Sai Gayatri Projects Pvt.Ltd., Hyderabad V. Dy. Commissioner of Income Tax, Circle-3(1), Hyderabad

ITA 578/HYD/2012

• Counselvise Citation: [2012] 140 COUNSELVISE.COM (IT) 66248 (ITAT-HYDERABAD)
• Duration Of Justice: 4 month(s) 25 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-09-2012
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Assessment Year: 2007-2008
• Appeal Filed On: 19-04-2012
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: ALKA R JAIN
• Assessee Lawyers: D V ANJANEYULU
• Keywords: Corroborative evidences; Revenue expenditure
• Section: 143(3); 37(1)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER ITA NO. 578/HYD/2012 ASSESSMENT YEAR: 2007-08 SAI GAYATRI PROJECTS PVT. LTD., ... APPELLANT HYDERABAD (PAN AAGCS1498B) VS. DY. COMMISSIONER OF INCOME TAX, RESPONDENT CIRCLE 3(1), HYDERABAD. APPELLANT BY : SHRI D.V. ANJANEYULU RESPONDENT BY : SHRI ALKA R. JAIN DATE OF HEARING : 03/09/2012 DATE OF PRONOUNCEMENT : 14/09/ 2012 ORDER PER ASHA VIJAYARAGHAVAN, J.M.: THIS APPEAL IS PREFERRED BY THE ASSESSEE DIRECTED AGAINST THE ORDER OF THE CIT(A)-IV, HYDERABAD DATED 21/03/2012 FOR THE ASSESSMENT YEAR 2007-08. 2. BRIEFLY THE FACTS OF THE CASE ARE THAT THE ASSES SEE IS A PRIVATE LIMITED COMPANY ENGAGED IN THE BUSINESS OF CIVIL CONTRACTS. FOR THE YEAR UNDER CONSIDERATION, THE AS SESSEE HAD RECEIVED GROSS CONTRACT WORKS FROM TWO CONCERNS, NA MELY, I) MEHAR KIRAN ENTERPRISES LTD. RS. 2,31,27,593/- II) IRMAC SERVICES LTD., HYD RS. 7,57,12,000/- RS. 9,88,39,593/- ============ ITA NO. 578/HYD/12 SHRI GAYATRI PROJECTS PVT. LTD. 2 AND IT FILED RETURN OF INCOME ON 30/11/2007 ADMITTI NG TAXABLE INCOME OF RS. 54,86,604/-. THE ASSESSMENT WAS COMPL ETED U/S 143(3) OF THE ACT, BY THE AO DETERMINING THE TOTAL INCOME AT RS. 8,40,89,552/- BY MAKING THE FOLLOWING ADDITIONS: I) ESTIMATING THE INCOME AT 12.5% ON THE GROSS BILLS FROM M/S MEHAR KIRAN ENTERPRISES LTD. 28, 90,948 II) TREATING ENTIRE RECEIPTS AS INCOME FROM IRMAC SERVICES LTD. 7,57,12,000 THE ASSESSING OFFICER WITH RESPECT TO TREATING THE ENTIRE RECEIPTS AS INCOME FROM IRMAC SERVICES HELD AS FOLL OWS:- IT IS CONSIDERED THAT THE STATEMENTS FILED BY ASSES SEE DO NOT REFLECT THE TRUE STATE OF AFFAIRS AND EVEN IT IF WERE PRESUMED THAT SUCH PAYMENTS WERE MADE, IT IS CONSID ERED THAT THESE PAYMENTS (WHICH ARE OF THE NATURE OF ANT I-PUBLIC POLICY ARE OUTSIDE THE PARAMETERS OF LEGAL BOUNDARI ES). AS THE ENTIRE OPERATION OF THE ASSESSEE IN THIS REGARD IS SEEN TO BE A MAKE BELIEVE ARRANGEMENT BE IT THE CONTRACT AG REEMENT OR THE BEARER CHEQUE PAYMENTS TO THE SO-CALLED PE RSONS EVICTED OR TOWARDS OTHER EXPENSES SUCH AS VEHICLE H IRE, OIL & LUBRICANTS, DRILLING, ETC. THE ENTIRE EXPENDITURE IS PROPOSED TO BE DISALLOWED AS THE ALLEGED PAYMENTS A RE NOT AS PER THE TERMS OF CONTRACT AGREEMENT, OR BY THE F ACTS OF THE CASE AS DISCUSSED ABOVE, OR IN ACCORDANCE WITH PUBLIC POLICY. 3. AGGRIEVED, THE ASSESSEE CARRIED THE MATTER IN AP PEAL BEFORE THE CIT(A). 4. THE CIT(A) RESTRICTED THE ESTIMATION OF INCOME I N RESPECT OF GROSS RECEIPTS RECEIVED FROM M/S MEHAR KIRAN ENTERP RISES LTD., FROM 12.5% TO 8%. WITH RESPECT TO THE RECEIPTS FROM M/S IRMAC SERVICES LTD., THE CIT(A) HELD AS FOLLOWS:- HOWEVER, IN PAGE NO. 17 PARA NO. 6.33 THE CIT(A) WH ILE UPHOLDING THE ADDITION SO MADE BY THE ASSESSING OFF ICER CONCLUDED AND ARRIVED THAT THE APPELLANT FAILED TO DISCHARGE THE ONUS OF PROVING THAT SUCH EXPENDITURE WAS ACTUA LLY INCURRED, WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF ITS BUSINESS DURING THE YEAR. IN FACT, THE APPELLANT HA S NOT EVEN SUBMITTED PRIMARY EVIDENCE OR THE BOOKS OF ACCOUNT TO SUPPORT ITS CLAIM. AS REGARDS THE PAYMENT OF EVICTI ON ITA NO. 578/HYD/12 SHRI GAYATRI PROJECTS PVT. LTD. 3 CHARGES/COMPENSATION ETC., IN THE ABSENCE OF EVIDEN CE REGARDING PURPOSE OF PAYMENTS, THE CLAIM OF THE APP ELLANT CANNOT BE ALLOWED SOLELY ON THE BASIS OF THE FACT T HAT PART OF SUCH EXPENDITURE WAS MADE THROUGH CHEQUES. SINCE TH E APPELLANT HAS FAILED TO DISCHARGE THE ONUS OF PROVI NG THE BASIS AND PURPOSE FOR THE EXPENDITURE CLAIMED BY IT , NO INFIRMITY IS FOUND IN THE CONCLUSION OF THE ASSESSI NG OFFICER THAT THE ENTIRE EXPENDITURE CLAIMED BY THE APPELLAN T AGAINST THE RECEIPTS FROM M/S IRMAC SERVICES LTD., HAS TO B E DISALLOWED. THEREFORE, THE ACTION OF THE ASSESSING OFFICER IN CONSIDERING THE ENTIRE RECEIPTS OF RS. 7,57,12,000/ - AS INCOME OF THE APPELLANT IS UPHELD. 5. AGGRIEVED THE ASSESSEE IS IN APPEAL BEFORE US. 6. BEFORE US, THE LEARNED COUNSEL FOR THE ASSESSEE SHRI D.V. ANJANEYULU CONTENDED THAT THE AO IN THE ASSESSMENT MADE U/S 143(3) ADOPTED TWO DIFFERENT METHODS I.E. IN RESPEC T OF THE GROSS RECEIPTS FROM M/S MEHAR KIRAN ENTERPRISES LTD., HYD . RS. 2,31,27,593/- ESTIMATING THE INCOME AT 12.5% BECAUS E OF THE INABILITY OF THE ASSESSEE TO FURNISH BOOKS OF ACCOU NT, VOUCHERS WHICH COMES TO RS. 28,90,948/- AND TREATING THE EN TIRE GROSS RECEIPTS OF RS. 7,57,12,000/- RECEIVED FROM IRMAC S ERVICES LTD., HYDERABAD AS INCOME OF THE ASSESSEE AND FURTHER DIS ALLOWING THE ENTIRE EXPENDITURE. THE ASSESSING OFFICER ALLEGED T HAT THE ENTIRE EXPENDITURE IS ANTI PUBLIC POLICY, OUTSIDE THE PARA METERS OF LEGAL BOUNDARIES AND NOT AS PER THE TERMS OF CONTRACT AGR EEMENT. THE LEARNED COUNSEL SUBMITTED THAT THE ASSESSING OFFICE R CAME TO THE CONCLUSION ON THE BASIS OF NON PRODUCTION OF BOOKS OF ACCOUNT AND VOUCHERS AND ALSO IGNORING THE ASSESSEES EXPLANAT ION THAT IT WAS DUE TO THE INABILITY OF THE ASSESSEE TO FURNISH BOO KS OF ACCOUNT ETC. IT WAS FURTHER SUBMITTED THAT THE ASSESSING OF FICER IGNORED THE EXPLANATION THAT THE BOOKS WERE IN THE CUSTODY OF THE ACCOUNTANT, WHO LEFT THE ORGANIZATION AND WAS UNTRA CEABLE. THE M.D. OF THE ASSESSEE COMPANY AFFIRMED BY AN AFFIDAV IT, WHICH WAS PRODUCED BEFORE THE ASSESSING OFFICER WHEREIN HE HA D STATED AS FOLLOWS:- ITA NO. 578/HYD/12 SHRI GAYATRI PROJECTS PVT. LTD. 4 FOR THE ASSESSMENT YEAR 2007-08 I.E., 01/04/2006 TO 31/03/2008, THE ASSESSEE PREPARED THE COMPUTERIZED CASH BOOK AND LEDGER AND OTHER STATEMENTS, FURNISHED TO THE STATUTORY AUDITORS FOR THE PURPOSE OF STATUTORY AUD IT UNDER THE COMPANIES ACT AND ALSO UNDER THE INCOME TAX ACT U/S 44AB. THE AUDIT WAS COMPLETED A CERTIFICATE WAS OBT AINED FROM THE AUDITORS. HE TOOK BACK THE BOOKS OF ACCOUN T FROM THE AUDITORS OFFICE UNDER AN ACKNOWLEDGMENT BUT HE DID NOT DELIVER THE SAME TO THE ASSESSEE COMPANY. IN THE MEAN TIME, I.E., IN JANUARY, 2008, SUDDENLY HE FELL SICK AND AS HIS HEALTH WAS DETERIORATING, HE LEFT H YDERABAD FOR HIS NATIVE PLACE SAID TO BE NELLORE SINCE THEN HE DID NOT TURN DOWN AND HIS WHEREABOUTS WERE NOT KNOWN TO THE ASSESSEE COMPANY. THE BOOKS WERE KEPT WITH HIM AND HE DID NOT RETURN THE SAME TO THE ASSESSEE COMPANY. THEREF ORE, THE ASSESSEE COMPANY IS NOT IN POSSESSION OF ITS BO OKS OF ACCOUNT FOR THE FINANCIAL YEAR 2006-07 AND HENCE FU RNISHING OF ACCOUNT BOOKS IS BEYOND ITS CONTROL. 7. THE LEARNED COUNSEL SUBMITTED THAT THE ASSESSEE UNDERTOOK AN AGREEMENT WITH THE IRMAC SERVICES LTD., ON 08/03 /2007, ACCORDING TO WHICH THE ASSESSEE HAS TO CLEAR THE LA ND AND LEVEL THE ENTIRE SITE, WHICH BELONGED TO THE OWNER, AND W HICH WAS COMPLETELY OCCUPIED BY ILLEGAL ENCROACHERS, WHO HAD CONSTRUCTED HUTS AND TENEMENTS ETC. IT WAS SUBMITTED THAT FOR C LEARING ALL ILLEGAL ENCROACHMENTS, FOR REMOVING BOUNDARIES AND BUNDS FORMED BY ENCROACHERS, THE FOLLOWING EXPENSES WERE INCURR ED: 1) LABOUR AND EVICTIONS CHARGES 2,05,50,000 2) DRILLING AND BLASTING EXPENSES 1,28,14,820 3) VEHICLE HIRE CHARGES 2,24,89,760 4) OILS, LUBRICANTS, MATERIAL ETC. 93,43,295 8. THE LEARNED COUNSEL SUBMITTED THAT A PER THE AGR EEMENT, THE SCOPE OF THE WORK, THAT HAS BEEN UNDERTAKEN BY THE ASSESSEE IS AS FOLLOWS: I) REMOVE THE ILLEGAL OCCUPANTS. II) REMOVE ILLEGAL STRUCTURES. ITA NO. 578/HYD/12 SHRI GAYATRI PROJECTS PVT. LTD. 5 III) REMOVE BOUNDARIES AND BUNDS FORMED BY ENCROACH ERS IV) MANAGEMENT OF LOCAL OFFICIALS. V) MANAGEMENT OF POLITICIANS VI) REHABILITATION OF EXISTING OCCUPANTS WITHOUT AN Y COMPLAINTS TO LANDLORD VII) HANDING OVER PEACEFUL AND VACANT POSSESSION OF LAND TO THE OWNER VIII) GETTING NO CLAIM CERTIFICATE FROM ILLEGAL OCC UPANTS. 9. THE LEARNED COUNSEL TOOK US THROUGH THE SCOPE OF WORK AS PER THE AGREEMENT. HE SUBMITTED THAT AS PER CLAUSE- 4 OF THE SAID AGREEMENT THE FEES PAYABLE TO THE ASSESSEE IS RS. 7 ,50,00,000/-, AND THE OWNER HAS GIVEN AN AMOUNT OF RS. 7,40,00,00 0/-, AS LOAN TO THE CONTRACTOR BEARING AN INTEREST BEARING AN IN TEREST OF 18% PER ANNUM WITH A CONDITION THAT IF THE ASSESSEE FAI LS TO EXECUTE THE CONTRACT WITHIN THE STIPULATED TIME AS PER THE CLAUSE-10 OF THE AGREEMENT, (WHICH IS 30 DAYS FROM THE DATE OF CONTR ACT), THE OWNER HAS THE RIGHT TO RECOVER THE LOAN WITH INTERE ST @18% . IT WAS CLAIMED THAT THE ENTIRE EXPENDITURE WAS FOR THE PURPOSE OF BUSINESS AND THE AMOUNT WAS PAID TO IDENTIFIABLE PE RSONS TO EVICT THE ILLEGAL OCCUPANTS OF THE PROPERTY AND WAS AN A LLOWABLE EXPENDITURE. 10. THE LEARNED COUNSEL SUBMITTED THAT THE SCOPE OF WORK ALSO INCLUDED MANAGEMENT OF LOCAL OFFICIALS AND POLITICI ANS, THEREFORE, THE SAME WOULD NOT BE TAKEN AS BRIBE AND CANNOT BE PRESUMED THAT THE EXPENDITURE IS TOWARDS ANT-PUBLIC POLICY. IT WAS FURTHER SUBMITTED THAT RELIEF MAY BE GRANTED BY ESTIMATING THE INCOME IN RESPECT OF RECEIPTS FROM M/S IRMAC SERVICES LTD AT 8% AS IN THE CASE OF MEHAR ENTERPRISES, ESPECIALLY SINCE THE P& L ACCOUNT FOR BOTH THE WORKS IS ONE AND COMMON. THE LEARNED COUNS EL FOR THE ASSESSEE SUBMITTED THAT ESTIMATION OF INCOME WITHOU T GIVING ANY ITA NO. 578/HYD/12 SHRI GAYATRI PROJECTS PVT. LTD. 6 SHOW CAUSE NOTICE IS BAD IN LAW RELYING UPON THE DE CISION OF IN THE CASE OF ZENITH PROCESSING MILLS LTD. VS. CIT, 2 19 ITR 721(GUJ). IT WAS, THEREFORE, ARGUED THAT ESTIMATION OF INCOME AS WELL AS TREATING THE ENTIRE GROSS RECEIPTS AS INCOM E WITHOUT CONSIDERING THE RELATED EXPENDITURE IS BAD IN LAW A ND NEEDS TO BE DELETED. 11. THE LEARNED COUNSEL CONTENDED THAT REJECTION OF AFFIDAVIT IS AGAINST THE SETTLED PROPOSITION IN THE CASE OF SOHA N LAL GUPTA VS. CIT, 33 ITR 786 AND IN THE CASE OF CASE OF CANARA BAN VS. ITO, 121 ITD 47 (NAG.), AND THAT THE ASSESSING OFFICER OUGHT TO HAVE CONSIDERED THE AFFIDAVIT SWORN BY THE M.D. OF THE A SSESSEE COMPANY. HE ALSO RELIED UPON THE FOLLOWING CASE LAW S: 1. BIKANER GYPSUMS LTD. VS. CIT187 ITR 39 (SC) 2. EASTERN CONSTRUCTIONS CO. VS. ITO, 59 TTJ 723(D EL.) 3. AIRPORT AUTHORITY OF INDIA VS. CIT, [2012] 66 DTR(DEL)(FB) 440. 12. THE LEARNED COUNSEL FOR THE ASSESSEE ALSO RELIE D UPON THE CBDT INSTRUCTION NO. 574, DT. 27/07/1973. 13. ON THE OTHER HAND, THE LEARNED DR SMT. ALKA R. JAIN PLACED RELIANCE ON THE ORDERS OF THE AUTHORITIES BELOW. 14. WE HAVE HEARD THE ARGUMENTS OF BOTH THE PARTIES , PERUSED THE RECORD AND GONE THROUGH THE ORDERS OF THE AUTHO RITIES BELOW AS WELL AS THE DECISIONS CITED. WE FIND THAT IT HAS NOT BEEN ESTABLISHED THAT THE AMOUNTS PAID TO THE MANAGEMENT S OF LOCAL OFFICIALS AND POLITICIANS FORMS A SUBSTANTIAL PART OF THE EXPENDITURE. ON PERUSAL OF THE RECORD, THE AO INDIC ATED THAT THE AMOUNTS WERE PAID EVEN PRIOR TO THE COMMENCEMENT OF THE AGREEMENT AND THE AFFIDAVIT BY THE MD THAT THE ASSE SSEE COMPANY ITA NO. 578/HYD/12 SHRI GAYATRI PROJECTS PVT. LTD. 7 IS NOT IN A POSITION TO FURNISH THE BOOKS OF ACCOUN T FOR THE YEAR CONSIDERATION WOULD ONLY SHOW THAT THE ONUS HAS NOT BEEN DISCHARGED BY THE ASSESSEE WITH RESPECT TO THE EXPE NDITURE. THE PAYMENTS TOWARDS DRILLING AND BLASTING EXPENSES OF RS. 1,28,14,820/-, VEHICLE HIRE CHARGES OF RS. 2,24,89, 760/- AND OILS, LUBRICANTS, MATERIAL ETC. OF RS. 93,43,295/- COULD NOT BE CORRELATED WITH THE WORK SPECIFICATIONS IN THE AGRE EMENT AND ARE FOUND TO BE DISPROPORTIONATE IN THE ABSENCE OF BOOK S OF ACCOUNT AND VOUCHERS TO SUBSTANTIATE THE GENUINENESS OF THI S EXPENDITURE. THE ASSESSEE COULD NOT DEMONSTRATE BEFORE THE LOWER AUTHORITIES THE FACT OF EXISTENCE OF ILLEGAL OCCUPANTS, STRUCTU RES, ENCROACHMENT, ETC. WHICH WOULD WARRANT SUCH HUGE EX PENDITURE AND THE ASSESSEE FAILED TO DISCHARGE THE ONUS OF PR OVING THAT SUCH EXPENSES WERE ACTUALLY INCURRED WHOLLY AND EXCLUSIV ELY FOR THE PURPOSE OF BUSINESS DURING THE YEAR. THE PAYMENT O F EVICTION CHARGES/COMPENSATION HAS TO BE ESTIMATED IN THE ABS ENCE OF EVIDENCE/BOOKS OF ACCOUNT TO SUPPORT THE CLAIM OF T HE ASSESSEE AND THE CLAIM OF THE ASSESSEE CANNOT BE ALLOWED SOL ELY ON THE BASIS OF THE FACT THAT PART OF SUCH EXPENDITURE WAS MADE THROUGH CHEQUES. THE JURISDICTIONAL HIGH COURT IN THE CASE OF TCI VS. CIT, 256 ITR 701 HAS HELD THAT MERE PAYMENT BY ITSELF WO ULD NOT ENTITLE THE ASSESSEE TO DEDUCTION OF EXPENDITURE UN LESS THE SAME WAS PROVED TO BE PAID FOR COMMERCIAL CONSIDERATIONS . 15. TAKING INTO CONSIDERATION THE NATURE OF THE WO RK, WHICH INVOLVED THE FOLLOWING STEPS: 1) BRINGING THE ILLEGAL OCCUPANTS TO THE NEGOTIATIN G TABLE EITHER THROUGH FORCE, PERSUASION EXECUTED THROUGH L OCAL LEADERS. 2) ONCE THE DEAL IS FINALIZED PAYING THEM THE NEGOT IATED AMOUNT IMMEDIATELY GETTING A NO OBJECTION CERTIFICA TE, OR RELEASE OR RIGHT CERTIFICATE. ITA NO. 578/HYD/12 SHRI GAYATRI PROJECTS PVT. LTD. 8 3) IMMEDIATELY IRRESPECTIVE OF THE TIME DAY & NIGHT WE HAVE TO DEPLOY PEOPLE AND MACHINERY TO DISMANTLE THE STR UCTURE REMOVE THE BOUNDARY WALLS, BUNDS ETC., EXISTING ON THIS ILLEGAL OCCUPANTS OCCUPIED LAND. FOR THIS PURPOSE, WE NEED TO KEEP WORK FORCE, MACHINERY READY THOROUGH MAINTAINI NG IDLY BECAUSE WE DO NOT KNOW WHEN THESE OCCUPANTS WILL CO ME AND GIVEN THEIR CONSENT TO HAND OVER THE POSSESSION . AFTER CLEARING THE LAND WE HAVE TO KEEP OUR PEOPLE AS SEC URITY SO THAT NO NEW PERSON WILL COME AND AGAIN OCCUPY AND E RECT STRUCTURES. 16. THE ASSESSEE HAS BROUGHT TO OUR NOTICE THAT THE ASSESSEE WAS FORCED TO PAY NOT ONLY HIGHER PRICES BUT ALSO P AYMENT HAD TO BE DONE IMMEDIATELY AFTER THE WORK IS COMPLETED AND AS THERE WAS NO BANK IN THE VICINITY OF THE VILLAGE WHERE TH E WORK HAS BEEN EXECUTED I.E. JALPALLY VILLATE, SAROORNAGAR MANDAL, RR DT., AMOUNTS HAD TO BE PAID BY CASH. WE ARE OF THE OPINI ON THAT CERTAIN EXPENSES WOULD HAVE BEEN NECESSITATED FOR THE PURPOSE RETRIEVING THE LAND FROM ILLEGAL OCCUPANTS. WE CANN OT RULE OUT THE POSSIBILITY OF INFLATION OF THE EXPENDITURE BY THE ASSESSEE. HOWEVER, CONSIDERING THE VERY TYPICAL AND UNPRECEDE NTED CIRCUMSTANCES IN THIS CASE, A FAIR ESTIMATE CAN BE MADE OF THE PROBABLE EXPENDITURE IN THE ABSENCE OF BOOKS OF ACC OUNT AND SUPPORTING EVIDENCES BY THE ASSESSEE. IN OUR OPINIO N, IT WOULD BE JUST AND PROPER TO RESTRICT THE DISALLOWANCE TO 50% OF THE EXPENDITURE CLAIMED BY THE ASSESSEE AND DIRECT THE ASSESSING OFFICER TO ALLOW THE SAME AS REVENUE EXPENDITURE, A S THE EXPENDITURE BY THE ASSESSEE INCURRED DURING THE COU RSE OF BUSINESS TO CARRY ON THE BUSINESS WOULD BE ALLOWABL E U/S 37(1) OF THE IT ACT. ITA NO. 578/HYD/12 SHRI GAYATRI PROJECTS PVT. LTD. 9 17. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. PRONOUNCED IN THE OPEN COURT ON 14/09/2012. SD/- SD/- ( CHANDRA POOJARI) (ASHAVIJAYARAGHAVAN) ACCOUNTANT MEMBER JUDICIAL MEMBER HYDERABAD, DATED: 14 TH SEPTEMBER, 2012. KV COPY TO:- 1) SAI GAYATRI PROJECTS PVT. LTD., PRASASHAN NAGAR, JUBILEE HILLS, HYDERABAD 500 033. 2) DCIT, CIRCLE-3(1), HYDERABAD. 3) THE CIT (A)-IV, HYDERABAD 4) CIT-III, HYDERABAD 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDERABA D.