURE INCURRED UN DER THE HEAD RENT AND HIRE CHARGES. IT IS THE CONTENTION OF THE ASSE SSEE THAT THE ISSUES RAISED BY THE CIT HAVE BEEN EXAMINED BY THE A.O. AT THE TIME OF COMPLETION OF ASSESSMENT. THE ASSESSEE FURTHER CONT ENDED THAT WHETHER OR NOT TDS HAS BEEN DEDUCTED IN RESPECT OF RENT AND HIRE CHARGES, ONCE THE EXPENDITURE HAS BEEN PAID DURING THE SAME FINAN CIAL YEAR AND NOTHING IS PAYABLE AT THE END OF THE FINANCIAL YEAR , THEN IN VIEW OF THE DECISION OF ITAT, VISAKHAPATNAM SPECIAL BENCH IN TH E CASE OF MERILYN SHIPPING & TRANSPORTS (SUPRA), NO DISALLOWANCE CAN BE MADE U/S 40(A)(IA) OF THE ACT, IN RESPECT OF AMOUNTS WHICH H AVE BEEN ALREADY PAID DURING THE SAME FINANCIAL YEAR. WE FIND FORCE IN TH E ARGUMENT OF THE ASSESSEE FOR THE REASON THAT THE A.O. HAS EXAMINED THE ISSUE OF NET PROFIT AND TDS ON RENT AND HIRE CHARGES AT THE TIME OF COMPLETION OF ASSESSMENT. THE A.O. AFTER SATISFIED WITH THE EXPLA NATIONS FURNISHED BY THE ASSESSEE HAD ACCEPTED THE INCOME RETURNED AND C OMPLETED THE ASSESSMENT. THEREFORE, THE CIT WAS NOT CORRECT IN C OMING TO THE ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 8 CONCLUSION THAT THE A.O. HAS NOT CONDUCTED PROPER E NQUIRY OF THE ISSUES BEFORE COMPLETION OF THE ASSESSMENT. 8. THE CIT ASSUMED THE JURISDICTION TO REVISE THE A SSESSMENT ORDER ON THE SOLE GROUND THAT THERE IS A LACK OF ENQUIRY ON THE PART OF THE A.O. IN EXAMINING THE ISSUES REFERRED TO IN HIS SHOW CAU SE NOTICE. THE QUESTION OF LOW NET PROFIT DECLARED BY THE ASSESSEE AND ALSO TDS ON RENT AND HIRE CHARGES HAVE BEEN CONSIDERED BY THE A.O. A T THE TIME OF COMPLETION OF ASSESSMENT. THE ASSESSEE FILED A PAP ER BOOK WHICH CONTAINS THE DETAILS FURNISHED BEFORE THE A.O. AT T HE TIME OF ASSESSMENT. ON PERUSAL OF THE PAPER BOOK FILED BY THE ASSESSEE, WE FIND THAT THE A.O. HAS ISSUED A DETAILED QUESTIONNAIRE IN RESPECT OF NET PROFIT AND ALSO TDS IN RESPECT OF RENT AND HIRE CHARGES. THE A.O. AFTER SATISFIED WITH THE EXPLANATIONS FURNISHED BY THE ASSESSEE HAS ACCE PTED THE INCOME RETURNED. THEREFORE, WE ARE OF THE VIEW THAT ONCE THE ISSUES WHICH ARE SUBJECT MATTER OF REVISION U/S 263 OF THE ACT, HAVE BEEN EXAMINED BY THE A.O. AT THE TIME OF ASSESSMENT, THE CIT HAS NO JURISDICTION TO ENTERTAIN FRESH ENQUIRY ON THE SAME ISSUES, BECAUSE HE HAS A DIFFERENT OPINION ON THE ISSUES. IN OUR CONSIDERED OPINION, THE ISSUE OF NET PROFIT AND TDS ON RENT AND HIRE CHARGES HAS BEEN EXAMINED BY THE A.O. AT THE ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 9 TIME OF ASSESSMENT, THEREFORE, THE CIT WAS NOT CORR ECT IN COMING TO THE CONCLUSION THAT THE A.O. HAS NOT EXAMINED THE ISSUE S. 9. THE CIT HAS POWER TO REVISE THE ASSESSMENT ORDER U/S 263 OF THE ACT, BUT TO INVOKE THE PROVISIONS OF SECTION 263 OF THE ACT, THE TWIN CONDITIONS MUST BE SATISFIED I.E. (1) THE ORDER OF THE A.O. IS ERRONEOUS AND (2) FURTHER IT MUST BE PREJUDICIAL TO THE INTER EST OF THE REVENUE. UNLESS BOTH THE CONDITIONS ARE SATISFIED, THE CIT C ANNOT ASSUME JURISDICTION U/S 263 OF THE ACT. IT IS NOT NECESSA RY THAT EVERY ORDER WHICH IS ERRONEOUS MAY NOT BE PREJUDICIAL TO THE IN TEREST OF THE REVENUE OR VICE VERSA. UNLESS THE ASSESSMENT ORDER IS ERRON EOUS, NO ACTION CAN BE TAKEN BY THE CIT U/S 263 OF THE ACT, THIS IS BEC AUSE THE TWIN CONDITIONS I.E. THE ORDER IS ERRONEOUS AND THE SAME IS PREJUDICIAL TO THE INTEREST OF THE REVENUE ARE CO-EXIST. IN THE PRESE NT CASE ON HAND, THE A.O. HAS CONDUCTED DETAILED ENQUIRY AND ALSO EXAMIN ED THE ISSUE OF NET PROFIT AND TDS ON RENT AND HIRE CHARGES. THE ASSES SEE EXPLAINED BEFORE THE A.O. THAT IT IS CONSISTENTLY DECLARED A NET PRO FIT OF 3.5% TO 4% FOR THE PAST 2 YEARS. THE A.O. AFTER EXAMINING THE BOO KS OF ACCOUNTS AND OTHER DETAILS FURNISHED BY THE ASSESSEE HAS ACCEPTE D THE EXPLANATIONS AND COMPLETED ASSESSMENT ACCEPTING THE RETURNED INC OME DECLARED BY THE ASSESSEE. ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 10 10. AS REGARDS THE TDS ON RENT AND HIRE CHARGES, IT IS THE CONTENTION OF THE ASSESSEE THAT WHETHER OR NOT TDS HAS BEEN DE DUCTED ON PARTICULAR EXPENDITURE, ONCE EXPENDITURE HAS BEEN P AID DURING THE SAME FINANCIAL YEAR, NO DISALLOWANCE CAN BE MADE U/S 40( A)(IA) OF THE ACT. WE FIND FORCE IN THE ARGUMENTS OF THE ASSESSEE FOR T HE REASON THAT IN VIEW OF THE SPECIAL BENCH DECISION OF ITAT, VISAKHA PATNAM IN THE CASE OF MERILYN SHIPPING & TRANSPORTERS (SUPRA), NO DISA LLOWANCE CAN BE MADE U/S 40(A)(IA) OF THE ACT, ONCE PARTICULAR EXPE NDITURE HAS BEEN PAID DURING THE SAME FINANCIAL YEAR. IN THE PRESENT CAS E ON HAND, THE ASSESSEE HAS FILED A PAPER BOOK CONTAINING FINANCIA L STATEMENTS FOR THE RELEVANT FINANCIAL YEAR. ON PERUSAL OF THE FINANCIA L STATEMENTS, WE NOTICED THAT THE ASSESSEE HAS INCURRED EXPENDITURE UNDER THE HEAD RENT AND HIRE CHARGES AND THE SAME HAVE BEEN COMPLETELY PAID DURING THE SAME FINANCIAL YEAR. EVEN FOR A MOMENT, ASSUMED THA T THE ASSESSMENT ORDER IS ERRONEOUS, IT IS NOT PREJUDICIAL TO THE IN TEREST OF REVENUE, AS THE ISSUE RAISED BY THE CIT TOWARDS DISALLOWANCE U/S 40 (A)(IA) OF THE ACT IS NOT DISALLOWABLE, BECAUSE THE ASSESSEE HAS PROVED T HAT THE IMPUGNED EXPENDITURE IS PAID DURING THE SAME FINANCIAL YEAR. THEREFORE, WE ARE OF THE VIEW THAT THE ASSESSMENT ORDER PASSED BY THE A. O. IS NOT ERRONEOUS, IN SO FAR AS IT IS PREJUDICIAL TO THE INTEREST OF T HE REVENUE, AS THERE IS NO LOSS OF REVENUE ON ACCOUNT OF NON COMPLIANCE WITH T DS PROVISIONS AS ITA NO.570/VIZAG/2013 M/S. NU-TECH ENGINEERS, VISAKHAPATNAM 11 THE EXPENDITURE IS NOT DISALLOWABLE UNDER SEC. 40(A )(IA) OF THE ACT IN VIEW OF ITAT, SPECIAL BENCH DECISION. THE CIT WITHO UT APPRECIATING THE FACTS REVISED THE ASSESSMENT ORDER. HENCE, WE SET A SIDE THE ORDER PASSED BY THE CIT U/S 263 OF THE ACT AND RESTORE TH E ORDER PASSED BY THE A.O. U/S 143(3) OF THE ACT. 11. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS ALLOWED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT ON 10 TH JUN16. SD/- SD/- ( . ) ( . ) (V. DURGA RAO) (G. MANJUNATHA) /JUDICIAL MEMBER /ACCOUNTANT MEMBER # /VISAKHAPATNAM: ' /DATED : 10.06.2016 VG/SPS )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT M/S. NU-TECH ENGINEERS, 38-10-26 /1, SURYABAGH, VISAKHAPATNAM-530 020. 2. / THE RESPONDENT CIT-1, VISAKHAPATNAM 3. + ( ) / THE CIT (A), VISAKHAPATNAM 4. # . , . , # / DR, ITAT, VISAKHAPATNAM 5 . / GUARD FILE / BY ORDER // TRUE COPY // 12 . (SR.PRIVATE SECRETARY) . , # / ITAT, VISAKHAPATNAM